A guide into stress-free product compliance

PACKAGING - Who takes care of your duties?

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

About the responsibilities related to the packaging of products sold in the European Union

Objectives

The EU's Packaging and Packaging Waste Directive (PPWD) 94/62/EC aims to reduce the impact of packaging (waste) to the environment.
The first priority is to reduce packaging amounts. Packaging shall be limited to the minimum volume and weight while still maintaining an adequate level of safety, hygiene and practicality.
And disposal of packaging waste must be limited.
This can be realised by reuse of packaging; recovery via material recycling, composting or energy (incineration). No hazardous substances are allowed either.
The PPWD restricts the presence of dangerous substances and heavy metals in packaging. In addition to the other chemical legislation such as the REACH and POP Regulations that apply also to packaging.

Targets

The PPWD sets targets for each Member State.
For instance, recycle at least 65% of all packaging waste before the end of 2025, and 70% five years later.
Each Member State must implement measures to attain the targets in their territory.

National measures

Member States have implemented measures to prevent packaging waste and to minimise the environmental impact of packaging. Examples are national systems for the collection of used packaging from the consumer. Participation of producers, consumers, organisations and authorities is essential to make systems successful.
The "polluter-pays" principle applies here too.
This is anyone who places packaging on the national market that will become waste after use (unpacking).


The costs involved

In most cases fees must be paid to the packaging recovery organisations that take care of the tasks.
The costs in euro per kg vary for each sort of packaging material. Additional minimum, flat or standards fees and various discounts may be applicable.
In a few countries the waste schemes are run by municipalities and producers have to pay contributions or taxes to local or national authorities (funds).

Extended Producer Responsibility

Extended Producer Responsibility (EPR) is an important element in the circular economy. EPR extends the producer's responsibility past the end of the product's lifecycle to the disposal and recycling of the product.

In May 2018 the PPWD was amended on EPR:
"Member States shall ensure that, by 31 December of 2024, Extended Producer Responsibility schemes are established for all packaging."
The reality is that almost all Member States have already implemented EPR schemes years ago.

National schemes

Several Member States allow producers to take care of all the responsibilities themselves. But in practice producers join available national waste recovery schemes and benefit from economies of scale.
The next page contains an overview of organisations that run schemes for household packaging, such as "Green Dot" that is available in many countries. Other organisations may provide similar services; the overview on the next page is non-exhaustive.

Mandatory registrations

Member States must keep track of all producers and their waste streams in order to fulfil their reporting obligations. For this reason, producers must register themselves. Germany recently updated the registration obligations: Verpackungsregister.

Exemptions

Some Member States have exempted companies from the obligations based on the amount of packaging (thresholds from zero to 50 tonnes) or based on the annual turnover of the company.
The differences between them are considerable.

Policies

Authorities are increasingly asking for environmental policies and packaging waste prevention plans. In some cases this obligation is implemented in legislation. Companies or trade associations have to present plans that define measurable objectives and they have to report about the progress of the implementation. Do not be surprised - but be prepared - if a question about waste policies arises during surveillance audits.

Non-exhaustive overview of national service providers

Austria

Altstoff Recycling Austria (ARA)

green dot

Belgium

FOST-Plus

green dot

Bulgaria

EcoPack

green dot

Croatia

EKO OZRA

 

Cyprus

Green Dot (Cyprus)

green dot

Czech Republic

EKO-KOM

green dot

Denmark

Dansk Retursystem

 

Estonia

Eesti Taaskasutusorganisatsioon (ETO)

green dot

Finland

RINKI

 

France

CITEO (Eco emballages)

green dot

Germany

Duales System Deutschland (DSD)

green dot

Greece

HE.R.R.CO

green dot

Hungary

NWMD / OKTF-NHI (or Ökopannon)

 

Ireland

REPAK

green dot

Italy

CONAI

 

Latvia

Latvijas Zaļais Punkts

green dot

Lithuania

Žaliasis taškas

green dot

Luxembourg

Valorlux

green dot

Malta

GreenPak

green dot

Netherlands

Afvalfonds Verpakkingen

 

Norway

Grønt Punkt Norge (GPN)

green dot

Poland

RekoPol Organizacja Odzysku

green dot

Portugal

Sociedade Ponto Verde

green dot

Romania

ECO-ROM Ambalaje

green dot

Slovakia

ENVI-PAK

green dot

Slovenia

SLOPAK

green dot

Spain

Ecoembes

green dot

Sweden

FTI (REPA scheme)

green dot

United Kingdom

VALPAK

www.valpak.co.uk green dot

 

Countries where Green Dot is available are indicated with the symbol Packaging who takes care of your duties

In Spain the only provider of an Integrated Management System (SIG) according to the Packaging Law 11/1997 is Ecoembalajes España, S.A. This organisation requires use of the Green Dot symbol making it mandatory for packaging in Spain.

In Cyprus the only provider of a Collective Packaging Management System according to The Packaging (Waste) Law 32/2002 is Green Dot Cyprus. As a result the Green Dot symbol is mandatory for packaging in Cyprus.

Useful links: ec.europa.eu europen-packaging.eu www.expra.eu www.pro-e.org


Share this post via:
       

0 found this article helpful

Was this article helpful?

Thank you for your feedback!