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PACKAGING – Who takes care of your duties?

Originally published by ProductIP, this article is about the responsibilities related to the packaging of products sold in the European Union.

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.

EU's PPWD aims to reduce packaging amounts.

Packaging Reduction 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 Packaging 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 Handling Packaging

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).

Packaging handling costs are computed based on the "polluter-pays" principle.

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 Packaging 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 following section 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; below overview is non-exhaustive.

Mandatory Waste 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.

Different EU Member States hold different regulations regarding packaging.

Packaging Waste Prevention 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)

www.ara.at 

Belgium

FOST-Plus

www.fostplus.be

Bulgaria

EcoPack

www.ecopack.bg

Croatia

EKO OZRA

www.eko-ozra.hr

 

Cyprus

Green Dot (Cyprus)

greendot.com.cy

Czech Republic

EKO-KOM

www.ekokom.cz

Denmark

Dansk Retursystem

www.danskretursystem.dk

 

Estonia

Eesti Taaskasutusorganisatsioon (ETO)

www.eto.ee

Finland

RINKI

rinkiin.fi

 

France

CITEO (Eco emballages)

www.ecoemballages.fr

Germany

Duales System Deutschland (DSD)

www.gruener-punkt.de

Greece

HE.R.R.CO

www.herrco.gr

Hungary

NWMD / OKTF-NHI (or Ökopannon)

www.szelektivinfo.hu

 

Ireland

REPAK

repak.ie

Italy

CONAI

www.conai.org

 

Latvia

Latvijas Zaļais Punkts

www.zalais.lv

Lithuania

Žaliasis taškas

www.zaliasistaskas.lt

Luxembourg

Valorlux

www.valorlux.lu

Malta

GreenPak

www.greenpak.com.mt

Netherlands

Afvalfonds Verpakkingen

afvalfondsverpakkingen.nl

 

Norway

Grønt Punkt Norge (GPN)

www.grontpunkt.no

Poland

RekoPol Organizacja Odzysku

www.rekopol.pl

Portugal

Sociedade Ponto Verde

www.pontoverde.pt

Romania

ECO-ROM Ambalaje

ecoromambalaje.ro

Slovakia

ENVI-PAK

envipak.sk

Slovenia

SLOPAK

www.slopak.si

Spain

Ecoembes

www.ecoembes.com

Sweden

FTI (REPA scheme)

www.ftiab.se

    

Countries where Green Dot is available are indicated with the symbol

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.  

Caspar ter Horst – Managing Director, ProductIP

Caspar ter Horst – Managing Director, ProductIP

Casper has 25+ years of experience in product compliance. In 2008, he co-founded ProductIP together with Maarten van der Dussen. Caspar and his team are dedicated to support companies within the supply chain to efficiently demonstrate to customers, authorities, and users that their products meet applicable legislation and buying requirements. As a result, helping companies reduce costs, streamline operations, manage suppliers, and at the same time put compliant, safer, more sustainable products to the market.

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Disclaimer

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

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