In this edition, we continue to offer our subscribers specialized information on EPR compliance.
If you have any questions, our experts are available for personal consultation.
Today's topics at a glance
Expansion of Our Services: Authorisation under EWKFondsG for foreign companies in Germany
France: Ban on non-recyclable polystyrene packaging postponed
Germany: New regulations on the disposal of electrical appliances, batteries and disposable e-cigarettes
Denmark: New regulations on EPR for packaging and single-use plastic products
Austria: Deposit on single-use plastic and metal beverage containers
Fresh Up - Reminders / Dates
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Deutsche Recycling
Expansion of Our Services: Authorisation under EWKFondsG for foreign companies in Germany
We are pleased to offer foreign companies the takeover of authorization under EWKFondsG and all associated obligations as part of our full-service offering.
Our Full-Service Offer in Detail:
Assumption of statutory manufacturer obligations
Legal review of the assessment notices from the Federal Environment Agency
Payment of the assessed fees according to the assessment notice
Consultation on all questions regarding the assumption of authorization
Support with initial inquiries regarding quantity verification by an expert, auditor, or tax advisor
Process support for our clients
Deutsche Recycling provides you with a fast and cost-effective solution that covers all aspects of the application process.
France: Ban on non-recyclable polystyrene packaging postponed
The French government has officially announced the postponement of the ban on non-recyclable packaging made from styrene polymers or copolymers, moving the deadline from 2025 to 2030.
Impact on Industry and the Environment
The postponement is intended to give the industry more time to adapt its processes and technologies to improve the recyclability of polystyrene packaging. At the same time, the goal remains to minimize the environmental impact of these materials and promote a circular economy.
If you're uncertain about your company's obligations or need support in complying with EU regulations, Deutsche Recycling Service GmbH is here to assist you as a trusted partner.
Germany: New regulations on the disposal of electrical appliances, batteries and disposable e-cigarettes
This includes uniformly labeled collection points and better information provided in retail outlets. A key focus is on the safe disposal of batteries to reduce fire risks from improperly discarded or damaged batteries.
The new regulations impose additional obligations on distributors of electronic devices, batteries, and disposable e-cigarettes:
Extended Take-Back Obligation: Distributors must ensure that consumers can return their used electronic devices and disposable e-cigarettes at all sales points. This applies regardless of whether the device was purchased at that location or whether a new device is being bought. This obligation also includes smaller outlets, such as kiosks or gas stations.
Labeling of Collection Points: Sales locations must clearly mark collection points for electronic devices, making it easier for consumers to return them. Distributors are responsible for ensuring that these collection points are highly visible and clearly marked.
Point-of-Sale Information: Distributors must clearly inform consumers at the point of sale—such as on shelves—that the purchased electronic device must be disposed of separately. This is communicated via the "crossed-out wheeled bin" symbol.
Safety Measures for Batteries: Electronic devices sold with batteries are subject to stricter disposal safety requirements. Distributors must ensure that consumers are informed about the correct disposal of lithium batteries to minimize fire risks.
It is important for your company to start preparing now for the upcoming changes. Our experts are available to assist you if you need support.
Denmark: New regulations on EPR for packaging and single-use plastic products
From January 1, 2025, the new Extended Producer Responsibility (EPR) regulations for packaging and single-use plastic products will officially come into effect in Denmark, fully extending their scope by October 1, 2025.
The Single-Use Plastics Directive introduces new rules and requirements for specific single-use plastic products and fishing gear in Denmark.
Affected products
As of December 31, 2024, the extended producer responsibility applies to the following six single-use plastic products:
Balloons (excluding those for industrial or other commercial uses not sold to consumers)
Beverage cups, including lids and closures, whether sold filled or empty
Beverage containers up to 3 liters, including:
Beverage bottles and composite packaging such as drink cartons with lids and closures. This excludes glass or metal containers with plastic closures.
Food containers, with or without lids, intended for:
Immediate consumption on-site or as take-away meals
Typically consumed directly from the container without further preparation like cooking or heating
Wet wipes for personal care and household purposes
Lightweight plastic bags with a wall thickness of less than 50 microns
What Are the Obligations?
Under these new regulations, companies that first place packaging on the Danish market will be subject to extended producer responsibility (EPR). This means businesses must cover the costs for the collection, sorting, and recycling of packaging waste, either individually or by participating in a return system.
Affected companies are required to register with the Danish Producer Responsibility system (Dansk Producentansvar - DPA).
Is your company a distributor of packaging in Denmark and unsure about your obligations or compliance? We're here to help. Simply contact us for assistance.
Austria: Deposit on single-use plastic and metal beverage containers
The Deposit Ordinance for single-use beverage packaging in Austria, which came into force on September 26, 2023, establishes the legal framework for introducing a deposit system on certain single-use beverage containers.
The aim is to reduce the proportion of single-use packaging in waste and promote the recycling of materials such as plastic and aluminum.
Affected products
The deposit system in Austria applies to the following types of packaging:
PET Bottles: Primarily made of plastic, these are commonly used for mineral water, soft drinks, and other non-alcoholic beverages.
Aluminum Cans: Includes cans for soft drinks, beer, and other beverages sold in single-use packaging.
Obligations for Initial Distributors
Companies that first place deposit-eligible single-use beverage packaging on the Austrian market must comply with the following key obligations:
Registration Requirement: Since June 2024, companies must register both their business and the products they distribute. Without this registration, products cannot be sold in Austria.
Deposit Requirement: A deposit of €0.25 must be charged when selling deposit-eligible packaging. Supermarkets and other retailers are required to accept returns of empty packaging.
Transition Period: Products bottled before April 1, 2025, can be sold without a deposit until December 31, 2025.
Authorised Representative: Foreign companies must appoint an authorised representative to ensure compliance with the obligations in Austria.
Labeling Requirement: Deposit-eligible packaging must be marked with a deposit symbol and a barcode. Specific guidelines regarding placement and color must be followed to ensure clear and correct labeling.
These regulations are designed to ensure the effective implementation of the deposit system, promoting the return and recycling of single-use beverage packaging and reducing environmental impact.
If you need assistance with regulatory compliance, our experts are available to guide you through the process and ensure your company meets the requirements. Click the button below to submit a free inquiry and get support.
Spain - EPR for packaging: Labelling will be mandatory from January 2025. All packaging must be clearly visible and legibly labelled with a pictogram indicating the intended disposal container.
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