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
Denmark: EPR regulations for single-use plastic products
Germany: New rules for better collection of e-bike or e-scooter batteries
France: European Commission criticises Triman symbol
Northern Ireland: The Windsor Framework - impact from July 2025
❗Austria: Changes in the area of textile waste from 2025 (updated)
Slovenia: New battery regulation
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Denmark: EPR regulations for single-use plastic products
In Denmark, new rules on extended producer responsibility for packaging and single-use plastic products will come into force by 2025 at the latest.
Extended producer responsibility for single-use plastic products
Extended producer responsibility is planned for the following 6 single-use plastic products from 31 December 2024:
Balloons, except balloons for industrial or other commercial use and purposes that are not sold to consumers.
Beverage cups, including lids and caps, sold full or empty.
Beverage containers with a volume of up to 3 litres. These include beverage bottles and composite packaging such as beverage cartons, including lids and caps. However, they do not include beverage containers made of glass or metal with plastic lids or caps.
Food containers, or containers with or without lids for food, that
a) are intended to be consumed immediately on site or taken away as take-out (dishes) and
b) are usually consumed out of the packaging and
c) are consumed without further preparation, such as cooking, boiling or heating.
Wet wipes for personal and household care.
Light plastic carrier bags, or plastic carrier bags with a wall thickness of less than 50 microns.
The legislation implementing producer responsibility for packaging in Denmark is being enacted in two phases. The first phase has already been completed and the regulation on the registration and reporting of packaging came into force on 1 April 2024.
The second part of the regulation is scheduled to come into force on 1 October 2025, and will set out the framework for, among other things, take-back systems, compensation, producer responsibility for beverage cups and criteria for environmental pollution.
It is important that affected companies act in a timely manner to remain compliant. Our experts are happy to assist you in implementing the necessary measures. Make a free enquiry now.
Germany: New rules for better collection of e-bike or e-scooter batteries
At the beginning of November, the German government adopted amendments to national battery legislation in order to implement the new EU Battery Regulation. This regulation promotes the sustainable handling of batteries along their entire value chain.
The new Battery Implementation Act (BattDG) replaces the previous Battery Act (BattG) and will come into force on 18 August 2025.
Effects for distributors:
Increased responsibility for the collection, recycling and correct disposal of batteries of all categories, including lithium-containing batteries.
Introduction of security deposits for producer responsibility organisations.
Extended requirements for compliance, due diligence and substance restrictions.
Option to set up your own organisations for take-back and disposal.
The adaptation of the legal framework brings clearer responsibilities and improves the possibilities for consumers and manufacturers to handle batteries sustainably. This promotes recycling and separate collection in order to minimise the extraction of raw materials, as well as strengthening compliance with the new EU regulations.
Deutsche Recycling offers a legal monitoring service that provides relevant information and supports implementation. If you have any questions, please do not hesitate to contact our consulting team.
France: European Commission criticises Triman symbol
The French regulations on the Triman symbol and the sorting instructions for packaging and products are being criticised by the European Commission because they could violate the principle of the free movement of goods in the EU internal market.
These requirements were introduced under the French AGEC law and affect products that fall under extended producer responsibility. They require the Triman logo and specific sorting instructions on packaging and products in the B2C sector.
The Commission's main criticisms are:
Barriers to the free movement of goods: National labelling requirements such as the Triman symbol could affect intra-European trade because they force companies to make product-specific adjustments for the French market. This results in a fragmented single market.
Environmental concerns: The regulations may lead to higher material consumption and more packaging waste, as additional labels or larger packaging is needed.
Lack of alignment with EU rules: France did not notify the Commission of these regulations in time, as required by the Transparency Directive (EU 2015/1535).
Despite the infringement proceedings that have been launched, the French regulation remains in force. Companies selling products in France must continue to use the Triman symbol.
Does your company sell in France and are you unsure about your obligations? We are happy to help. Please contact us.
Northern Ireland: The Windsor Framework - impact from July 2025
The Windsor Framework has a direct impact on companies that trade with Northern Ireland, both within the EU and outside (e.g. in the UK or other non-EU countries).
Labelling requirement
Products destined exclusively for the Northern Irish market must be labelled to indicate that they are for use only in Northern Ireland (e.g. ‘UK(NI)’). This labelling distinguishes them from goods that may be imported into the EU.
The introduction of the labelling requirement will be phased in, with a start date of 1 July 2025.
Products affected
The Windsor framework agreement mainly affects the following categories:
Food and agricultural products: Simplified certification procedures for goods such as meat, dairy products and plants.
Medicines: Ensuring that British medicines can continue to be supplied to Northern Ireland.
Goods at risk at customs: Goods that could potentially enter the EU via Northern Ireland (via the Red Lane) will continue to be subject to EU customs regulations.
Products with specific EU standards: electronics, toys, textiles and other regulated goods.
Impact on EU traders
For EU traders exporting goods to Northern Ireland, most of the previous arrangements remain unchanged, as Northern Ireland continues to be part of the EU single market for goods. This means that products must continue to comply with EU rules.
Impact on non-EU traders
Non-EU traders who want to export goods to the EU or Northern Ireland must continue to ensure that their products meet EU standards, particularly in sensitive areas such as toys, electronics, chemicals and food. If they can prove that their goods remain exclusively in Northern Ireland, they will benefit from fewer controls and tariffs (green lane).
If you need assistance with compliance in Northern Ireland, our experts are on hand to guide you through the process and ensure that your company meets the requirements. Simply contact us via chat, email, contact form or phone.
From 2025, the separate collection of textiles will be mandatory in Austria, as prescribed by the EU Waste Framework Directive (2008/98/EC). This should increase the recycling rate and reduce the environmental impact of textile waste.
Mandatory separate collection
A key aspect of the EU requirements is the mandatory separate collection of textiles by 2025 at the latest. The aim is to recycle or reuse used textiles efficiently.
Which product categories could be affected?
The separate collection requirement is likely to affect:
Clothing and shoes
Home textiles such as bed linen, curtains and carpets
Accessories and other textile products
Is there an EPR scheme for textiles in Austria?
Currently, there is no specific EPR scheme (extended producer responsibility) for textiles in Austria, as it already exists in France, for example. Nevertheless, it is expected that from 2025, separate collection could also place financial and organisational demands on companies.
It is important for your business to prepare for the upcoming changes now. Our experts are happy to help if you need support with the EPR scheme for textiles. Click on the button below now to make a free enquiry.
With the implementation of the EU Battery Regulation (Regulation (EU) 2023/1542), Slovenia is introducing new legal requirements for the production, labelling and disposal of batteries from October 2024. Companies will have to make extensive adjustments to comply with the new requirements.
The regulations affect:
Battery manufacturers, including those that sell through marketplaces.
Companies that import batteries and distribute them in Slovenia.
Both B2B and B2C sales – regardless of the distribution channel.
Foreign companies must also register, set up a branch in Slovenia or appoint an authorised representative.
The new obligations
Registration requirement: From 18 August 2025, all manufacturers and importers must register in the Slovenian national register.
Marking and labelling: Batteries must bear the CE marking in accordance with EU requirements. All labelling and product information must be available in Slovenian. The contact details of the manufacturer or importer must be clearly visible.
Technical requirements: Manufacturers and importers must ensure that batteries:
Comply with material restrictions (e.g. avoid heavy metals).
Include information on carbon footprint and recycled content.
Meet performance and durability standards.
Provide health and lifespan information.
Cooperation with take-back systems
Companies must become part of an authorised take-back system. These systems take care of collection, recycling and reporting.
Penalties for violations
The new regulations will be strictly enforced. Violators face fines of €1,200 to €40,000.
The full implementation of the requirements is expected from August 2025, with a final price list for participation in take-back systems. Companies that take action today can avoid unnecessary fines while supporting their sustainability goals.
Do you have any questions about the battery regulation in Slovenia? Contact us for support in implementing the new obligations.
Herstellerpflichten in der Türkei und im Westbalkan
On Thursday, 5 December 2024 at 10:30, Sascha Aue will present which regulations apply in Turkey and the Western Balkans in the areas of WEEE, packaging and batteries.
Find out how you as a company can efficiently master the specific requirements of the target market.
Register now and secure your place in the webinar!
On Thursday, 12 December 2024 at 10:30 a.m., our expert Sascha Aue will provide you with a valuable overview of the latest regulations in the areas of WEEE, packaging and batteries.
Find out how you can successfully meet the various requirements and ensure your legal compliance.
Secure your place on the webinar and get direct feedback from our expert.
Germany – Stiftung ear: Stiftung ear has announced that no new fee regulation will come into force on 1 January 2025. The fees will not be adjusted until August 2025 and will be linked to the amendment of the Battery Act.
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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