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
EU: Amazon is discontinuing EPR services – what does this mean for sellers?
EU: Final adoption of the new EU Packaging Regulation
EU: New General Product Safety Regulation
Germany: The Single-Use Plastics Fund Act – What you need to know
Portugal: Labelling requirement postponed until end of 2025
Sweden: EPR for textiles - new regulation from 1 January 2025
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Mit freundlichen Grüßen 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.
EU: Amazon is discontinuing EPR services – what does this mean for sellers?
Amazon has informed its merchants that Extended Producer Responsibility (EPR) services will be discontinued as of 31 December 2024.
What does this mean for sellers?
For new merchants: The ‘EPR Services on Amazon’ programme is closed to new registrations.
For existing merchants: Amazon sellers who have previously used this programme will need to find a new provider in order to continue to comply with EPR regulations.
As experienced EPR experts, we provide comprehensive support to help you comply with all legal requirements. Our services include:
Registration and licensing of WEEE/electrical appliances, batteries, packaging, furniture, textiles and other product categories.
Appointing an authorised representative for your products in EU member states and other countries.
Our experts will guide you through the entire process and ensure that your company meets all legal requirements.
Click the button below to make a free enquiry and get our support!
EU: Final adoption of the new EU Packaging Regulation
The European Union's Packaging and Packaging Waste Regulation (PPWR) has reached another milestone: the European Parliament adopted a revised version (corrigendum) of the text during the plenary session.
The final version of the regulation is expected to be formally adopted by the European Council, representing the 27 member states, in December 2024 and to come into force in 2025.
Background and voting process
The European Parliament had already adopted a provisional draft of the regulation by a large majority on 24 April 2024: 476 votes in favour, 129 against and 24 abstentions. However, this provisional version was only available in English and still had to undergo a legal-linguistic revision. Since the European elections were due to take place in June 2024, it was decided to provisionally adopt the draft for the time being to give the new parliament the opportunity to vote on the finalised text. This corrigendum has now been successfully approved.
Key contents of the PPWR
The PPWR aims to reduce packaging waste and promote recycling. It sets ambitious targets that EU member states must implement:
Packaging reduction targets:
5% less packaging by 2030,
10% by 2035,
15% by 2040.
Recyclability of packaging: From 2030, all packaging (except wood, cork, textiles, rubber, ceramic, porcelain and wax) must meet strict recycling criteria. A recyclability rating scale (A to C) is introduced:
Class A: 95% recyclability,
Class B: 80%,
Class C: 70%.
Recycling quotas:
Plastic packaging: 50% recycled by 2025, 55% by 2030.
Proportion of recycled material in plastic packaging:
65% for disposable beverage bottles (by 2040),
50% for PET contact packaging,
65% for other plastic packaging.
Collection of single-use containers: By 2029, 90% of all single-use beverage containers made of plastic and metal (up to three litres) must be collected separately – e.g. through deposit systems or comparable solutions.
If you need help complying with the regulations,our experts are on hand to guide you through the process and ensure that your company meets the requirements.
Click the button below now to make a free request for assistance.
The new European General Product Safety Regulation (Regulation (EU) 2023/988), also known as the General Product Safety Regulation (GPSR), will come into force on 13 December 2024.
This regulation aims to ensure the safety of consumer products, particularly in the context of distance selling and e-commerce.
Objective of the new rules:
The GPSR addresses societal changes such as digitalisation, technological developments and globalised supply chains. It ensures that consumers only receive safe products, regardless of their origin or point of sale.
Stakeholders affected:
The regulation affects all economic operators, including manufacturers, authorised representatives, importers, distributors and fulfilment service providers. Online marketplaces must also meet specific requirements.
Covered products:
The GPSR applies to all products intended for consumers or likely to be used by them, with exceptions such as pharmaceuticals, food and means of transport that are not directly operated by consumers.
Obligations of distributors:
Distributors must sell only safe products and ensure that products are correctly labelled and include safety information. They must also monitor storage and transport conditions to ensure product safety.
Control and review:
Distributors must verify that products meet the requirements before placing them on the market. In the event of non-compliance, they must take measures such as recall actions and notification of market surveillance authorities.
Special obligations for distance selling:
Additional requirements apply to online and distance selling, such as the provision of product images and warnings. Online marketplaces must ensure that all necessary information is easily accessible to consumers.
Do you need support with the Product Safety Regulation?
We are happy to help. Just contact us via chat, email, contact form or phone.
On Wednesday, 1 January 2025, further measures as part of Extended Producer Responsibility (EPR) will come into force in Germany. The Single-Use Plastics Fund Act and the associated regulation set new standards for manufacturers, importers and retailers of single-use plastic items.
How to comply with the new EPR requirements
The following obligations will apply from 2025:
Reporting the type and quantity: Report the single-use plastic products sold in Germany annually.
Paying environmental levies: Pay the applicable levies into the single-use plastic fund.
Who is required to register?
Producers based in Germany: Apply for registration numbers for all brands and product categories of your single-use plastic items. This is done directly through the German Environment Agency.
Manufacturers outside Germany: Appoint an authorised representative to take on your EPR obligations in Germany. This authorised representative is responsible for ensuring that your products are compliant and can continue to be offered on the market. A service provider such as Deutsche Recycling can provide support with this.
Dropshippers and resellers: Ask your suppliers for their registration numbers and ensure that all products are compliant. Carefully check the registration status of your suppliers.
Consequences of non-compliance
Non-compliance with the new EPR regulations can result in significant sanctions:
Fines: Violations can result in fines of up to €100,000 – regardless of whether the non-compliance was intentional or negligent.
Sales ban: Unregistered products may not be sold in Germany.
Confiscation of goods: Authorities can remove non-compliant products from the market, which can result in significant financial losses.
Additional penalties: Providing false information about quantities or failing to comply with other regulations can result in further administrative and civil penalties.
Timely registration is essential to avoid these risks.
Which products are affected?
The law covers a wide range of single-use plastic products, including:
Food containers: For immediate consumption, such as take-out boxes.
Bags and film wrappers: Flexible packaging that contains food for immediate consumption.
Beverage containers: Up to 3 litres, including lids and closures.
Drinking cups: For all types of beverages, regardless of material.
Lightweight plastic carrier bags: Primarily used for transporting food or other items.
Wet wipes: For personal and household cleaning.
Balloons: Except for industrial or professional use.
Tobacco products: cigarette filters and other disposable plastic products.
Our full-service offering enables you to meet these challenges efficiently and in compliance with the law.
Contact us to learn more about how we can help you meet the requirements of the EWKFondsG and safeguard your market presence in Germany.
Portuguese legislation (Decree-Law No. 152-D/2017) requires manufacturers, importers and distributors to register with a dual system in Portugal and to fulfil their legal obligations.
These include:
Annual financial statements and payment of the corresponding licensing fees.
Which products are affected?
The requirement applies to the following packaging:
sales packaging,
secondary packaging,
transport packaging,
service packaging,
shopping bags (plastic and paper bags – for Portuguese companies only) and
multipack packaging.
Labelling requirement from 2025:
Article 28 (5) of Decree-Law No. 24/2024 requires that packaging managed under the Integrated Packaging and Packaging Waste Management System (SIGRE) must be labelled. This includes:
Information on the disposal of non-reusable primary and secondary packaging, including the appropriate recycling containers.
The disposal information can be provided either directly on the packaging or in the product instructions or at the points of sale.
The exact requirements are published by APA, I.P. and DGAE in the form of guidelines.
The new labelling requirements were supposed to come into force in January, but have been postponed until the end of 2025.
Important for foreign companies
According to Portuguese legislation, only a company with a Portuguese VAT number can register with a dual system.
Foreign companies that distribute products without a registered office in Portugal (e.g. via online shops) must appoint an authorised representative to fulfil their obligations.
If you need assistance with compliance with the new regulations under the Portuguese Packaging Law, or require an authorised representative, our experts are always happy to help.
Since 1 January 2022, Sweden has also introduced measures for extended producer responsibility (EPR) for textiles.
The licensing of collections will start on 1 January 2025.
Manufacturers and importers of textiles must register with the relevant bodies and report their waste textiles.
With this legislation, the country aims to hold manufacturers more accountable and promote more sustainable use of textile products.
In this blog article, you will learn what EPR for textiles in Sweden is all about, which companies are specifically affected and what they have to pay.
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