As always, weâll keep you informed with regular updates on the latest trends and developments in environmental compliance.
If you have any questions, our experts will be happy to provide you with personalised advice.
Today's topics at a glance
Important compliance deadlines in 2025
New developments and important dates
Denmark: NewEPR obligations
Germany: The Single-Use Plastics Fund Act - What you need to know
Spain: New system participation requirement from 2025
EU: Adoption of the PPWR
Webinar invitation
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Deutsche Recycling
Important compliance deadlines in 2025
Denmark:
1 January 2025: Introduction of the bonus-malus system for an extended guarantee period for electrical and electronic products. The fees are to be paid based on the reported market volumes for 2024.
1 April 2025: Completion of registration with the dpa system for companies that bring packaging onto the Danish market, as well as reporting of expected packaging volumes for 2025.
Germany:
2025: The first payment of the levy on single-use plastics in accordance with the Single-Use Plastics Directive is due.
By 15 May 2025: Report the single-use plastic products placed on the market in 2024 to the German Environment Agency.
Sweden:
1 January 2025: Introduction of licensing for textile collections. Manufacturers and importers must register and report waste textiles.
Slovenia:
From 18 August 2025: Registration requirement for battery manufacturers and importers in the Slovenian national register.
United Kingdom:
1 April 2025: Last reporting deadline under the EPR packaging obligation. Large companies (turnover > ÂŁ1 million and responsibility for > 25 tonnes of packaging in 2024) must report every six months, smaller companies must report annually.
New developments and important dates
Germany â Single-Use Plastics Fund Act:
Additional measures for Extended Producer Responsibility (EPR) have been in force in Germany since 1 January 2025. The Single-Use Plastics Fund Act and the associated regulation set new standards for manufacturers, importers and retailers of single-use plastic items. Find out more here
Northern Ireland â Labelling requirement:
From 1 July 2025: Introduction of the staggered labelling requirement. Products destined exclusively for the Northern Irish market must be labelled âUK(NI)â to distinguish them from goods for the EU market. More information here
Spain - Labelling requirement for household packaging:
From 1 January 2025: Introduction of a specific labelling requirement for household packaging in accordance with Decree 1055/2022. The labelling must be visible, legible and permanently affixed to the packaging or label. Find out more here
Action required by affected companies
It is crucial that affected companies act quickly to remain legally compliant. Our experts are happy to assist you in implementing the necessary measures. Make a free enquiry now.
In 2025, new regulations on extended producer responsibility (EPR) for packaging, single-use plastic products and fishing equipment with plastic components will come into force in Denmark.
Here is an overview of the most important information and deadlines that companies need to be aware of:
EPR for packaging
14 January 2025: Producers of packaging must register with the DPA and conclude a contract with a Producer Responsibility Organisation (PRO) by this date.
1 June 2025: The actual quantity of packaging placed on the market in 2024 must be reported by this date. Further information on the reporting requirements will be provided in due course.
1 October 2025: Extended producer responsibility for packaging officially comes into force.
Special features for reusable packaging:
1 January 2025: Registration requirement for producers of reusable packaging with the DPA. Producers of reusable packaging can choose whether or not to join a PRO. There is no obligation on their part.
1 February 2025: Reusable packaging producers must report by this date the expected volumes of reusable packaging they plan to import in 2025.
EPR for single-use plastic products
1 January 2025: Extended producer responsibility for single-use plastic products comes into force.
1â10 April 2025: First reporting period for the amount of single-use plastic products sold in the previous quarter.
Quarterly reporting requirements: After the first report in April 2025, reporting must be done quarterly â from 1â10 April, July, October and January.
EPR for fishing gear
1 January 2025: the regulation comes into force.
1 April 2025: first report on quantities placed on the market in 2024. Thereafter, annual reporting by 1 April.
Our experts are on hand to help you ensure that your company meets the requirements. Feel free to contact us for a free consultation!
Germany: The Single-Use Plastics Fund Act â What you need to know
New measures as part of Extended Producer Responsibility (EPR) have been in force since 1 January 2025. The Single-Use Plastics Fund Act and the corresponding regulation introduce binding standards for manufacturers, importers and retailers.
How to comply with the new EPR requirements
From 2025, the following obligations must be observed:
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 via the German Environment Agency.
Producers outside Germany: Authorise a representative to take on your EPR obligations in Germany. This representative will ensure that your products comply. Service providers such as Deutsche Recycling can support you with this.
Dropshippers and resellers: Request your suppliersâ registration numbers and ensure that all products comply with the legal requirements. Carefully check your suppliersâ registration status.
Consequences of non-compliance
Failure to comply with the new EPR regulations can result in significant sanctions:
Fines: Monetary penalties of up to âŹ100,000 â regardless of whether the violation was intentional or negligent.
Sales ban: Unregistered products may not be sold in Germany.
Confiscation of goods: Non-compliant products may be withdrawn from the market by authorities.
Additional penalties: False declarations of quantities or failure to comply with other provisions may result in additional legal consequences.
Which products are affected?
The law affects a wide range of single-use plastic products, including:
Food containers: For immediate consumption, e.g. take-away boxes.
Bags and film wrappers: Flexible packaging for food for immediate consumption.
Beverage containers: Up to 3 litres in capacity, including lids and closures.
Drinking cups: For all types of beverages, regardless of material.
Lightweight plastic carrier bags: Specifically for transporting food or other items.
Wet wipes: For personal and household care.
Balloons: Excluding industrial or commercial use.
Tobacco products: cigarette filters and other single-use plastic products.
Our full-service offering helps you to comply with the requirements of the Single-Use Plastics Fund Act in an efficient and legally compliant manner. Contact us to learn more about how we can help you secure your market presence in Germany.
Spain: New system participation requirement from 2025
From January 2025, commercial packaging will also be subject to system participation in Spain. This obligation previously applied only to household packaging and now also affects packaging in retail, gastronomy and industry.
Categories of commercial packaging:
Commercial packaging: For wholesale and retail, gastronomy, offices, markets and services (e.g. food packaging for restaurants).
Industrial packaging: For industry, agriculture, forestry and aquaculture (e.g. packaging for transport and storage of raw materials).
Affected companies:
Spanish companies: Manufacturers and distributors of packaging.
International exporters: Companies that import packaging into Spain. Responsibility lies with the companies that bring packaging into Spain for the first time.
The Spanish Ministry of the Environment requires foreign companies that are required to register in the packaging register to have a Spanish tax number for non-residents. This number is referred to as a NIF number.
Deutsche Recycling offers a full-service package for this and a fast and cost-effective solution. Our service covers all aspects of the application process. Contact us.
Am 16. Dezember 2024 hat das EuropĂ€ische Parlament die endgĂŒltige Fassung der PPWR verabschiedet. Sie tritt 20 Tage nach ihrer Veröffentlichung in Kraft, wobei der Geltungsbeginn erst nach 18 Monaten, also Mitte 2026, erfolgt.
Many obligations and requirements are subject to further transition periods that extend to 2040.
Key content 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% recyclability
Class C: 70% recyclability
Recycling quotas:
Plastic packaging:
50% recycled by 2025
55% recycled 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 disposable containers:
By 2029, 90% of all single-use plastic and metal beverage containers (up to three litres) must be collected separately â for example, through deposit systems or comparable solutions.
We cordially invite you to our exclusive webinar âEPR in North America: What to expect in 2025â on Thursday, 27 February 2025 at 10:30 a.m.. Our experts Rolf Andreas and Dominik Stock will provide you with information on the current EPR regulations in Canada and the US in the areas of WEEE, packaging, batteries and textiles.
To ensure that you continue to receive an informative and appealing newsletter in the future, we look forward to your feedback. Please feel free to send me an email with your comments and suggestions for improvement.
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