We warmly welcome you to our 3th Newsletter of 2024! 🌍 With the newsletter, we regularly provide our subscribers with specialized information focusing on EPR-compliance.
If you have any questions, our experts are available for personal consultation.
Today's topics at a glance
Extended Producer Responsibility (EPR) in the textile sector: Developments in the Netherlands
EPR for textiles in Sweden - objectives and guidelines
General Product Safety Regulation - New obligations for retailers
Single-use plastics fund law: introduction and implementation
Single-use plastic fund in Germany: the online platform DIVID
Stricter regulations for packaging
We hope you enjoy reading the newsletter and look forward to your feedback!
Best regards,
Deutsche Recycling
Extended Producer Responsibility (EPR) in the textile sector: Developments in the Netherlands
The European Union is planning to introduce reporting requirements for extended producer responsibility (EPR) in the textile sector. This initiative covers textile products such as clothing, bed linen and shoes and aims to set specific collection, recycling and reuse targets by 2030.
Some EU countries, including France, Sweden and the Netherlands, have already passed legislation for textile EPR programmes. The main aim of these programmes is to improve the entire life cycle of textile products and promote the circular economy, while reducing the production of fast fashion. Products that last longer are to be rewarded with lower EPR fees to support sustainability.
Collective declaration: The 2023 Declaration
An important step in the implementation of the EPR measures in the Netherlands is the introduction of collective notification (Declaration 2023). This process allows manufacturers, traders and importers of textiles to jointly declare their obligations under the EPR. No fee is levied or charged for the collective declaration, which is a simplified and cost-effective way for companies to fulfil their obligations.
Provisional fee in 2024
In the following year, 2024, the companies concerned will have to pay a provisional fee for the amount of textiles they are expected to place on the Dutch market. This fee is based on estimates and is levied to cover the costs of the EPR scheme. The provisional fee is part of the financing model of the EPR system and ensures that the necessary resources are available for collection, recycling and reuse activities.
Affected companies
The EPR for textiles in the Netherlands is expected to affect all companies that are expected to sell clothing and other textile products in the Netherlands from 1 July 2023. It does not matter whether the sale is made to commercial or private buyers. The following players must take into account and fulfil the provisions of the EPR for textiles in the Netherlands:
Textile manufacturers based in the Netherlands, as they can be assumed to sell finished textile products to Dutch retailers.
Importers who import clothing and other textile products for Dutch companies.
Domestic online retailers based in the Netherlands because their textile products can be purchased by Dutch customers.
Foreign online retailers who sell and deliver their goods to Dutch consumers.
Year-end reporting and peak billing 2025
Another important aspect of the EPR system is the year-end reporting, which will take place in 2025. In this step, companies will report the actual quantities of textiles they have placed on the Dutch market. This will be followed by peak billing to ensure that fees are only charged for the textile products actually sold. This settlement promotes the accuracy and fairness of the system by ensuring that companies only contribute to cost recovery according to their actual market participation.
If you need assistance with compliance, our experts are on hand to guide you through this process and ensure your business is compliant. Click the button below now to make a free enquiry and receive support.
EPR for textiles in Sweden - objectives and guidelines
Since 1 January 2022, Sweden has also implemented extended producer responsibility (EPR) measures for textiles. Manufacturers had until 1 January 2024 to ensure that textile waste was collected by licensed collection systems.
With this legislation, the country aims to increase the responsibility of producers and promote a more sustainable use of textile products.
In this blog article, you can find out what the EPR for textiles in Sweden is all about, which companies are specifically affected and what they can expect to pay.
General Product Safety Regulation - New obligations for retailers
In April 2023, the Council of the European Union introduced Regulation (EU) 2023/988 on general product safety, known as the "General Product Safety Regulation" (GPSR). This regulation sets stricter safety requirements for products offered in both stationary and online retail and replaces the provisions of EU Directive 2001/95/EC on general product safety, which was implemented in Germany by the Product Safety Act.
The new regulations standardise and update the safety requirements for products in line with the latest digital and technological advances. They include new labelling and information obligations that must be taken into account, especially in online retail.
The provisions will apply from 13 December 2024.
Support for retailers in fulfilling the new obligations
In the course of 2024, not only producers, importers or distributors but also online retailers and online markplaces will have to prepare for the new information and other obligations under the GPSR and ensure compliance with them.
Due to the broad scope of application, numerous products will fall under the new regulations. The exact determination of which products are specifically affected is still pending due to the lack of specific regulations or a list in the GPSR and requires an individual review for each product.
We will be happy to help you review your business model with regard to the new requirements of the GPSR. Click on the button below to receive a free consultation.
Single-Use Plastic Fund Act: Introduction and implementation
The EU Single-Use Plastics Directive of 2019 and the German Single-Use Plastics Fund Act (EWKFondsG) entail new obligations for manufacturers of certain products, including the extension to fireworks from 2026 and 2027 respectively.
In contrast to the Packaging Act, which is primarily aimed at distributors of packaged goods, the EWKFondsG also includes certain non-packaging products such as wet wipes, balloons and tobacco products in addition to packaging.
Affected companies and products
The law is aimed at manufacturers who make single-use plastic products such as to-go cups, tobacco filters, wet wipes, lightweight carrier bags and other similar products available on the German market for the first time, depending on their position in the supply chain. One particular case relates to bags and film packaging with food content, where it is not the producer of the empty packaging but the supplier of the filled product that is considered the manufacturer.
The extended producer responsibility obliges the companies concerned to contribute to the costs of waste management, cleaning public spaces and awareness-raising measures. This regulation makes producers directly responsible for minimising plastic consumption and combating littering.
Special levy and single-use plastic fund
The newly established Single-Use Plastic Fund, which is managed by the Federal Environment Agency, serves as an instrument for financing environmental protection measures. The amount of the levy is based on the type and quantity of single-use plastic products placed on the market and was set in October 2023. In addition, the quantity reports must be confirmed by external auditors, whereby the obligation to check is waived for single-use beverage packaging subject to a deposit and if the quantity falls below a de minimis limit of 100 kg per year. Nevertheless, the obligation to register, report quantities and pay duties remains in place for all manufacturers concerned.
Is your company a distributor of single-use products or single-use plastic products in Germany and you are not sure which obligations apply to your company and whether you are complying with them? We will be happy to help you. Simply get in touch with us.
Single-use plastic fund in Germany: the online platform DIVID
The Single-Use Plastics Fund Act represents a further step in the implementation of the EU Single-Use Plastics Directive and aims to tackle the challenges of environmental pollution caused by single-use plastic products.
This law obliges manufacturers of single-use products containing plastic to register and make financial contributions. The regulation is intended to reduce the amount of plastic waste thrown away, increase producers' responsibility in handling their products and promote a more sustainable use of plastic resources. The law on the Single-Use Plastic Fund adopted on 15 May 2023 requires certain producers to cover the disposal costs for their single-use plastic products collected on the streets or in parks from 2024.
The Federal Environment Agency (UBA) will set up the online platform DIVID to coordinate and implement the contributions to be made by the companies concerned to the Single-Use Plastic Fund. This platform is planned to be activated in stages from 1 April 2024.
Until the launch of the digital platform DIVID
The IT infrastructure will be finalised by this date. Registration for domestic producers will therefore be possible from 1 April 2024. From this date, foreign producers and their representatives will also be able to create accounts on DIVID. The UBA will provide information on the gradual availability of the platform for additional user groups and on the release of further functions via DIVID and on the website www.ewkf.de.
From 1 January 2024 to 1 April 2024, the UBA will offer a preliminary version of DIVID on the website www.einwegkunststofffonds.de, which manufacturers can use in particular to submit applications to classify their products and determine their producer status.
Manufacturers who have already started selling the single-use plastic products in question before 1 January 2024 must register by 31 December 2024. Immediate registration is only mandatory for producers who start their business activities from 1 January 2024. Until registration is possible, failure to register has no consequences. The legal obligation to pay levies begins in 2024, regardless of registration.
Talk with an Expert!
Are you a manufacturer of single-use products or are you affected by the EU Single-Use Plastics Directive?
Do you have questions about the Packaging Act?
SDo you need support with registration or with the administration of your tax obligations?
We will be happy to help you. Simply get in touch with us via chat, e-mail, contact form or telephone. We will answer your enquiry within the next 24 hours.
Stricter regulations for packaging and minimum recycled content
In 2024 and 2025, there will be some important innovations in connection with packaging and recycling:
1. Minimum recyclate content for disposable PET drinks bottles:
From 2025, single-use PET drinks bottles must contain at least 25 per cent recycled plastic (recyclate). This step aims to increase the use of recycled material in single-use beverage bottles and reduce the environmental impact.
2. Increase the minimum recycled content for single-use plastic beverage bottles:
From 2030, the minimum quota for all beverage bottles made from single-use plastic will be increased to at least 30 per cent. This should help to further increase the proportion of recycled material in plastic bottles.
3. Universal registration obligation for all packaging:
From 1 July 2022, all manufacturers of packaging must register their packaging with the Central Agency Packaging Register (ZSVR). This applies not only to packaging subject to system participation, but also to transport packaging and sales or secondary packaging in the industrial and commercial sectors.
4. Service packaging:
Service packaging that is only filled with goods immediately before handover to the customer (e.g. at bakery or meat counters) must also be registered in LUCID from 1 July 2022. However, it will still be possible to use pre-licensed packaging.
These measures are intended to help make the handling of packaging more sustainable and increase the proportion of recycled material.
If you are unsure what obligations your company will have to fulfil or need support in complying with the EU Single-Use Plastics Directive, Deutsche Recycling Service GmbH is your trusted partner. We support you in the implementation of the EU Single-Use Plastics Directive.
Click on the button below now to make a free enquiry and receive support.
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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