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
France: New take-back system for small fire extinguishers
Great Britain: Changes to WEEE obligations for foreign companies
Romania: Legal changes for packaging
India: New labelling requirements for plastic packaging
Update on the PPWR
Webinar invitation
We hope you enjoy reading the newsletter and look forward to your feedback!
Best regards, Deutsche Recycling
France: New take-back system for small fire extinguishers
Since 1 January 2025, small fire extinguishers have no longer been taken back by Ecosystem, but by ECOPAE, which has initially been approved until 2027.
Obligations for manufacturers and distributors
Manufacturers, importers and distributors of small fire extinguishers are legally obliged to participate in one of the recognised disposal associations and to ensure the environmentally friendly disposal of their products. This includes:
Registration number: Manufacturers or importers who sell small fire extinguishers on the French market must register and receive a registration number.
Labelling requirements: Fire extinguishers must be labelled with the Triman logo and the note ‘Cet extincteur se recycle’ (This extinguisher is recycled).
Reporting requirement and disposal fee: Distributors are obliged to pay disposal fees to finance the collection and recycling of the quantities they distribute.
Which products are affected?
The regulation applies to fire extinguishers and pressure-operated extinguishing devices that use powder or water, regardless of whether they are permanently installed or mobile. The maximum filling quantity is 2 kg or 2 litres. CO₂ and halon extinguishers are excluded.
These fire extinguishers are mainly used on pleasure craft, in residential buildings and in vehicles such as trucks, cars and motorhomes.
Do you have any questions? Our team of experts will be happy to help by email or phone.
Great Britain: Changes to WEEE obligations for foreign companies
The British Environment Agency has amended the WEEE Regulations for 2025. Existing registrations will need to be updated during 2025.
What is changing:
Organisations without a UK establishment that sell EEE only through intermediaries (e.g. distributors or importers) will no longer be considered as a producer.
These companies will no longer need to register for WEEE in the UK from 2025.
Voluntary registration in place of distributors will no longer be possible.
What will remain the same:
Companies not based in the UK that sell directly to end users in the UK (e.g. via an online shop) must continue to be registered as producers.
Companies that sell both directly and indirectly must continue to register, but only for the quantities delivered directly to end users.
Action required for affected companies
Do you sell exclusively indirectly and have not yet informed us of this
Please contact us as soon as possible so that your registration for 2025 is not renewed.
Do you sell both directly and indirectly and have you already informed us
Your registration will be renewed. From January 2025 onwards, you will only have to report the quantities sold directly to end users.
Inform your customers (distributors, importers) that starting in 2025 you will no longer be able to take on the obligation to register.
Do you have questions about WEEE registration or extended producer responsibility (EPR)? Our experts will be happy to help.
The Romanian Ministry of the Environment has published new legal requirements for packaging that affect manufacturers and distributors.
1. New reporting requirements for manufacturers and distributors
Companies that place drinking cups, food containers and PET bottles on the market must now submit reports to the Environmental Fund Administration (AFM).
This is based on Regulation No. 6/2021, which aims to reduce the environmental impact of single-use plastics.
These reports are to be submitted to the AFM annually as part of the declaration under Regulation 185/2023.
2. Adoption of the new EU Packaging Regulation (PPWR)
On 16 December 2024, the European Council officially adopted the new Packaging Regulation (PPWR).
This replaces the previous Directive 94/62/EC and brings with it changes to Regulation (EU) 2019/1020 and Directive (EU) 2019/904.
The exact implications have not yet been described, but companies should prepare for them, as new packaging regulations and stricter recycling requirements are to be expected.
3. Changes to the AFM eTAX platform from January 2025
New feature: From January 2025, the eTAX platform will show in the ‘Display Calculation’ section how much money companies will have to pay for recycling quotas that have not been met.
This function applies to the packaging quantities placed on the market for which the recycling targets were not met in the respective reporting month.
What does this mean for companies?
Producers and distributors of single-use plastic must now actively send reports to the AFM.
The new PPWR will bring new packaging requirements across Europe – companies should prepare for this at an early stage.
From 2025, companies that place packaging on the market in Romania will be able to use the AFM-eTAX platform to better understand whether they have met their recycling targets or whether additional payments are due.
Our experts will help you comply with the new regulations and make your company legally compliant.
Click on the button below to make a free request and get support.
India: New labelling requirements for plastic packaging
India has updated its Plastic Waste Management Rules of 2016. New labelling requirements for plastic packaging will apply from 1 July 2025.
New labelling requirements
Labelling requirement: Manufacturers, importers and brand owners must provide the information required by Rule 11.1 either in a barcode/QR code, a product leaflet or as a unique number directly on the packaging.
Rule 11 requires:
Plastic bags and laminated packaging must include the manufacturer's name and registration number (issued by the Central Pollution Control Board, CPCB) and, in the case of plastic bags, their thickness.
Compostable plastic bags are exempt from this. Instead, they must comply with Standard IS 17088:2008 and have a certificate from the CPCB.
Reporting requirement: Manufacturers, importers and brand owners must notify the CPCB of how their packaging is labelled. This information is published quarterly on the CPCB website.
In addition, the new rules introduce penalties:
Rule 19 provides for financial penalties in the event of violations, which can increase in the event of persistent violations. In serious cases, there is even the threat of imprisonment.
Deutsche Recycling offers a fast, cost-effective and comprehensive solution for the new labelling requirements.
On 11 February 2025, the new European Packaging Regulation (EPR) will come into force after being published in the Official Journal of the EU on 22 January 2025.
For the time being, there are no practical consequences, since all obligations will apply at the earliest from 12 August 2026 and some will apply later due to transitional periods.
Nevertheless, the date 11 February 2025 is important because:
New definitions were introduced, e.g. for reusable packaging and the new role model with producers, importers and economic operators.
Derogations were defined, for example for small businesses, legal frameworks and the protection of historical packaging designs.
Producers and importers should actively use the remaining 18 months to carry out the conformity assessments in good time. Otherwise, they risk a distribution ban because their packaging would not be marketable.
Implementation support
Our experts are on hand to help ensure that your company meets the new requirements. Click here to make a free enquiry and get support.
We cordially invite you to our exclusive webinar ‘EPR in North America: What to expect in 2025’ on Thursday, 27 February 2025 at 10:30 a.m.. Our experts Rolf Andreas and Dominik Stock will provide you in German 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 us an email with your comments and suggestions for improvement.
