We warmly welcome you to our 4. newsletter 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
The plastic levy and tax in Europe
EU Battery Regulation: New obligations from February 2024
EPR packaging in the United Kingdom: Current overview
Packaging disposal in Spain
Postponement of implementation of EPR Packaging in Denmark
EPR in Hungary: Current developments
We hope you enjoy reading the newsletter and look forward to your feedback! Best regards,
Deutsche Recycling
The plastic levy and tax in Europe
The plastic levy, introduced by the European Union (EU) in 2021, aims to address the environmental issue of non-recycled plastic waste. It requires EU member states to impose a financial levy based on the amount of non-recycled plastic waste they produce.
This levy is intended to incentivize the reduction of plastic waste while serving as a source of funding for the EU budget until 2027.
The plastic levy amounts to 0.80 euros per kilogram of non-recycled plastic packaging waste and is levied by all member states. The specific financing of this levy is at the discretion of individual countries, without EU-wide requirements. Some countries finance it from their national budgets, while others introduce taxes, fees, or contributions for certain plastic products.
Difference between plastic levy and plastic tax explained
The plastic levy is an EU-wide regulation, while the plastic tax is a national regulation not mandated by the EU. Companies must familiarize themselves with various regulations and taxes in export countries to ensure compliance in international trade.
An overview of the situation in some EU countries:
- In Germany, the plastic levy has been paid from the regular state budget so far. The introduction of a plastic tax for manufacturers and importers of single-use plastic packaging is planned for 2025.
- In France, the plastic levy is financed from the national budget, and there are no specific plans for a plastic tax.
- Italy plans to introduce a plastic packaging tax from July 1, 2024.
- The Netherlands already require affected companies to report their in-market single-use plastics and pay corresponding contributions.
- In Poland, there is no plastic tax for companies, but there is a law regarding recycling fees. Affected companies must register in the Product and Packaging Waste Management Database (BDO) and pay fees.
- Spain has introduced a tax on non-reusable plastic packaging since 2023 to implement the EU directive on single-use plastics. The tax is 0.45 euros per kilogram and applies to both the manufacture of these packaging within the country and the import from other countries, as well as the acquisition within the EU equally.
The various national regulations on plastic levy and tax lead to inconsistency.
If you need assistance in complying with the regulations, our experts are available to guide you through this process and ensure that your company meets the requirements. Click the button below to submit a free inquiry.
The EU Battery Regulation, which came into effect on February 18, 2024, aims to reduce the environmental impact of batteries and establish a harmonized legal framework for the design, performance, durability, labeling, collection, and recycling of all common battery types in the EU.
Responsibilities for Manufacturers
As of August 18, 2024, battery producers (manufacturers) will have new obligations, including providing a clearly written, readable operating manual and safety information for each battery, conducting conformity assessment and issuing an EU declaration of conformity, affixing the CE mark, labeling with model identification and batch number, and providing complete manufacturer identification.
Responsibilities for Importers
Importers of batteries from third countries will also have new obligations as of August 18, 2024, including pre-market control obligations, affixing their own data on the battery, sales bans and notification obligations in case of non-compliance, handling requirements, and documentation retention for EU declarations of conformity.
Responsibilities for Retailers
Retailers selling batteries or products with batteries must also comply with new control and behavior obligations as of August 18, 2024, including control obligations regarding manufacturer identification, sales bans and notification obligations in case of non-compliance, handling requirements, and cooperation obligations with surveillance authorities.
You can find more information about the EU Battery Regulation in our latest newsletter.
EPR Packaging in the United Kingdom: Current overview
The current EPR obligations in the UK include registration and reporting to the relevant environmental authority. Companies must register to ensure they take responsibility for their generated waste and support recycling programs.
Which companies are obligated?
Large producers (with annual turnover exceeding £2 million and processing or supplying over 50 tonnes of packaging material per year) must report biannually (deadline 30 April 2024) and bear financial obligations from 2025.
Small producers (with annual turnover between £1 million and £2 million and processing or supplying over 25 tonnes of packaging material per year OR with annual turnover exceeding £1 million and processing or supplying 25 to 50 tonnes of packaging material per year) must submit packaging data annually.
The EPR packaging fees in the UK, originally planned for 2024, have been postponed to 1 October 2025. Nevertheless, companies must already be registered and collect data on packaging types, materials, and weights.
Which product categories are affected?
Product categories falling under the new EPR regulations include electronics, batteries, packaging, and vehicles. Companies must ensure their products comply with UK standards and participate in take-back and recycling programs.
Future developments of EPR regulations in the UK include expanding product categories, higher recycling targets, introducing digital product passports, and mandatory labeling for recycling. These changes aim to further reduce environmental impacts and promote the circular economy.
Mandatory labeling for recycling
With the extended producer responsibility for packaging (pEPR), mandatory recycling labeling is introduced.
If you are unsure or need assistance with compliance, our experts are available to guide you through this process and ensure your company meets the requirements. Click the button below to submit a free inquiry and get support.
The disposal of packaging in Spain is subject to a comprehensive regulatory framework that covers all aspects of the packaging industry.
Regardless of their origin or the materials used, companies introducing or circulating packaging in the Spanish market must comply with strict regulations. These regulations apply not only to domestic companies but also to foreign companies distributing their products in Spain.
In this article, we take a closer look at the legal requirements and tax obligations related to packaging disposal in Spain.
Postponement of Implementation of EPR Packaging in Denmark
The planned deadline for registration requirements in Denmark has been postponed to April 1, 2024, while the implementation of extended producer responsibility for packaging has been postponed to July 1, 2025.
Currently, the Packaging Directive is still being negotiated at the EU level, leading to a standstill in the implementation of extended producer responsibility for packaging in Denmark.
Affected Companies
These new regulations for placing product packaging on the market have significant implications for Danish manufacturers and fillers, as well as importers and foreign companies and online retailers shipping goods to Denmark.
What Are the Obligations?
According to these new developments, companies introducing packaging into circulation for the first time in Denmark will be subject to extended producer responsibility (EPR) in the future. This means that companies will be responsible for the costs of collecting, sorting, and recycling packaging waste, either individually or by participating in a take-back system. Affected companies are required to register in the manufacturer register (Dansk Producentansvar - DPA).
If shipping is done by a foreign company (without a Danish branch or CVR number) and directly to Danish end consumers, the shipping company must fulfill the EPR obligations (including registration with the DPA and reporting of packaging quantities) through an authorized Danish representative.
These registration and reporting obligations will already take effect on April 1, 2024!
Is your company placing packaging on the market in Denmark and you are unsure about which obligations apply to your company and whether you are compliant with them? We are happy to assist you. Just contact us.
The recent developments in Extended Producer Responsibility (EPR) in Hungary have significant implications for online retailers and companies distributing products such as packaging, textiles, electrical and electronic devices, batteries, and furniture in the Hungarian market.
This article provides an overview of the current developments in EPR in Hungary and highlights the obligations that affected companies must now fulfill.
Are you a manufacturer or distributor of products in the categories of packaging, textiles, electrical and electronic devices (WEEE), as well as batteries and furniture?
Do you have questions regarding EPR in Hungary?
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