We warmly welcome you to our 4th 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
Poland: Increase of the BDO fees
Hungary: Environmental product fee cancelled
Belgium: EPR notification for mattresses due by latest 31 March 2025
Portugal: Extension of the EPR to new product categories
Webinar invitation
Fresh up - Reminders / Dates
We hope you enjoy reading the newsletter and look forward to your feedback!
Best regards Deutsche Recycling
Poland: Increase of the BDO fees
As of January 1, 2025, BDO fees in Poland have increased. Companies registered in the BDO (Baza Danych o Odpadach) database must pay the annual fee on time to avoid penalties.
The registration obligation applies to all companies that:
Distribute products in packaging,
Manufacture packaging, electrical appliances, batteries, or accumulators,
Sell or import vehicles, tires, oils, or lubricants.
Failure to comply may result in penalties ranging from 5,000 PLN (approx. 1,194 EUR) to 1,000,000 PLN (approx. 238,798 EUR).
Find more information about the BDO register and the latest changes in our blog post:
Previously, companies in certain industries had to comply with both the extended producer responsibility (EPR) and the environmental product charge (EPC).
This meant double the administrative burden because they had to:
pay EPR fees for the collection, recycling and disposal of their products.
pay an environmental product charge (EPC), which previously existed for certain product streams independently of the EPR.
However, a mechanism was already put in place when the EPR was introduced whereby the EPR charges paid could be deducted from the environmental product charge. This did not abolish the EPC for the product streams concerned, but there was no longer any actual payment obligation – only a bureaucratic requirement to provide evidence of payment.
What change came into force on 1 January 2025?
The double burden of the EPR and the environmental product charge (EPC) is abolished. This affects the following product categories:
packaging
electrical and electronic equipment
batteries
tyres
office supplies
advertising paper
In the future, companies will no longer have to manage an environmental product charge (EPC) for these product categories, but only have to fulfil the EPR requirements. Less red tape for companies, but no major financial savings, as the payment of the EPC was compensated by the EPR fees anyway.
What are the changes for plastic bags?
Plastic bags have been treated differently since 1 January 2025.
They then belong to the ‘product stream of other plastic products’ and continue to be subject to both the EPR and the environmental product fee.
However, the amount of the product fee for plastic bags has been adjusted – the EPR fee is now deducted directly from the product fee.
Plastic bags remain the only case in which both fees (EPR and EPC) are still relevant.
What will happen to the penalties for non-compliance with the EPR?
From 1 April 2025, new rules for enforcing the EPR will come into force.
These are set out in the Government Decree on Fines in Waste Management.
Objective: Clear definition of penalties for companies that fail to fulfil their EPR obligations.
If you are unsure about your company's obligations or need assistance with EPR compliance in Hungary, Deutsche Recycling Service GmbH is at your side as a trustworthy partner.
Belgium: EPR notification for mattresses due by latest 31 March 2025
Manufacturers and importers of mattresses that are active on the Belgian market must report their sales figures for 2024 by 31 March 2025 at the latest.
This obligation arises from the extended producer responsibility (EPR) and applies to all actors who distribute mattresses in Belgium.
Who is affected by the EPR obligation?
The EPR scheme for mattresses in Belgium applies to all distributors who supply mattresses to end customers or companies in Belgium, whether they are based in Belgium or abroad. This includes:
Manufacturers based in Belgium,
Importers who import mattresses from abroad,
Online retailers who sell mattresses directly to Belgian customers,
Foreign traders who offer their products in Belgium without a local distributor.
Which products are affected?
The EPR requirement applies to all mattresses intended for private and commercial use (B2C & B2B). This includes, but is not limited to:
Household mattresses
Hotel and hospitality mattresses
Hospital and care bed mattresses
specialised mattresses for professional use.
What are the deadlines?
The sales figures for 2024 must be reported by no later than 31 March 2025. Companies that fail to fulfil their obligations by the deadline risk penalties or sanctions from the relevant authorities.
If you have any questions about the EPR requirement for mattresses in Belgium or need assistance with registration and reporting, our experts are available to help.
Portugal: Extension of the EPR to new product categories
Portugal has made changes to the Waste Management Act with Decree-Law No. 24/2024. One of the innovations is the extension of the extended producer responsibility (EPR) to furniture and mattresses.
Previously, EPR applied mainly to products such as packaging, electrical appliances and batteries. With the new law amendment, producers and importers of furniture and mattresses are now also obliged to cover the entire disposal chain of their products.
When does the new regulation come into force?
From 31 December 2025, producers and importers of furniture and mattresses must:
ensure that their products are environmentally collected, recycled or disposed of.
register in an EPR system and possibly pay fees to finance waste recovery.
What does this mean for companies?
Companies that place furniture or mattresses on the Portuguese market need to prepare for the new obligations.
It is important that affected companies act in a timely manner to remain compliant. Our experts are happy to assist you in implementing the necessary measures. Make a free enquiry now.
We cordially invite you to our exclusive webinar ‘EPR in North America: Key insights for staying compliant in 2025’ on Tuesday, 23 March 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.
Denmark: Extended producer responsibility for single-use plastic products
1-10 April 2025: First reporting period for the quantity of single-use plastic products sold in the previous quarter.
Quarterly reporting obligations: After the first report in April 2025, reporting must take place quarterly - from 1-10 April, July, October and January.
Denmark: Extended producer responsibility for fishing equipment
1 April 2025: First reporting period for fishing equipment placed on the market in 2024. Thereafter, reporting will take place annually on 1 April.
Feedback
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.
.png?upscale=true&width=1120&upscale=true&name=EPR%20Nordamerika%202025%20(1).png)
