We warmly welcome you to our 5th 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
Malte: Report on single-use plastic required
Spain: EU Commission initiates infringement proceedings
Sweden: EPR for textiles – current developments
United Kingdom: new system administrator for packaging EPR
United Kingdom: submit packaging data for 2024
Webinar invitation
Fresh up - Reminders / Dates
We hope you enjoy reading the newsletter and look forward to your feedback!
Best regards Deutsche Recycling
Malte:
Report on single-use plastic required
Companies that place packaging on the market in Malta must also indicate, as part of the extended producer responsibility (EPR) for packaging, whether they market single-use plastic products – and whether this was already the case in the period July to December 2024.
Who is affected?
The EPR regulation for packaging requires manufacturers, importers and distributors who place more than 100 kg of packaging per year on the Maltese market.
Which products are included?
Beverage bottles, cups and lids (partly or fully made of plastic)
Food containers (partly or fully made of plastic)
Packaging and wrapping
Beverage cans
Wet wipes
balloons
What are the obligations?
Companies that place packaging on the market in Malta must register with the Maltese Environment and Resources Authority (ERA) and join a take-back scheme.
If companies distribute single-use plastic products in Malta or have already placed them on the market in the period July to December 2024, they must report this by March 28, 2025 at the latest.
Our experts will help you comply with the new regulations and set up your business in accordance with the law.
Click on the button below to make a free request and get support.
Spain: EU Commission initiates infringement proceedings
The European Commission has initiated infringement proceedings against Spain for introducing new labeling requirements for packaging.
These rules could affect the free movement of goods in the single market because they force companies to provide special labels only for the Spanish market.
The Commission argues that such national regulations hinder the harmonization of packaging regulations in the EU and create additional costs for companies. Spain has two months to respond to the complaints. If no satisfactory solution is found, the Commission could bring the case before the European Court of Justice.
This decision follows a similar case against France, which has been targeted by the EU Commission for introducing the Triman logo. The Triman symbol requires manufacturers to place a specific recycling label on certain packaging – a national requirement that the EU believes violates the single market. As a result, companies that sell their products in multiple countries face additional labeling requirements.
With these proceedings, the European Commission is underlining its intention to create a uniform labeling system for packaging at the EU level in order to facilitate trade and to avoid confusing consumers with different national requirements.
It remains to be seen how Spain will react to the criticism and whether this will lead to a broader debate on the future of packaging labeling in the EU.
If you have any questions about packaging labeling requirements in Spain, our experts will be happy to help.
As things stand, from January 2025, manufacturers will have to ensure that textile waste is collected via licensed take-back systems. However, this obligation is expected to be postponed to 2026.
Since January 1, 2022, Sweden has been taking measures to introduce extended producer responsibility (EPR) for textiles. The aim is to reduce the environmental impact of textiles and to establish a functioning circular economy in the textile sector.
Who is affected by EPR for textiles:
EPR applies to all companies that place textiles on the Swedish market, whether or not they are based in Sweden. This includes, in particular:
Manufacturers and importers of clothing, home textiles, bed linen, towels, curtains, etc.
Online retailers that deliver textiles directly to Swedish end customers
Brand owners and retailers that sell textile products under their own name
Foreign companies without a presence in Sweden are also affected if they sell textiles directly to consumers. In this case, an authorized representative based in Sweden must be appointed.
What are the obligations?
According to the revised EU Waste Framework Directive (2018/851), all EU member states are required to ensure separate collection of used textiles from January 1, 2025.
Sweden is planning to introduce an EPR obligation for textiles, similar to the system in place in France. However, no fully implemented obligations, such as those for volume reporting or the financing of collection, currently exist. The specific requirements are expected to be regulated by law by 2026.
United Kingdom: new system administrator for packaging EPR
On January 21, 2025, PackUK was officially launched as the new system administrator for the UK's extended producer responsibility (EPR) packaging program.
This program shifts the cost of packaging waste management from taxpayers and local authorities to the companies that place packaging on the market, in line with the “polluter pays” principle.
Consequences for placing packaging on the market:
Meeting costs: Companies that place packaging on the UK market are now obliged to pay fees that cover the costs of collecting, recycling and disposing of household packaging waste.
Fee structure: From 2026/27, the fees will be adjusted to provide incentives for the use of more environmentally friendly packaging materials. Recyclable packaging will incur lower fees than materials that are difficult to recycle.
Registration and reporting: Obligated companies must register with PackUK and regularly report on the quantities of packaging they place on the market.
If you are unsure about your company's obligations or need assistance with compliance with EPR in the UK, Deutsche Recycling Service GmbH is here to help.
Companies that place packaging on the UK market muss report their packaging data until April 1, 2025 for the year 2024 under the new EPR system.
New legal requirements have been in force since January 1, 2024:
Large companies (with an annual turnover of over £2 million and more than 50 tons of packaging in the previous year) must submit their data for the period July to December 2024 by April 1, 2025 at the latest.
Small companies are obliged to report their packaging data for the entire period January to December 2024 by April 1, 2025.
In addition, all affected companies – regardless of size – must register with the relevant environmental authority by this date.
The reported packaging data forms the basis for calculating the EPR fees to be paid.
Companies that fail to meet their reporting or registration obligations face enforcement action by the authorities.
Is your company a distributor of packaging in the United Kingdom and you are unsure about what obligations apply to your business and whether you are complying with them? We are happy to help. Just get in touch.
We cordially invite you to our german webinar “EPR made easy” on Thursday, April 10, 2025, at 10:30 a.m..
Our expert Sascha Aue will explain to you in an understandable and practical way what Extended Producer Responsibility (EPR) means, who it affects and what steps you need to take to be compliant.
Register now and secure your place in the webinar!
In our webinar on Thursday, April 17, 2025 at 10:30 a.m., Fabienne Valambras will explain everything you need to know about extended producer responsibility (EPR) in France.
Find out what impact the multitude of EPR categories and legal requirements has – and what companies should consider when entering the market.
Afterwards, we warmly invite you to a Q&A session where you can ask our expert your questions directly.
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.
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