We warmly welcome you to our 6th 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
New Packaging Regulation (PPWR) - Obligation for Online Retailers and Manufacturers
EPR for Textiles in the EU
EPR Textile - Outlook in respective EU countries
New Product Safety Regulation from 12.2024 - Obligations for Retailers
Fresh Up - Reminders / Dates
We hope you enjoy reading the newsletter and look forward to your feedback! Best regards,
Deutsche Recycling
New Packaging Regulation (PPWR) - Obligation for Online Retailers and Manufacturers
The new EU Packaging and Packaging Waste Regulation (PPWR) and Extended Producer Responsibility (EPR) have profound implications for manufacturers and e-commerce.
Key points for online retailers and manufacturers:
Authorized Representative Requirement: The regulation mandates both online retailers and manufacturers to appoint an Authorized Representative in each EU member state where they sell their products. This representative is responsible for waste disposal and recycling of packaging waste.
Recyclability: Packaging must be recyclable, with its components separable and ideally individually recyclable.
Packaging Minimization: Packaging should be designed to minimize weight and volume to the required minimum.
Labelling Requirements: Packaging must be labelled appropriately before being placed on the market. The new regulation introduces new labelling requirements (starting from around 2026) and a QR code (starting from around 2027).
The PPWR will be presented for approval in the European Parliament by the end of March. If approved, it could come into force by 2025.
If you 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 request for assistance.
On March 14th, the European Parliament adopted recommendations for the proposed revision of the EU Waste Framework Directive and the EU Strategy for Sustainable and Circular Textiles.
Affected Companies:
Extended Producer Responsibility (EPR) is intended to obligate companies selling clothing in the EU (regardless of whether it was manufactured in the EU or imported) to take responsibility for the entire lifecycle of their products. This includes disposal, recycling, and reuse of textiles.
Combatting Illegal Exports of Textile Waste:
The proposed regulations of the EU Textile EPR Directive, which is to be gradually implemented from 2025, will also facilitate the separate collection of textiles. Another significant aspect of the EU Textile EPR Directive is combating illegal exports of textile waste to countries that are not adequately prepared for it. The new regulations clearly define what constitutes waste and what is considered reusable textiles. It will establish new infrastructure for the separate collection, sorting, reuse, and recycling of used clothing in the EU.
The introduction of EPR for textiles is intended to help reduce the environmental impacts of textile production.
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EPR Textile - Outlook into respective EU countries and the implications for manufacturers
Some European countries have already passed legislation on Extended Producer Responsibility (EPR) for textiles and begun to establish textile EPR programs.
France: France is the first EU country with an EPR system for textiles. Under the "Circular Economy and Anti-Waste Law," adopted on February 10, 2020, manufacturers and importers of textiles are now required to bear the costs of collecting, recycling, and disposing of textile waste. Registration is mandatory for manufacturers, importers of textiles, and distribution platforms placing goods on the market in France.
Netherlands: Since July 1, 2023, manufacturers, importers, and retailers of textile products are responsible for the recycling and reuse of textiles. They are responsible for an appropriate collection system, recycling, and reuse of clothing and home textiles, as well as financing the entire system. Foreign retailers targeting the Dutch market cannot register directly; they must work with authorized representatives in the Netherlands.
Sweden: Measures for Extended Producer Responsibility (EPR) for textiles were introduced on January 1, 2022. From January 1, 2025, obligated companies must be registered with a licensed textile collection system. Exporters must also comply with the EPR guidelines for textiles in Sweden.
Italy: On February 2, 2023, the Ministry of Environment and Energy Security (MASE) in Italy introduced a draft decree. This decree identifies new obligations for manufacturers in the textile sector regarding the design, production, disposal, and recycling of textiles. Since 2022, separate collection requirements for textile waste apply to both manufacturers and importers and retailers.
Latvia: Latvia passed an amendment on March 16, 2023, requiring manufacturers, importers, and retailers of textile products to bear the costs of collecting, processing, and recycling their textile waste. These costs would be part of the EPR fee. The reporting obligation for textiles in Latvia comes into effect on July 1, 2024.
If you need assistance with compliance, 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 request for assistance and support.
New Product Safety Regulation from 12.2024 - Obligations for Retailers
As of December 13, 2024, the new European General Product Safety Regulation (GPSR) will come into force. The new regulations are intended to ensure that consumers are offered only safe products, regardless of the origin of the products or whether they are sold in stores or on online marketplaces.
Specific obligations for retailers:
Control and Verification: Retailers must ensure that products, before being placed on the market, are marked with a type, batch, or serial number or contain other identifiable elements. They must also provide clearly identifiable information about the manufacturer and clear instructions for the safe use of the product.
Ensuring Storage and Transport Conditions: Retailers must ensure that storage or transport conditions do not affect the conformity of the product.
Ensuring Product Safety: Retailers must have internal procedures to ensure product safety.
Sales Prohibition and Reporting Obligation: If retailers find that a product does not comply with requirements or is dangerous, they must not place it on the market. In the event of such a product, they must inform the manufacturer, ensure that corrective actions are taken, and inform the market surveillance authorities.
Application as Manufacturer under Certain Circumstances: Under certain circumstances, retailers may be considered as manufacturers if they place a product on the market under their name or make substantial changes to the product that affect its safety.
Do you need assistance with implementing the Product Safety Regulation?
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United Kingdom - EPR for Packaging: Large producers importing or supplying packaging must submit their reports by no later than May 31, 2024.
Denmark - EPR for Packaging: Manufacturers must register by April 1, 2024. Reporting of planned packaging quantities must be submitted by no later than September 30, 2024.
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