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January 2024 Newsletter

Newsletter: January 2024

The latest news regarding WEEE, e-waste, battery and packaging compliance

Canadian EPR Advancements


Extended Producer Responsibility (EPR) is gaining traction across Canada as provinces make significant strides towards sustainable waste management practices. Recent developments in Alberta, Yukon, Quebec, Nova Scotia, and British Columbia highlight their efforts to transition to full EPR models, which especially impacts the programs’ funding models.

Alberta is shifting from a shared funding model between producers and municipalities to a fully producer funded EPR approach. Alberta is set to implement full EPR for packaging with registration open since November 2023. Producers will be required to meet specific thresholds of revenue and packaging volumes, and they must join a Producer Responsibility Organization (PRO) to ensure compliance. Nova Scotia has also implemented a full EPR system with producer registration currently open for initial data submissions and on track for the program to begin in 2025.

Other noteworthy updates in Canada include:

  • Yukon amendments to the Environmental Act pave the way for the implementation of Extended Producer Responsibility, starting with packaging. The draft regulation is expected to be unveiled early in 2024.
  • Quebec updated their definition of obligated producers to include online retailers and distance sellers, which took effect in 2023. Additionally, Quebec plans to amend its packaging regulations by 2030 to obligate professional packaging; they are the first province with concrete plans to scope in professional packaging.
  • In British Columbia, the first prohibition date of their upcoming plastic ban has been postponed to July 2024. This delay impacts single-use food service items, plastic shopping bags, and oxo-degradable plastics.

Due to the multiple recent and upcoming changes to legislation in the Canadian provinces, please reach out to us for an assessment. Accerio offers monitoring and full-service compliance management in Canada.

India Battery and Plastic Waste Rules Amended

The Indian Government recently introduced amendments to the Battery Waste Management Rules (BWM Rules), 2022, and the Plastic Waste Management Rules (PWM Rules), 2016.

Two notable amendments apply to both the Plastic Waste Management Rules and the Battery Waste Management Rules:

  • The Central Pollution Control Board (CPCB) is now empowered to extend the annual reporting deadline up to a maximum period of nine months beyond the yearly deadline of June 30th.
  • Extended Producer Responsibility (EPR) registration will remain valid until it is canceled or withdrawn, eliminating the need for periodic renewals.

The PWM Rules were amended for the 8th time. The amendment updates the definition of ‘Producer’ to exclude scenarios involving imports, focusing on entities directly involved in the production of plastic packaging within the country. Additionally, all obligated entities and all categories of plastic packaging are now subject to specific marking and labeling requirements, such as including the name of the entity and producer registration number on packaging that contains plastic.

The 1st amendment to the BWM Rules introduces several noteworthy changes, starting with expanding the definitions of ‘Producer’ and of obligated batteries to address identified gaps in compliance requirements. Reporting requirements have also been expanded to include batteries for self-use and pre-consumer waste generated during manufacturing, assembling, or import. Labeling requirements are also included in the amendment. Now, Producers are mandated to mark all batteries or battery packs with their EPR registration number on or before March 31st, 2025.

If your company manufactures, assembles, or imports products in India and would like to further understand your obligations, please reach out to Accerio for an assessment and registration plan.

USA PFAs Compliance

RPU Products Containing PFAS

Perfluoroalkyl and polyfluoroalkyl substances, commonly known as PFAs, have gained notoriety as “forever chemicals” due to their persistent nature and potential threats to both human health and the environment. Found in a myriad of everyday products, PFAs have become a focal point of regulatory efforts and both the United States and the European Union have taken initial steps.

In the European Union, the Stokholm Convention has been a platform for discussions on restricting the use of PFAs. Furthermore, the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) system actively manages PFAs levels. Several PFAs are listed on the REACH Candidate List of substances of very high concern (SVHC), underlining the need for stringent controls.

In the United States, the Environmental Protection Agency (EPA) has mandated U.S. manufacturers and importers of products containing PFAs to report information on PFAs uses, production volumes, disposal, exposures, and hazards. This reporting obligation impacts products manufactured and imported from January 1, 2011, to December 31, 2022, providing a comprehensive dataset for monitoring and assessing the prevalence of PFAs.

Maine has enacted a ban on intentionally added PFAs, effective from 2023 for certain products such as carpets and rugs. This ban extends to all products starting January 1, 2030. Maine requires a one-time report on PFAs, due by January 1, 2025. Similarly, Minnesota has implemented a ban on intentionally added PFAs, commencing on January 1, 2025, for specific products like carpets and cookware. The ban expands to cover all products from January 1, 2032, onwards. As part of its comprehensive strategy, Minnesota mandates a one-time report on PFAs, with a deadline set for January 1, 2026.

It is recommended that producers collect information on PFAs content in their products to prepare for reporting requirements.

January 2024 Newsletter Read More »

February 2019 Newsletter

Newsletter: February 2019

The latest news regarding WEEE, e-waste, battery and packaging compliance

German Scope Updates


At the beginning of the year the German WEEE authority announced that “passive” devices (devices that only transmit currents or signals) will be in scope as of the 1st of May and thus need to be registered  This development brings Germany into line with what is already common practice in many other European countries.

Here are some examples of passive devices: 

Passive devices are to be categorized in either category 4 (large devices), category 5 (small devices) or category 6 (small ICT devices).

Passive devices vs. components

To differentiate between Passive Devices and Components, the new rule is of relevance to end-equipment designed for operation with a maximum alternating voltage (AC) of 1,000 volts or a maximum direct voltage (DC) of 1,500 volts. Components, such as cable by the metre, ferrules or ring cable lugs, remain out of scope.

If you are a manufacturer of passive devices, you should check the following:

Do you already have a registration for the corresponding device type and brand?

Yes, I have the required registrations No, I am not registered in the required categories
From May onwards, we can simply add the quantities of your passive devices in the corresponding device type to your regular reporting. Please get in touch with us so that we can arrange for a respective registration. As the approval procedure by the respective Authority can take up to 12 weeks it would be preferable to apply for registration in February.

If you need any help within this process, please contact your Accerio Account Manager who will be happy to assist you.

2018 in Review


2018 was a big year in the WEEE/e-waste, batteries and packaging compliance world, with some significant changes and developments.

  • The European Union underwent a significant change with the advent of new reporting categories, called Open Scope, to expand and facilitate improvement of recycling and reporting of electronic waste. The previous system used 10 categories and the new system has 6 categories for reporting and more products are now expected to be reported.
  • The German reporting structure underwent some big changes with the new packaging law and associated authority launching, plus bringing new products into scope (see passive instruments article for reference).
  • Poland launched the new BDO environment authority superseding the previous GIOS organization and expressed intent to increase enforcement activities. 
  • Portugal experienced significant changes in the reporting systems and procedures. Additionally the Portuguese Environmental Agency became more active in enforcing correct implementation of Authorized Representative requirements and notifying distance sellers of packaging obligations.
  • 2018 saw an increase in compliance enforcement activities across the EU, especially in Ireland and Germany, with a greater and more aggressive focus on the full range of compliance requirements that occur after registration.
  • The advent of the European WEEE Enforcement Network (EWEN) which co-ordinates environmental authorities across the EU started in late 2017 and stepped up their strategy and efforts to crack down on free-riders in 2018, especially the growing area of online sales of electronics.

The changes in 2018 demonstrate that ongoing monitoring of the ever changing EU WEEE, batteries and packaging compliance landscape is imperative to ensuring full and correct compliance with stricter enforcement expected in 2019, and Accerio as your compliance partner is here to ensure you are covered.

E-Waste Compliance in Canada


In Canada, E-Waste laws are in place in all 10 provinces and in 2 out of 3 territories (with Nunavut the exception). Provincial and territorial governments regulate Extended Producer Responsibility programs through local law. Some governments began targeting e-waste management about 20 years ago, while others came into effect as recently as 2017.

 Canada requires producers to participate in an approved stewardship program and to pay the appropriate environmental handling fee (EHF) for each regulated product sold into a province or territory. While the country continues to move toward standardization of product categories, each province and territory maintains their own laws and individual list of products that are considered to be in scope of e-waste.

 EPR laws focus e-waste stewardship responsibility on a variety of players, including manufacturers, brand owners, importers and retailers. It can be difficult for companies that sell into Canada to know what their EPR requirements are, whether the products they sell are ‘regulated’ and into which province or territory they are considered to be regulated. In addition, regulated product lists continue to evolve, making it necessary to review obligation status on an ongoing basis. There are also battery and packaging laws in place which look at producer responsibility differently from e-waste, which adds to the complexity of meeting compliance requirements.

 If your products are sold into Canada and you would like to understand whether you have any obligations as a steward, you can simply contact Accerio for an obligation assessment. Our country experts keep track of this ever changing landscape and are available to help simplify compliance in Canada and help you fulfill your legal obligations. 

February 2019 Newsletter Read More »

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