June 2024 Newsletter

Newsletter: June 2022

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

Chile EPR Reporting Requirements for 2023 Data

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The Ministry of Environment in Chile recently published Resolution Ex. N°1025/2024, under the framework extended producer responsibility (EPR) law. This resolution mandates producers of priority products to report quantities placed on the Chilean market in 2023 by July 15, 2024. Priority products subject to this obligation are:

  • Lubricating oils
  • Electrical and electronic equipment (EEE), which includes a broad scope of devices
  • Portable batteries (Pilas) – batteries under 5kg
  • Industrial Batteries (Baterias) – batteries over 5kg
  • Packaging and containers, including for producers who placed less than 300 kilograms of packaging, reusable packaging, and packaging in the “other” category on the market annually
  • Tires for bicycles, wheelchairs, and solid tires
  • Graphic paper (i.e. newspapers and magazines)

Law No. 20.920 (EPR Law) published in 2016 set the framework for recycling and waste management of these products. While data reporting requirements have started, the Ministry must publish decrees for each product type to establish full EPR with specific targets and obligations for producers. Currently, the only priority products with fully implemented legislation are Tires and Packaging and Containers, which include additional obligations beyond the reporting requirements of this resolution. EEE, Portable Batteries, and Industrial Batteries are subject to the upcoming reporting deadline but no further EPR requirements; this is awaiting secondary regulations.

Accerio can assist your company with assessment, registration, and data management to prepare for the reporting deadline. Please contact us if your company markets products in Chile.

Minnesota Passes 5th Packaging EPR Law in the US

Minnesota governor Tim Walz signed bill HF3911-4 on May 21, 2024, establishing the Packaging Waste and Cost Reductions Act. The Act details requirements for packaging producers making Minnesota the fifth state in the US to adopt packaging extended producer responsibility (EPR). Similar to other packaging laws in the US, the Act aims to increase the recycling rate of packaging in the state.

Covered materials include product packaging, food packaging, and paper products. Like California, Colorado, Maine and Oregon, the Act mandates the creation of a Producer Responsibility Organization (PRO) and an advisory board by January 1, 2025. Producers must join a PRO by July 1, 2025; however, the states program implementation is not expected until 2029. With this deadline approaching, more information on PRO registration steps for producers is anticipated soon.

Between 2025 and 2029, the program will gradually roll out, primarily with the Minnesota Pollution Control Agency (MPCA) conducting a comprehensive needs assessment of the state recycling system and approving PRO stewardship plans. While the Act does not specify targets for recyclability, collection, or compostability, it includes provisions that ban materials not covered by an approved stewardship plan after January 2032.

Accerio is assisting producers with registration under current US packaging obligations and monitoring upcoming deadlines.

Vermont and Illinois Battery EPR Updates

Two miniature workers with yellow alkaline batteries

Two US states made critical updates to their battery compliance in June. Illinois enacted a battery extended producer responsibility (EPR) law (SB3686) covering portable batteries, medium format batteries, and battery-containing devices. Similarly, Vermont amended their EPR law through S.254 (Act 152), broadening the state’s 2014 battery EPR law to include rechargeable batteries, battery-containing devices, and a broader range of primary batteries.

Prior to this amendment, Vermont’s battery EPR law was limited to manufacturers of standalone primary batteries < 4.4 lbs. intended for consumer products. Starting January 1, 2026, all obligated batteries should be registered under an approved battery stewardship plan. Additionally, the Secretary of Natural Resources of Vermont is required to conduct a needs assessment for EV/hybrid batteries, energy storage system batteries, and batteries that are not easily removable from products before July 1, 2026, to address future battery recycling needs.

Producers subject to Illinois’ battery EPR law also must register under an approved battery stewardship plan by January 1, 2026.

Both states’ laws include some exclusions, such as batteries that are not easily removable from their devices, automotive lead acid batteries, and batteries contained within professional medical devices.

If your company sells batteries into the US, please contact Accerio for assessment of your current and upcoming obligations.

Implementation of Spain Packaging Regulatory Changes by Ecoembes

Spain ministerio-para-la-transicion-ecologica

In 2023, Spain implemented a new packaging and packaging waste law requiring all producers, both local and foreign, to register with the Packaging National Register and implement an extended producer responsibility (EPR) scheme, either individually or collectively. Prior to the new law, only household packaging producers were required to register directly with the collective organisation Ecoembes.

During the transition to the new law, the National Packaging Register provided a grace period to producers, allowing time especially for foreign producers to appoint an Authorized Representative (AR), register with the National Packaging Register, and implement an EPR scheme. Up to now, Ecoembes has allowed members under the old law to remain registered with them. However, effective June 30th, 2024, membership contracts of foreign producers without an AR will be terminated so that contracts reflecting the new structure can be drafted.

If your company is in the process of registering through the new system, it is crucial to notify Ecoembes about this and inform them on your appointed AR. If you are not re-registering at this time, please be aware that your contract with Ecoembes will not extend beyond June 30th.

Accerio offers management services for Spain EPR packaging compliance, including assessment, registration, and reporting preparation. Contact us if your company seeks compliance under Spain’s new packaging waste law.

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