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March 2025 Newsletter

Newsletter: March 2025

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

US Packaging EPR’s First Major Producer Deadlines

U.S. Department of Agriculture (USDA) Secretary Sonny Perdue (blue/green gingham shirt and tan mask) and Senator John Cornyn (blue gingham shirt and blue bandana/mask) tour McLane Global, one of USDA’s partners in feeding rural kids in Texas and across America who have been impacted by school closures as a result of COVID-19.

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 The Secretary and Senator will tour the food box packing facility and participate in a discussion with partners Baylor Collaborative on Hunger and Poverty, Charwells K12, and PepsiCo, on July 16, in Houston, TX. The tour is led by Mclane Global Chairman Denton McLane. Also attending are U.S. Congressman Daniel Reed Crenshaw, Texas Secretary of Agriculture Sid Miller, McLane Global CEO Todd Avery, Chairman Drayton McLane, Jr., and #MillionMeals partners Baylor Collaborative on Hunger and Poverty Director of Government Relations Grace Norman, PepsiCo Food for Good Director Matt Smith, and Chartwells K12 CEO Belinda Oakley. All USDA Food and Nutrition Service (FNS) programs – including the Supplemental Nutrition Assistance Program (SNAP); Special Nutrition Program for Women, Infants, and Children (WIC); and the National School Lunch and Breakfast Programs – have flexibilities and contingencies built-in to allow them to respond to on-the-ground realities in the event of a disaster or emergency situation.USDA Photo by Lance Cheung. Original public domain image from Flickr

Extended Producer Responsibility (EPR) laws in the U.S. are evolving with several states actively implementing or considering EPR legislation. Legislative initiatives are implemented at the state level which results in variation among laws from state-to-state, adding a layer of complexity when it comes to producers’ obligations.

States with active packaging EPR in the US are California, Colorado, Oregon, Maine, and Minnesota. There are several additional states in the process of developing EPR legislation. The deadlines for producers to keep in mind are:

  • Oregon’s first reporting deadline of March 31, 2025, where producers will report their volumes to inform the Oregon program fees
  • Minnesota’s July 1, 2025 producer registration deadline
  • Colorado’s proposed reporting deadline shortly after Oregon’s, which is slated for July 31, 2025
  • California’s proposed reporting deadline of August 31, 2025

To prepare for these deadlines, companies should start by assessing their obligations, as there are specific thresholds and packaging scope considerations in each state. Accerio conducts such assessments and supports companies with registration and reporting data preparation.

Portugal Packaging Sorting Instructions

Portugal has introduced packaging sorting instruction obligations for producers of non-reusable packaging. Providing customers with sorting information promotes accurate waste separation and enhances the volume and quality of waste recycling materials.

  • The obligation can be met in one of two ways:
    Marking primary and secondary non-reusable packaging
    • The marking should indicate the appropriate waste bin of the packaging material
    • Marking can be in the form of pictograms representing the bins or in a QR code that guides the customer to such pictograms
  • Providing customers with the information on the appropriate destination of the packaging material at the point of sale
    • Point of sale applies to physical establishments (e.g.: retail stores, supermarkets, etc.) or the producer’s website

Portugal recognizes that the rules above must adapt to packaging marking and digital tool requirements in line with the new EU Packaging and Packaging Waste Regulation (PPWR). Please contact Accerio for further information on packaging labelling and sorting instruction requirements.

India Battery and Plastic Waste Management Rules Update

The Ministry of Environment, Forest & Climate Change has recently updated the labeling requirements for battery and plastic packaging EPR obligations. Registered producers of batteries and registered producers, importers, or brand owners (PIBOs) of plastic packaging now have the option to display their name and EPR registration number via a Quick Response (QR) Code or Barcode, provided they inform the Central Pollution Control Board (CPCB) of the details. The updates to the Plastic Waste Management Rules also introduced penalties, such as fines and legal action, for non-compliant PIBOs.

For plastic packaging, the QR Code or Barcode can be printed directly on the packaging. For battery, it may be placed on:

  • Batteries or battery packs
  • Equipment containing a battery or battery pack
  • Packaging for batteries or battery packs
  • Packaging for equipment containing a battery or battery pack
  • Bulk packaging of batteries or battery packs (not intended for retail sale)

Alternatively, for both battery and plastic packaging, the EPR registration number may be included in the product information brochure.

Utilizing these digital tools is an optional provision, allowing the choice to use a QR code or Barcode instead of directly printing the company name and EPR registration details on the packaging or battery. Please contact Accerio for additional information on EPR requirements in India.

Hungary Tax-Based EPR System Ends

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Hungary had overlapping, or dual, systems for Extended Producer Responsibility (EPR) in place for the past few years, meaning many producers paid fees through both systems. The tax-based system started in 1995, with environmental product charges via the tax system for a specific list of products. In 2023, Hungary published Decree 80/2023, which created a new extended producer responsibility system. Most recently, in January 2025, Hungary published Act LXXXIX of 2024, which brought about a series of modifications to various legal texts, including the ones governing over the two systems. These changes eliminate the dual system.

Starting 1st January 2025:

  • Standard EPR: “extended producer responsibility products” or circular products are:
    • Packaging, SUP (single use plastic), Paper Stationery, and Commercial Printing Papers
    • Electrical and Electronic Equipment
    • Batteries and Accumulators
    • Textiles
    • Wooden furniture
    • Tires
    • Cooking Oil and Grease
    • Motor Vehicles
  • Tax-based “environmental protection products charge products” are:
    • Other plastic products, like: Plastic carrier bags made of plastic, Flowers, foliage and fruit of plastics and parts thereof; articles made of artificial flowers, foliage or fruit
    • Other chemical products, like: Soap; organic surface-active agents; washing preparations, wet-wipes, Cosmetic or toilet preparations
    • Other petroleum products
  • Plastic carrier bags remain to be considered both “extended producer responsibility products” and “environmental protection products charge products” and remain subject to both fees

If your company sells products to Hungary, please contact Accerio for assessment and registration services.

March 2025 Newsletter Read More »

December 2024 Newsletter

Newsletter: December 2024

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

EU Parliament Adopts EU Packaging Regulation

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The European Union Parliament formally approved the EU Packaging and Packaging Waste Regulation (PPWR) during a plenary session on November 26, 2024. The European Council then adopted the final text on December 16th with final publication in the EU Official Journal expected in the coming weeks. The Regulation will come into force 20 days following the final publication.

Once the Regulation is in effect, EU Member States will have an 18-month transition period to implement its provisions. Compliance deadlines will vary, especially the provisions that are awaiting implementing legislation. After the 18-month transition period, the PPWR will replace the existing EU Packaging and Packaging Waste Directive.

The PPWR includes several measures for businesses:

  • Establishment of reuse targets, restrictions on certain single-use packaging, restrictions on certain hazardous substances, and recyclability and recycled content requirements
  • Reduction of unnecessary packaging through setting maximum empty space ratios and decreasing packaging weight and volume
  • Declaration of Conformity that details packaging is compliant with provisions in the PPWR
  • Required labeling with details like material composition, recycled content, hazardous substances, and manufacturer/importer information

With these new producer requirements on the horizon, please contact Accerio for assessment, data preparation, and compliance assistance.

India Draft Rules for EPR Packaging

The Ministry of Environment, Forest, and Climate Change released a Draft Rule for Extended Producer Responsibility (EPR) for packaging made from Paper, Glass, Metal, and Sanitary Products on December 6, 2024. The enforcement of these rules is scheduled for April 1, 2026. These rules add to India’s EPR packaging obligations, which have been active for plastic packaging since 2016.

Key Impacts of the Draft Rule:

  • Obligated producers, importers, and brand owners are Indian companies who introduce packaging made of glass, metal (excluding non-ferrous metal-based packaging), paper, or paperboard and sanitary products into the market.
  • Obligated entities will have to register through centralized online portal, which is yet to be developed.
  • EPR targets begin from 2026-27 onwards with a 70% collection target obligation on all packaging.
  • Additional circularity targets include recycling and use of recycled content.
  • EPR targets are fulfilled by procuring EPR certificates from registered waste processors, recyclers, or end-of-life disposal facilities via a centralized online portal.

If your company is a producer of packaging, or an already active EPR stream in India, please contact Accerio for assessment and obligation information.

Canada EPR Developments

The amount of Extended Producer Responsibility (EPR) programs across Canada has continued to grow, with advancements across multiple waste streams. Recent developments range from entirely new programs obligating batteries and packaging for the first time to extensive scope expansions in some of the oldest programs.

Noteworthy updates in Canada include:

  • Alberta announced a scope expansion coming into effect April 2025 for small home appliances, audio visual & telecommunications equipment, electronic toys, music devices, and lawn & power tools.
  • In British Columbia, the Canadian Electrical Stewardship Association (CESA) WEEE program transitioned to management by EPRA, which impacts compliance for electronic products such as small appliances and power tools. Reporting via EPRA begins with January 2025 put on market data.
  • The producer definition in the Saskatchewan packaging regulation has expanded to include companies with a presence in Canada. This change has significant implications for the number of obligated producers in Saskatchewan.
  • Ontario has delayed the initial supply data verification for registered Blue Box packaging producers until 2026.
  • New Brunswick passed a law obligating stand-alone batteries. There is currently a legal obligation to register with the authority RecycleNB. However, the official stewardship plan is yet to be published, expected by the end of December 2024. Reporting obligations will begin in 2026.
  • Other notable EPR programs coming into effect in 2025 are: Alberta Packaging, Nova Scotia Packaging, Yukon Packaging, and Yukon Hazardous Waste.

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.

December 2024 Newsletter Read More »

September 2024 Newsletter

Newsletter: September 2024

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

Accerio B.V. Has Moved to a New Amsterdam Office Location

We have moved to a new location in Amsterdam; it’s a beautiful location in the heart of the city. We love the big bright windows and the view of the bustling street and canals. This office has space to accommodate our growing team, and the new location makes us excited for what is to come.

Please check that you have our two current office addresses in your system:

Accerio B.V.
Keizersgracht 307-bel
1016 ED Amsterdam
The Netherlands

Accerio Global
2005 Broadway Street
Boulder, CO 80302
USA

EU Member States Align with EU Battery Regulation

European_Commission

On July 28th, 2023, the European Commission published the EU Battery Regulation in the Official Journal of the European Union. The Regulation came into force on August 17th, 2023, and applied directly in all EU member states after a period of 6 months. Now, a year after coming into force, several EU member states have released draft laws and amendments to align their national legislation with the Battery Regulation.

Croatia: Their draft law was submitted to Parliament on July 29, 2024; it defines the responsibilities of authorities and introduces penalties for non-compliance with extended producer responsibility (EPR), labelling, and battery passports. While the focus is on enforcement and penalties, no changes have been made to the current EPR system, maintaining the existing fund-based waste management model. The law aims to enhance compliance with EU battery standards.

Czech Republic: The proposed amendments are planned to come into force in phases starting from January 1, 2025. Notably, the draft law imposes distributor obligations on online platforms, introduces mandatory collective compliance for producers of portable batteries, light vehicle batteries, and industrial batteries, and requires distinguishing the costs for the management of waste batteries (visible eco fees) from the battery price for all types of batteries apart from portable batteries.

France: Changes are being made in a phased approach, with a mid-2024 law already in force to align certain due diligence and reporting with the Battery Regulation. The law introduced EPR requirements for professionally prepared re-used, repurposed, and remanufactured products subject to EPR in France (which includes WEEE, waste batteries and packaging waste) . In the next phase, a draft decree which, if passed, would come into force January 1, 2025 and would require distributors to display the eco fees paid by the producer under its EPR obligations at the point of sale of a new battery. The draft would also require holders of light means of transportation (LMT) batteries, industrial, and electronic vehicle (EV) batteries, which are prepared for reuse or repurposing, to provide documentation of the battery’s state of health, subsequent use, and appropriate protection against damage during transport if requested by a competent authority.

Germany: A draft law was published in May 2024 and, if implemented in its current state, would expand the scope of obligated battery types to match the EU Battery Regulation, enhance requirements for producers who comply with their EPR obligations via a collective organization, and introduce authorized representative requirements for foreign producers. Collective organizations would need to undergo a new approval procedure with the authority and design eco-modulation incentives for EPR fees of batteries that have a lower negative environmental impact.

As these and other EU countries align their legislation, we are tracking the initial actions and deadlines that producers need to meet. Please let us know if your company needs support with European EPR battery compliance.

Romania Expanded WEEE Eco Fee Requirements

Repair

On May 18, 2024, Romanian Law No.127 entered into force which modified the existing 2015 law. This amendment expanded producer obligations to communicate WEEE eco fees to ‘potential buyers’ prior to the point of sale for electric and electronic products. To achieve this, the management fee for each category of electric and electronic product must still be displayed and listed separately from the cost of electric and electronic products.

Under the previous law, Producers with activities in Romania were already required to display their eco fees on the client’s invoice documents and/or on the website order page (like how VAT is displayed), to inform their customers. However, this amendment expands the requirements, to inform any potential buyers. Though Law No.127 does not specify a mandatory way of conveying this information, producers can display their eco fees on product price tags, stock display stands, purchase pages/inventory detail widgets on their website, just to name a few.

In addition to the eco fee obligation, Law No.127 impacts collective organizations and authorized representatives, by increasing collection rate goals and adding supportive legal provisions.

Producer obligations to display the environmental management fees, or eco-fees, are increasingly common. For guidance on these requirements globally, please contact Accerio.

Two New EPR Streams in India

The Ministry of Environment, Forest, and Climate Change of India recently published a series of amendments to the Hazardous and Other Wastes (Management and Transboundary Movement) Rules 2016, introducing new Extended Producer Responsibility (EPR) streams.

The first is an amendment introducing EPR for Used Oils, effective from April 1, 2024, to regulate the management of used oil produced by manufacturers, importers, and recyclers. The oils in scope include virgin base oil, white oil, hydraulic oil, transformer oil, cutting oil, rubber processing oil, thermal fluids, anti-rust oil, general purpose lubrication oil, engine oil, brake oil, grease, re-refined/recycled base oil, gear oil, turbine oil, and compressor oil.

Producers, importers, recyclers, and collection agents all hold obligations under the amendment. Specifically, the obligated entities must register on the portal and report annually on or before June 30th each year. Producers also must fulfil EPR targets by purchasing EPR certificates from registered recyclers.

Second is a draft amendment, passed on August 14, 2024, introducing an EPR framework for non-ferrous metals (aluminum, copper, zinc, or their alloys). If passed into law, this amendment would be effective from April 1, 2025, mandating that producers of non-ferrous metals register with the Central Pollution Control Board (CPCB) and fulfil their EPR obligations by ensuring the collection, recycling, or refurbishing of their products.

If your company is a producer of oils, non-ferrous metals, or an already active EPR stream in India, please contact Accerio for assessment and obligation information.

Ireland Consultation on Individual Battery Compliance

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Ireland conducted a public consultation earlier this year on compliance options for battery EPR producers. After the close of the consultation in May, the Department of the Environment, Climate, and Communications entered final review and is expected to publish the outcome of the consultation soon.
Presently, producers in Ireland can finance the management of waste batteries in two ways:

  • through membership of a collective organization (WEEE Ireland or ERP Ireland), or
  • self-complying and arranging for the collection, transport, and treatment of their waste batteries themselves.

Additionally, the EU Battery Regulation allows Member States to implement national measures that obligate producers to join a collective organization (removing the possibility to self-comply). However, Member States need to justify the removal of the self-compliance option; in this case, starting with a public comment period to gather perspectives from producers and economic operators in Ireland.

If the outcome of the consultation supports removing the self-compliance option, we can expect a draft amendment to Statutory Notice 283 of 2014 containing the Batteries and Accumulators Regulations. Accerio will monitor this change and be in touch with relevant updates.

Accerio Presenting at the PSX Conference in Denver

Accerio was selected to speak at the Product Stewardship Society’s annual PSX conference, which will be held October 15th-17th at the Grand Hyatt in Denver. The event focuses on education, trends, and solutions for product stewardship professionals.

Accerio’s session, “Practical Challenges of Global Extended Producer Responsibility Implementation”, will pull from our vast practical experience and highlight the impacts of existing and upcoming global EPR legislation, including U.S. packaging laws, the European Union’s battery and packaging regulations, plastic packaging taxes, and eco-modulation concepts. We will provide practical guidance for what organizations’ operational teams and leaders must know to prepare for significant changes now and in the coming years.

If you are attending the PSX 2024 conference, please get in touch. We would enjoy meeting you in person!

September 2024 Newsletter Read More »

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.

June 2024 Newsletter Read More »

March 2024 Newsletter

Newsletter: March 2024

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

Amendment to the EU WEEE Directive

European_Commission

The European Union introduced an amendment to the Waste Electrical and Electronic Equipment (WEEE) Directive, aiming to provide clarity to certain areas and update respective Articles. Directive (EU) 2024/884, published on March 13th, 2024, introduces several changes to Directive 2012/19/EU, which Member States are required to implement into their national laws by October 9th, 2025.

One significant addition is Article 24a, mandating a comprehensive review of the EU WEEE Directive by December 31st, 2026. This review will encompass critical provisions concerning:

  • legal certainty regarding retroactive requirements,
  • implementation of the waste hierarchy,
  • protection of consumers from WEEE treatment costs,
  • ensuring effective enforcement by Member States,
  • creation of a new category for photovoltaic panels, aligning collection targets with the expected product lifespan,
  • and a mechanism to finance future EEE treatment costs in the event of producer failure or liquidation.

This amendment follows a ruling by the Court of Justice of the European Union on January 25th, 2022, invalidating Article 13(1) of Directive 2012/19/EU concerning photovoltaic panels placed on the market between August 13th, 2005 and August 13th, 2012 due to unjustified retroactive effect. Consequently, Articles 12 and 13 on financing the treatment of WEEE and Articles 14 and 15 on the marking of EEE have been revised to clarify effective dates for each scope change, with different effective dates for the original EEE scope (2005), open scope EEE (2018), and photovoltaic panels (2012). However, Member States are still tasked with determining responsibility for certain historical WEEE. Furthermore, Article 14 and Article 15 of the Directive have been updated to reference the latest European standard EN 50419:2022 on the marking of EEE.

Accerio will be reviewing the upcoming legislative updates in each Member State as well as tracking the progress of the EU Commission’s WEEE Directive review in 2026.

New Jersey Propulsion Battery EPR Law

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New Jersey has taken the lead by becoming the first US state to enact an Extended Producer Responsibility (EPR) law specifically targeting electric and hybrid vehicle propulsion batteries. This law, passed in January 2024, has come out of the national and global conversations on sustainable management of electric vehicle (EV) components.

Under the new law, producers of propulsion batteries are mandated to undertake several responsibilities to ensure proper management and disposal. One of the primary requirements is the labeling of batteries to enable better tracking and management throughout their lifecycle.

The definition of in-scope batteries covers batteries used to supply power to propel an electric or hybrid road vehicle, whether embedded within vehicles or provided separately from them. However, the law exempts starter batteries and those used for industrial purposes. The scope of obligated producers encompasses various entities involved in the production and distribution chain, including vehicle manufacturers, importers, battery manufacturers, remanufacturers, and importers. We encourage you to reach out to Accerio for assessment if your company sells electric vehicles or their batteries.

Next steps for Producers:

  • Register on the state’s registration portal by January 8, 2025 (the portal is not open yet).
  • Submit annual reporting of battery sales/distribution by January 8, 2026, and each subsequent year.
  • Develop and submit a battery management plan, with the deadline determined following a state-conducted needs assessment.

The state will conduct a needs assessment to identify specific requirements for battery management plans and labeling. In the meantime, producers are encouraged to assess their obligations and prepare for registration. Please contact Accerio for assistance assessing and monitoring obligations as the New Jersey program develops.

EU Advancement on Packaging Regulation

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In a significant development, the European Council presidency and representatives from the European Parliament have reached a provisional political agreement on the regulation concerning Packaging and Packaging Waste. This is the first major update since the proposal for the EU Packaging and Packaging Waste Regulation was announced in November of 2022. This provisional agreement also marks a step towards the goals outlined in the European Green Deal.

The proposal, prompted by concerns over packaging waste, aims to address its environmental impacts and to harmonize the internal market for packaging to drive the transition towards a circular economy. Key elements of the agreement include requirements for recyclability, minimizing harmful substances, and implementing standardized labelling to improve consumer information.

The proposal includes several measures for businesses:

  • Establishment of reuse targets, restrictions on certain single-use packaging, and mandates for economic operators to minimize packaging.
  • Reduction of unnecessary packaging through setting maximum empty space ratios and decreasing packaging weight and volume.
  • Obligation for take-away/to-go food businesses to offer customers the option of using their own containers, with a target of 10% of products in reusable packaging formats by 2030.

For Member States:

  • Implementation of deposit return systems for single-use plastic bottles and metal beverage containers by 2029, aiming for a 90% separate collection rate annually.
  • Restrictions on certain packaging formats, including single-use plastic packaging and lightweight plastic bags.

Despite challenges, such as balancing access to recycled plastics, the agreement aims to stimulate investment in green jobs. The next step involves formal approval by the Parliament and Council, with the expectation of implementation before the upcoming EU elections in June 2024. Accerio will monitor developments and provide guidance on the regulation’s impact on packaging design.

Peru Draft Packaging Law

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The Peruvian Federal Government introduced a draft decree at the close of 2023 aimed at addressing the management and handling of packaging waste. This draft, known as the Supreme Decree Approving the Special Regime of Management and Handling of Packaging and Container Waste (REE), recently closed for public comment and is now under discussion with Congress.

One of the core elements of the draft decree is the introduction of an Extended Producer Responsibility (EPR) system tailored specifically for packaging waste. Under this system, producers, including packers, fillers, and importers, will bear the responsibility for managing and handling the packaging waste generated from their products. While the decree aims to cover a broad spectrum of packaging waste, covering primary, secondary, and tertiary packaging of most material types, certain exemptions have been outlined. These include flexible packaging, hazardous waste packaging, primary packaging for drugs and medications, wood packaging, and microenterprises with operations valued below USD 20,000.

Producers falling within the scope of the decree will be mandated to implement and administer individual or collective packaging management systems. This entails obtaining approval from the Ministry of Environment for their management plans and submitting annual declarations to track progress towards predefined collection and recovery targets to be set by the Ministry.

Accerio can assess if your company would be impacted and help your company prepare for registration if the draft is approved.

March 2024 Newsletter Read More »

June 2023 Newsletter

Newsletter: June 2023

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

Washington State Signs Battery EPR Bill

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In May 2023, the governor of Washington State signed SB 5144, a new Extended Producer Responsibility (“EPR”) battery law providing for responsible environmental management of batteries. The law’s EPR obligations cover portable and medium format batteries (batteries up to 25lbs), as well as devices that contain such batteries. Products within this scope will be gradually phased into program management between 2027 and 2029. However, certain exemptions apply based on battery removability, battery or product function, and battery size and chemistry.

Obligated producers are the battery or battery containing product’s manufacturer, brand owner/licensee, importer of record, or first person to place on the market. Producers must join a stewardship organization (collective organization) starting 2027. Additionally, battery labeling requirements are phased in from 2028-2030. The labeling requirements apply to all covered batteries and battery-containing products, plus large format batteries (batteries greater than 25lbs and rating more than 2000 watt-hours).

Washington also has an active E-Waste EPR legislation covering certain products containing screens. Please reach out to Accerio for an assessment of obligations in Washington and for updates as the program develops.

Maryland's First Step towards Packaging EPR

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The State of Maryland passed legislation SB-222 with an effective date of July 1, 2023. The law aims to carry out a statewide ‘Needs Assessment’ of the current recycling systems. Unlike the other packaging extended producer responsibility laws in California, Colorado, Maine, and Oregon, SB-222 does not detail rules for producers but rather informs future EPR laws in Maryland.

To achieve that, SB-222 calls for the creation of a producer responsibility organization (“PRO”) and a producer responsibility advisory council. The advisory council is responsible for providing recommendations for the establishment and implementation of a PRO in the state for packaging materials. Recommendations will include responsibilities of producers under the PRO. The Office of Recycling in the Department of the Environment will carry out the statewide recycling Needs Assessment through an independent consultant. On or before December 1, 2024, the advisory council will report its findings and recommendations to the governor.

Accerio will be tracking the result of the Needs Assessment and subsequent development of the packaging EPR program in Maryland. Please contact us for assessment of your company’s obligations under USA EPR laws.

Changes Ahead for Canadian Compliance

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Canada has several updates to provincial/territorial EPR programs on the horizon, both to existing and upcoming legislation. There are already 9 hazardous waste laws, 7 battery laws, 5 packaging laws, and 12 WEEE laws active that obligate a variety of selling models for EPR.
The following changes will impact producers:

  • Quebec updated their producer definition for multiple EPR waste streams, now obligating online retailers and distance sellers. In most cases, interest is charged for back-reporting.
  • Saskatchewan household packaging is transitioning to full EPR. Prior to the change, producers are responsible for 75% of program costs transitioning to 100% of costs under the new system.
  • The New Brunswick Packaging + Paper Program is shifting away from a municipal-funded collection system to an EPR program.
  • Northwest Territories published draft legislation to serve as the legal basis for future EPR programs. If approved, initial work will determine which waste streams will be covered.
  • Yukon commits to implement EPR by 2025 for household batteries, packaging, and hazardous waste, as well as automotive waste, though no further announcements have been made.

Accerio can assess your company’s current and future obligations, manage registrations, and provide legislative monitoring.

Uruguay Draft WEEE Regulation

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The Uruguayan government published a draft for the Regulation on Comprehensive Management of WEEE (Reglamento para la gestión integral de residuos de aparatos eléctricos y electrónicos) on February 27, 2023. As of today, it is under discussion in congress and has not been approved.

The draft proposes to implement an EPR system for General WEEE producers and importers, including obligations to register and implement an individual or collective management plan for WEEE, and collection and recycling targets. The draft distinguishes between “General” and “Non-General” WEEE, the former being those devices that can be used indistinctly in household, businesses, or industry, and the latter are those devices that are specifically destined to be used in business or industrial environments. The regulation will not impose EPR obligations to producers and importers of Non-General WEEE but includes obligations to other stakeholders involved in waste management, such as waste processors and recyclers. The draft regulations will apply to an open scope of Electronic and Electric Equipment (“EEE”), including components, consumables, their accessories, and their integrated batteries. If approved, there will be requirements for EEE producers to promote durability and repairability and inform consumers of repair and take-back options.

Though the finalized timeline will not be clear until approval, the current draft indicates collection target deadlines beginning in 2024 and scaling up to an 85% collection target 5 years after the law’s publication. Accerio will update potentially impacted clients if the draft is approved.

June 2023 Newsletter Read More »

March 2023 Newsletter

Newsletter: March 2023

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

EU Packaging Regulation Proposal

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In November 2022, the European Commission proposed a European Packaging and Packaging Waste Regulation, addressing crucial sustainability and safety topics throughout packaging’s entire life cycle. A key distinction between the proposed Regulation and current Packaging Directive is that the Regulation will create a harmonized framework for all EU Member States without transposition in their local legal system. If approved, the Regulation will repeal the currently in force Packaging Directive.

Key aspects:

  • Obligations for all parties in the supply chain who place packaging on the EU market, for all packaging levels (primary, secondary and tertiary), and all packaging materials
  • New obligations throughout the life cycle of packaging, starting from its design and manufacturing to its end-of-life. Touching upon topics such as:
    • Recyclability
    • Minimum recycled content in plastic packaging
    • Targets for reusable packaging usage
    • Harmonized packaging labeling
    • Mandatory Authorized Representative appointment in each Member State where the obligated party places products on the market
    • Provisions on communication of information to end users
  • Prohibition on Member States introducing additional sustainability requirements if they are contrary to the Regulation’s provisions or restrict the free movement of goods in the EU Single Market

It is of note that the provision forbidding contrary or restrictive sustainability requirements is in line with the recent infringement procedure by the EU Commission that included the France Triman labeling requirements. More specifically, the Triman initiative has been considered an action that leads to the fragmentation of the Single Market; the EU Commission has called France to comply with its legal obligations deriving from the EU law. France has until 15th of April 2023 to respond to the concerns of the EU Commission.

The legislative process for drafts like the Packaging Regulation lasts around 18 months but there are steps that you can take to prepare. Please contact Accerio for more information and assistance preparing for the Packaging Regulation.

New E-Waste Rules in India

The Indian government announced new E-Waste Management Rules (E-Waste Rules) on November 2nd, 2022 that are set to enter into force on April 1st, 2023. The E-Waste Rules will replace the E-Waste Management Rules 2016. The legislation will apply to manufacturers, producers, refurbishers, dismantlers, and recyclers involved in any part of the product’s life. The scope has been greatly expanded from the 2016 E-Waste Rules to include solar photo-voltaic panels, certain IT equipment, additional consumer devices, tools and appliances, as well as medical devices.

Manufacturers and Producers shall comply with Extended Producer Responsibility obligations, which among others, are:

  • Registration through the new centralized portal
  • Fulfillment of annual EPR targets
  • Submitting annual and quarterly reports

The E-Waste Rules also allow for reductions in management quantity through purchasing refurbishing certificates. Additionally, there are important changes to the responsibilities of Bulk Consumers, reducing their obligations and shifting responsibilities to other parties in the supply chain. Contact Accerio for an assessment of your obligations under India’s new E-Waste Management Rules.

Belgium Draft Repairability and Durability Legislation

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In September 2022, the Belgium Ministry of Environment published a draft law together with three draft decrees on the subjects of Repairability and Durability score for electronic devices (as well as software compatibility). The draft law introduces a repairability index for electronic devices. The proposed standards are similar to those in France’s 2020 AGEC Law. Belgium’s proposed index is based on several criteria, such as the availability of technical information and maintenance manuals, the ease with which the product can be dismantled, the availability of spare parts and their delivery time, and the price of spare parts.

The new law will also be introducing a durability index as a possible way to supplement the repairability index. The draft decree provides the modalities of communication, format of the repairability index and accessibility to technical standards, a software compatibility obligation, as well as the products covered by the repairability score (some examples of the covered products are washing machines, smartphones, TVs, and laptops).

Public consultation on the drafts closed on the 22nd of March 2023. The drafts are now in the first reading phase at the Federal government level and a publishing date has yet to be announced. The drafts are scheduled to enter into force 6 months after its publication.

March 2023 Newsletter Read More »

March 2022 Newsletter

Newsletter: March 2022

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

France Labeling Obligations for Household Products

According to the French Anti-waste Law and the respective Decrees published on the 29th of June 2021, producers placing Household products obligated under EPR on the French market are required to mark their products with the Triman symbol and the accompanying harmonized sorting information, as approved by the French Authorities.

The products affected are:

  • Household WEEE
  • Portable Batteries and Accumulators
  • Household Photovoltaic Panels
  • Household Lamps
  • Household Packaging

On the 15th of December 2021, the French Authorities approved harmonized sorting and return information that will accompany the Triman logo for the first four product categories. After thorough consultations, the respective eco-organizations confirmed the finalized format and issued the labelling guidelines for producers in mid-January 2022. The packaging information was approved earlier in 2021, with a slightly different format than the other four product categories.

The Triman symbol and the sorting information became mandatory on all household products as of 2022, though there is an extended period for producers to bring products into compliance. Please contact us for more information on the new requirements.

Phase 6 of the UK WEEE DTS is Up and Running!

Under the UK WEEE Regulation, household WEEE distributors are obligated to provide a free of charge, one-for-one basis take-back option to private end-users. This requires the distributor to take any product back for recycling when a private end-user buys a product that fulfills the same function, regardless of the EEE brand or its original seller.

Distributors have two compliance options to fulfill this requirement:

  • Offer in-store take-back of WEEE on a one-for-one basis or
  • Join the Distributor Take-back Scheme (DTS)

DTS is an approved scheme by the UK government that has been running in two-year phases since 2007. The most recent phase (Phase 6) runs from the 1st of January 2022 through December 2023. Being a DTS member exempts distributors from the obligation to provide in-store one-for-one take-back. The DTS increases the rate of WEEE collection, reuse and recycling in the UK while making complying with take-back requirements feasible for foreign and online distributors. Accerio assesses clients for distributor obligations on an ongoing basis and makes recommendations on the best compliance options. Please contact us for more information on the DTS and compliance in the UK.

Marketplaces’ New Role in EU EPR Compliance

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Marketplaces are online platforms that enable businesses to offer their products for sale under their own name, risk, and liability, directly to end-users and resellers. The marketplace acts as an intermediary, providing a platform to bring sellers and buyers together to conclude sales contracts in which the marketplace itself is not party.

Unfortunately, online retail through marketplaces has been a common sales channel of non-compliant or ‘freeriding’ producers in the EU. Addressing this has been discussed in the EU for many years and is a stated priority in the preparation of the 2023 Waste Framework Directive. Though no official guidance has been published by the EU, a few member states have proactively defined the marketplaces’ role in the EPR compliance framework.

Beginning the 1st of January 2022, France AGEC law established that marketplaces hosting obligated products are required to comply with the French EPR legislation on behalf of the producers selling through the platform or ensure the producers themselves are compliant. In response to these requirements, most marketplaces require evidence or supporting documentation of the producer’s compliance for each applicable EPR waste stream as a condition to sell through the marketplace.

In Germany, the German Packaging Act, VerpackG, details a supervisory role for marketplaces over their vendors’ packaging compliance. Third parties who sell through an online marketplace are required to provide their EPR registration number to the marketplace. If the producer fails to provide this information, the marketplace is obligated to ban them from selling through their platform.

In both examples, marketplaces face significant fines if they fail to follow these requirements. Accerio is monitoring the development of EU-wide legislation and, in the meantime, similar measures that are expected to be adopted by other countries.

Draft of a Circular Economy Law for Mexico

The Mexican Senate approved the Circular Economy General Law draft on 18 November 2021, now under review of the Environment and Natural Resources Commission of the Chamber of Deputies. The law would promote the efficient use of products, services, materials, energy, water, and secondary raw materials, by means of clean manufacturing and principles of reuse, recycling, and redesign. Mainly, the purpose is to transition from a linear to a circular economy in Mexico.

If approved, the Law will create the following obligations for EEE and packaging producers:

  • Packaging producers must prepare and file a Circular Economy Plan and EEE producers must have a Waste Plan in place with the Ministry of Environment and Natural Resources (“SEMARNAT” for its acronym in Spanish).
  • Producers will need to meet consumer communication requirements as well as collection, recovery, and valorization rates that will be set in the secondary legislation.
  • Producers must also consider minimum recycled plastic content goals for packaging, starting with 20% by 2025 and 30% by 2030.

Accerio will monitor the progression of the law and reach out to clients who are likely to be impacted by the requirements. The draft details significant sanctions for infractions to the law, so we encourage producers to contact us for more information.

March 2022 Newsletter Read More »

February 2021 Newsletter

Newsletter: February 2021

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

EU Batteries Regulation Proposal

The EU Commission has made a proposal to repeal the current Batteries Directive 2006/66/ED and amend Regulation (EU) No 2019/1020. The proposed changes aim to harmonize the batteries waste compliance requirements among EU Member States and to standardize the registration procedure for producers and other actors in the supply chain.

There is an opportunity for public comment available to Producers and interested parties until March 1st, 2021, via this link. For Producers and Manufacturers of batteries, this is an important opportunity to have your voice heard about the proposed changes.
Important key proposed changes include:

  • Definition changes for the key terms “Producer”, ‘’Distributors’’, “Placing on the Market”, and “Making available on the Market”.
  • Battery manufacturers “not established in an EU Member State” will be required to appoint an Authorized Representative.
  • Electric vehicle batteries will be brought into scope as a fourth battery type.
  • Increased transparency of supply chain by establishing and operating a system of control and traceability.
  • A focus on increased collection of portable batteries, including increasing the collection target over time (65% by 2025, and 70% by 2030).
  • New information, labelling, sustainability, and safety requirements, including for example, a QR code to be placed on batteries.
  • The introduction of recycling efficiencies and recovery targets, with a schedule to increase over time, for specific raw materials, including lithium, lead, cobalt, copper, and nickel.
  • Extended producer responsibility (EPR) for industrial batteries.
  • Portable battery definition to include also batteries used in light vehicle (such as scooters and electric bikes) with a maximum weight threshold of 5 Kg.
  • Setting out in detail the model structure for the EU Declaration of Conformity.
  • Distributors of batteries will carry responsibilities to ensure Manufacturers, AR’s, Importers, and other distributors are appropriately registered to sell, and that the batteries are properly compliant with CE Mark, DoC and other requirements, including applicable documentation.

The 2020 European Green Deal’s New Circular Economy Action Plan has identified batteries as a category of products that are a high use of resources, but also great potential for recycling and circularity. The market demand for batteries is expected to dramatically increase over the next decade, especially for lithium batteries. The proposed changes are deemed necessary to address the urgent need for increased battery production, and investment and capacity expansion for recycling and handling capability.

 

 

French Repairability Index

France is the first EU country to implement a key element of the EU Circular Economy Package with the introduction of a Repairability Index for a selection of EEE products. This index is in force as of the 1st of January 2021. Products in scope will need to list the Repairability Index on the product packaging, on a label or online using a specific logo and color.

To begin with, products required to comply are the following:

  • Washing machines
  • TVs
  • Computers and Laptops
  • Mobile phones
  • Corded lawnmowers
  • Battery operated lawnmowers
  • Robotic lawnmowers

Producers or importers will be responsible for calculating and communicating the Index to all parties in the supply chain, and sellers both online and with a physical store must present the Index “in a visible manner on each product offered for sale/in the presentation of the equipment and close to its price”.

The Reparability Index is represented by a grade between 1 and 10, with calculations based on five specific criteria, to inform end-users about the “possibility to repair a product”.

The criteria are:

  1. Availability of the technical documentation, for use, maintenance, and repair
  2. Ease of disassembly, access, and removal of worn parts
  3. Availability of and access to spare parts
  4. Price of spare parts, especially relative to the cost of the item itself
  5. Product specific criteria such as accessibility to remote assistance for repair and possibility of a software reset.

The system will certainly evolve over time to include other requirements and quite likely an expanded product list, and in the early stages there are no sanctions for non-compliance. There are increased specifications planned; from 2022 manufacturers and importers will be required to provide essential spare parts, and in 2023 extended producer responsibility for financing the repair of products is expected. The Repairability Index will influence product design and purchasing habits, and other countries will soon follow suit.
If your products are in scope with the new legislation in France, please contact Accerio for additional information.

German Battery Changes

There are some new procedures for the management of end-of-life batteries in Germany, following changes to the German Battery law.

The Stiftung EAR has now taken over the role as the responsible organization for battery registrations from the UBA. There is a grace period until 01.01.2022 for transfer of current registrations, provided that the battery information at the UBA was up to date at year-end 2020. If your German battery registration is managed by Accerio, we have ensured all details were up to date by the end of 2020.

Main changes to the system include:

  • The collection target for portable batteries increased from 45 to 50%.
  • Collection systems for portable batteries will require approval by the Stiftung EAR.
  • Fees for portable batteries will be structured to provide an incentive to Producers to minimize the use of hazardous substances.
  • From now on firms that do not have a local German entity can appoint an authorized representative. However it is important to note that this is not a mandatory requirement.

The information requirements for producers to provide to customers have become more extensive. End users of batteries will need to be informed about measures to reduce waste and pollution of the environment from spent batteries, the options they have to prepare batteries for re-use, and the potential risks associated with lithium batteries.

Producers of industrial and automotive batteries need to publish the recycling rates they achieved last year on their website before the 31st of May. Furthermore, the German Environment Agency has now the right to request take-back documentation approved by an independent auditor/expert.

If you have any questions about your Producer obligations for batteries in Germany, please contact Accerio for support.

New EPR Legislation in South Africa

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South Africa will begin enforcement of a comprehensive Extended Producer Responsibility law for electronic waste, packaging, and batteries on May 1, 2021, although existing producers will be granted six additional months to move into compliance. After this point, EPR schemes will be regulated and subject to approval by the Environmental Department. Critically, the law stipulates that both foreign and domestic entities will be obligated as producers.

Additional facets of the law include:

  • Participation in a Product Responsibility Organization (PRO) or individual compliance, a change from the previous voluntary system.
  • Scope of EEE categorized under three classes of products: large, medium, and small equipment.
  • Obligations for integrated batteries.
  • Registration with the national authority for most consumer products in the above categories
  • Mandatory take-back and labeling
  • Reporting concerning the above actions and the amounts of product placed on the market.
  • Separate provisions for lighting products, with specific collection criteria and product scope; carrying different requirements than most EEE.

With respect to packaging obligations, the new law introduces EPR for all packaging types and materials, as well as for certain single-use products, following the EU Packaging Directive’s scope.

In terms of WEEE, violations of the Law can be punished by imprisonment, significant fines, or both. Doubtless the de facto requirements of the law will shift with its implementation and subsequent legislation which can be expected in November of 2021.

February 2021 Newsletter Read More »

November 2020 Newsletter

Newsletter: November 2020

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

Singapore Packaging Update

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The next phase of Singapore’s new suite of Extended Producer Responsibility Waste laws, incorporating Packaging, is ready to roll out in Q1 2021.

The spirit of intention of this legislation is to drive a reduction of packaging waste in Singapore, with a focus on packaging reduction and re-use, recycled content, and increased recyclability of packaging.
Actors who meet the definition of packaging producer in Singapore, include local entities who are importing regulated goods and packaging into Singapore.

Packaging Producers will be required to collect packaging data starting from January 1 2021 in order to be prepared for packaging reporting by the end of the year. The reporting required involves submission of plans that indicate initiatives to reduce packaging pollution, including specific targets and performance indicators and reviews of progress.

The Singapore Resource Sustainability Act focuses on definitions of exclusion, and most regulated goods and specified packaging are in scope, unless they meet any of the exclusion criteria. The list of regulated goods is available, and Accerio can help to determine if your products meet the definitions.

Penalties for non-compliance are not insignificant and include financial penalties with steep daily fines in some cases and imprisonment for persistent non-compliance and subsequent convictions.

If your company is importing regulated goods and packaging into Singapore, or if you unsure if your products fall into the definitions of regulated goods, please reach out to Accerio for assistance to register and be compliant with the Singaporean law.

EU Tax on Non-Recyclable Plastic

January 1, 2021 the EU non-recyclable plastics tax will come into effect. The tax is part of a Coronavirus recovery package. The €0.80 per Kg tax will be levied on EU Member state governments and will be calculated on the reported weight of non-recyclable plastic placed on the market in each country. Lesser economically developed countries will be granted exemptions.

Because it is individual EU Member States and not the non-recyclable plastics Producers themselves who are covered by this tax, it leaves a great amount of discretion for how this cost could be passed on to Producers, or not, as they see fit. Specific details are not yet available about which products the tax will apply to, or what exemptions may exist.

Because EU Member states will receive tax incentives from the EU Commission for higher rates of recycling, it is reasonable to expect that they will enact punitive economic instruments and policies targeting Producers who place unrecyclable plastics on the EU market. Whilst we cannot yet tell what the costs will be to Producers, what we can expect is enhanced scrutiny of plastics reporting by Producers, and almost certainly some kind of increase in fees and costs for Producers affected.

Regardless of the specific outcome of this tax, the trend is clear. There is a consistent push towards more recyclable packaging, and less of it, with taxes and laws coming into force in the next 12+ months in many European Member States. In anticipation of fee increases from this tax and other similar policies there is a window of opportunity now for Packaging Producers to analyze packaging used and work with supply chains to identify unrecycled plastics in use and possible recyclable alternatives, as well as potential to reduce the amount of packaging used.

Ontario 2021 WEEE Law Relaunch

On January 1, 2021 the new Ontario Electronic Waste law (The Electrical and Electronic Equipment (EEE) Regulation under the Resource Recovery and Circular Economy Act, 2016, O. Reg. 522/20: Electrical and Electronic Equipment) comes into force, obligating an expanded range of Electrical and Electronic Equipment. Products covered by the law include Telecommunications, Audio visual, and IT products, with spare parts and cables now included as well.

It is important to note that rechargeable batteries sold integrated in products were previously exempted, however all chemistries of integrated batteries will now carry obligations under the new E-Waste law. All standalone batteries, of all chemistries weighing < 5Kg are covered by Ontario’s new Battery law that commenced on July 1 2020 and was covered in our last newsletter.

The registration deadline with the Ontario authority was originally set for November 30, 2020, which didn’t permit much time to prepare, so this has been extended now until January 31, 2021. Registration requires submission of sales data from 2018 and 2019 in order to determine obligation thresholds, so Producers who have been selling Electrical and Electronic Goods, products with integrated batteries, or stand-alone or replacement batteries from that time frame should please contact Accerio as a matter of high priority for assistance in preparing reporting data in time for your registration application.

Please note that for Accerio clients who are currently already registered and complying through the collective EPRA will also need to register with the Authority (RPRA) but can continue complying through a collective organization, and your Account Manager will contact you to process this adjustment.

Year-End Reporting Preparation

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2021 is almost upon us, and with it comes the end-of-year WEEE, Batteries, and Packaging reporting. All Producers selling these types of goods anywhere in the EU will be required to report, which makes for a lot of very tight deadlines at a busy time of the year.

As a reminder, here are a few tips to make the process as streamlined as possible; please let us know here at Accerio if:

    • There have been any product changes that you may not have advised us of yet. Please send us SKU numbers, weights and technical specifications.
    • There are new reporting staff and or change of email addresses. Please update our information so we can be sure to be in communication with the right people.
    • There has been any takeback or recycling done by yourselves or any third parties, please send us the data and information. We may need a report directly from the recycling facility on how the take-back was recycled, so please ensure you know who to contact to obtain these reports.

It’s also a good idea to touch base with Authorized Signatories in your organization to remind them that some annual reports will require their signature, given it is an extra demand on them at a busy time of the year.
If you would like us to check through your data before the end of year to ensure that January is as stress free as possible, please feel free to contact your account manager.

November 2020 Newsletter Read More »

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