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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 »

September 2022 Newsletter

Newsletter: September 2022

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

California Packaging and Battery EPR Laws

California

Several advances have been made to introduce EPR legislation in California over the course of 2022. This summer, Senate Bill 54 was passed to create an EPR packaging program. The law aims to reduce and eliminate single-use packaging, increase compostable packaging on the market, and move towards increasing recyclability of packaging. In-scope products include single-use packaging and plastic single-use food service ware imported or sold in California, which must be recyclable or compostable by 2032. To comply, producers can either form or join a Producer Responsibility Organization (PRO) by 2024.

Two California battery laws passed as well. The first law, the Responsible Battery Recycling Act of 2022 (AB 2440), introduces EPR on easily removable batteries and will replace the current Rechargeable Battery Recycling Act of 2006, repealing the old law starting January 1, 2027. Obligated producers must join a stewardship program for the collection and recycling of covered batteries. The second law, SB 1215, expands the definition of covered devices in the Electronic Waste Recycling Act of 2003 to include battery-embedded products. Starting January 1, 2026, retailers are responsible for charging the California consumer a visible fee for each product purchased with batteries that cannot be easily removed.

Please contact Accerio for more information if your company is currently selling or plans to sell products in California.

New India EPR Rules and Draft Rules

The India Ministry of Environment, Forest and Climate Change has made recent changes to extended producer responsibility (EPR) regulations. The Ministry issued new rules for battery and packaging, and is working on the draft for WEEE management. 

Most recently issued are the Battery Waste Management Rules, 2022 that replace the Batteries Management and Handling rules from 2001. Local producers and importers of batteries will be responsible for collection and recycling or refurbishment of waste batteries. The updates also include an improved system for producers to report on their obligations via an online EPR portal.  Obligated producers can comply through a collective organization or through an individual system. 

In February of 2022, the Plastic Waste Management Rules, 2016 were amended to include details on plastic packaging EPR. The rules obligate producers, importers, brand owners and plastic waste processors to follow EPR requirements for four categories of plastic packaging.

There are also proposed changes to the E-Waste Management Rules, 2016. Most impactful would be the expansion of product scope to include additional categories of IT and household electronics. Please reach out to Accerio if your company imports product into India and would like an assessment of obligations.

Implementation of the EU Packaging Levy

European_Commission

The EU Packaging Levy was published in 2020 to support the goals of the EU Green Deal and the Recovery plan for Europe (also known as Europe’s Covid-19 recovery package). EU Member States must contribute €0.80 for each kg of plastic packaging waste that is not recycled at end of life (based on average Eurostat data in respective base years).

Each Member State can either cover these costs via their national budget or pass them through to the respective industry streams by:

  • Introducing a new Plastic Packaging Taxation on non-recycled plastics
  • Integrating them into existing packaging-related taxes or fees, such as EPR fees
  • Introducing other fiscal measures such as reduced subsidies or tax and fee exemptions

Some Member States have already introduced a new plastic tax (such as Spain and Italy) and more are expected to follow suit. As this taxation is focusing on non-recycled content so far, the demand for recycled plastic is expected to rise significantly.

Spain Packaging and Packaging Waste Law

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The Ministry for the Ecological Transition and the Demographic Challenge has proposed a new Packaging and Packaging Waste Law to replace Law 11/1997 of 24 April 1997. The draft law would incorporate the EU Packaging Directive and the EU SUP Directive into the Spanish legal framework.

Key proposed changes are:

  • Expanded scope of EPR regulations to include household, commercial and industrial packaging
  • An obligation for producers to register in a new Packaging National Register and be responsible for the environmentally sound management of the packaging they place in the Spanish market. All foreign producers are obligated to appoint an AR
  • Obligations for online marketplaces to bear responsibility as a subsidiary producer, for products placed on the Spanish market via their platform in the case that the foreign producer has not registered
  • Options for producers to comply collectively or individually, with additional obligations for large producers to set up and apply a prevention and eco-design business plan

This law is currently in a revision phase. The EU Commission has issued their Expert Opinion urging the Spanish Government to reconsider some of the dispositions in the draft that have been considered by the Commission as creating obstacles to the free movement of goods, or the provision of services, as well as possible cases of non-conformity with Union Law. Consequently, the publication of the Law is suspended until November 7, 2022 and is subject to informing the Commission of the measures it intends to take in response to the opinion. Accerio will update our clients once the law is published with next steps.

September 2022 Newsletter Read More »

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