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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 »

August 2020 Newsletter

Newsletter: August 2020

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

Ontario's New Battery Law

Ontario battery recycling

The Province of Ontario in Canada has a new battery law that came into force on July 1 2020 as part of the Resource Recovery and Circular Economy Act: Ontario Regulation 30/20. Battery producers who place any sold-separately battery that weighs less than 5 Kg on the Ontario market are defined as obligated “Stewards”. Both single-use and rechargeable batteries are obligated. Stewards will be considered individually accountable and financially responsible for the resource recovery (reuse, refurbishment, or processing) of those end-of-life batteries that fall within the scope of obligated batteries.

The definition of a battery steward encompasses a variety of scenarios, but it does capture most sellers, with variables such as which party is the brand holder, their residency status in Ontario and Canada, and to whom the battery is sold. Some exemptions apply for specific scenarios.

Integrated batteries, meaning batteries that are sold already inside a product, are exempted from this law. However, a new electronic waste law is in the pipeline for Ontario and due to come into force early 2021. This is expected to encompass integrated batteries.

Requirements for compliance include free collection networks for consumers, the need for promotional and education materials until the end of 2022 to increase consumer awareness, and most producers will be likely to need to source services from a Producer Responsibility Organization to meet the legal obligations.

If your company sells portable batteries weighing less than 5 Kg on the Ontario market, or in any Canadian province, please contact Accerio for more details about your potential obligations.

UK Plastic Packaging Tax

From April 2022, the UK government will impose a £200 per tonne tax on plastic packaging that contains less than 30% recycled plastic. Plastic packaging is defined as packaging materials where plastic is the predominant material. The tax is designed to grow the recycled plastics market to meet increased demand and divert more waste from landfill. Most of the provisions have been finalized, however a few details are yet to be confirmed, including whether or not to exempt transit packaging intended only to protect products during transport.

This tax will apply to:

  • Large Producers: who place more than 10,000 Kg of plastic packaging on the UK market annually
  • UK Packaging Producers
  • UK Packaging Importers, if the packaging is produced outside of the UK
  • All packaging, regardless whether it is empty or filled, to all end users

This tax will not apply to:

  • Small producers: who place less than 10, 000 Kg of plastic packaging on the UK market annually
  • Foreign distance sellers (see above, the UK importer will carry obligation)

Quarterly reporting on packaging will be mandatory, with declarations required of all weights of packaging placed on the market (POM).  The tax applying to packaging in scope will be administered through Her Majesty’s Revenue and Customs (HMRC) Department, and unless packaging is declared – with evidence – to contain at least 30% recycled material, the tax will apply to the total weight POM.

April 2022 will be here before we know it, so it is advisable to look now at supply chains to determine the % recycled content of plastic packaging used, and if proof of the recycled content exists in the form of certification or specification sheets.

New Eco-Design Regulations

Eco Design repair screen

The new EU Eco-design regulations, adopted as part of the Circular Economy package’s Eco-Design Working Plan, are coming into force in 2021, with the objective of increasing the repair, reuse, and recyclability of the products targeted. The 10 regulations apply to all products in scope that are placed on the EU Market regardless of their country of manufacture.  The product categories targeted are:

  1. Household Refrigerators
  2. Refrigerators with a direct sales function (e.g. fridges in supermarkets, vending machines)
  3. Washing Machines
  4. Dishwashers
  5. Welding Equipment
  1. Electronic Displays (including most computer monitors and televisions)
  2. Light Sources and Separate Control Gears
  3. External Power Supplies
  4. Electric Motors
  5. Power Transformers

The Eco-Design Regulations have a direct application, with no need for transposition into local legislation. The 2021 deadlines vary, the first being March for electronic displays, April for external power supplies, July for electric motors and power transformers, September for light sources.

The new requirements are focusing on lower limits for the Energy Efficiency Index and are bringing new material efficiency specifications. The Regulations are strengthening the concepts of products designed for repair and reuse, and design for dismantling, recycling and recovering, in accordant with the Waste Hierarchy. More, specific information will have to be made available in the technical documentation and on the producer website, together with specific labelling requirements, especially for some plastic components.

For Producers it may impact on production strategies and costs, with the decision to be made whether to manufacture compliant product lines specifically to be sold in Europe or to make products bound for all geographies in line with these regulations.

If you are interested in more information regarding Eco-Design Regulations, please contact Accerio for an introduction to the new requirements.

The Impact of POPs

POPs Old monitor

From July 15, 2020 the recast EU Regulation on Persistent Organic Pollutants (POPs) came into force, repealing the previous POP’s Regulation. POPs are problematic for all biological life, and legacy Electronic and Electrical Equipment (EEE) containing these materials will now face increased treatment requirements, driving up WEEE treatment costs across Europe.

The new regulation aligns more closely with the REACH regulation and the Waste Framework Directive, with greater clarification of definitions to ensure unity across the EU. The list of POP chemicals included has been expanded, applying restrictions on the use of specific substances in manufactured products, as well as more detail of end-of -life treatment methods that must be used for certain products containing chemicals.

These chemicals are not as plentiful in current manufacturing as they once were but, they are still being collected in older WEEE processed. For example, many household electrical items, such as televisions and computer monitors, used to be manufactured using brominated flame retardants to reduce their risk of catching fire if overheating. These old items can no longer be recycled with other WEEE and must now be subject to thermal treatment at a hazardous waste plant.

As yet it is not clear how or when collective organizations and authorities will pass on the costs, or if they will instead absorb them, but it is probable that the increased handling overheads will translate into increase fees for Producers across the EU.

August 2020 Newsletter Read More »

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