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September 2025 Newsletter

Newsletter: September 2025

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

EU Battery Regulation: Updates for Producers

Two miniature workers with yellow alkaline batteries

The EU Battery Regulation came into effect in August 2023 and applied directly in all EU member states after a period of 6 months. Now, a year after the application, producers and Member States have implemented several key deadlines. 18 August 2025 marked the official repeal date of the previous legislation, the EU Battery Directive. Also on this date, two high impact requirements of the EU Battery Regulation Extended Producer Responsibility (EPR) began: the new battery categorization and the requirement for all distance selling producers to appoint an Authorized Representative (AR) in each Member State where they do not have a local entity.

  1. EWRN Published EU Battery Categories Battery Guidance
    The European WEEE Registers Network (EWRN) recently published guidance that combines understanding from regulation definitions, recitals, and other articles to aid battery producers in categorizing under the five categories set out by the EU Battery Regulation (Regulation 2023/1542). The guidance correlates the new five categories with the three battery categories from the EU Battery Directive and provides examples of batteries falling into each category. The resource also proposes a definition interpretation of batteries “specifically designed for industrial uses”. Producers can use this resource while reviewing their battery types. The EWRN Guidance can be viewed here.
  2. EU Council Adopted Law to Delay Due Diligence and Exemptions
    The EU Council approved to delay the battery due diligence obligations by 2 years. This requirement is detailed in Chapter VII “Obligations of economic operators as regards battery due diligence policies” of the EU Battery Regulation. This postponement falls in line with the delay of due diligence for the Corporate Sustainability Due Diligence Directive (CSDDD).
    Battery due diligence is the responsibility of companies in the battery supply chain to manage social and environmental risks linked to raw and secondary materials used in production. It involves risk management systems, third-party checks, oversight, and transparency to ensure risks are identified, prevented, and addressed across suppliers, subsidiaries, and subcontractors.
    An additional proposal has been put forth by the European Commission to extend exemptions of small and medium sized enterprises (SMEs, companies under €40 Million in Revenue) to small mid-cap enterprises (SMCs, companies under €150 Million in Revenue) to alleviate unnecessary administrative burden.

Please reach out to Accerio if your company would like assessment and monitoring of battery obligations in the EU.

Washington and Maryland Pass EPR Packaging Laws

Maryland (SB901C) and Washington (SB5284C) became the 6th and 7th U.S. states to pass packaging EPR laws, signed into law in May 2025. Both require producers to register with a Producer Responsibility Organization (PRO) by July 1, 2026.

Covered materials include all types of packaging and paper products, including beverage containers, sold or distributed to consumers in MD and WA, respectively. In both states, implementation will be gradual through 2029, starting with needs assessments and PRO planning. While exact recycling or reuse targets are not yet defined, materials not covered under approved stewardship plans may be restricted from sale after 2032.

Producers selling into these states should begin assessing their packaging materials and market activities to determine applicability and plan for compliance. As the programs evolve, Accerio will provide further updates and assist clients with registration and data preparation.

Spain’s Draft EPR Decree for Textiles

On 23 June 2025, Spain released the draft Royal Decree establishing Extended Producer Responsibility (EPR) for textiles, including clothing, footwear, and fashion accessories, as required by Law 7/2022 on waste and circular economy.

The proposal obligates all “Producers” (including manufacturers, importers, own-brand distributors, and distance sellers) to register in a dedicated section of the Product Producers Registry (Registro de Productores de Producto), declare the volumes placed on the Spanish market annually, and fulfil their obligations exclusively through collective compliance with a producer responsibility organization (SCRAPs). Online platforms and logistics providers would also be required to check that only registered producers operate in the market.

The scope of the regulation will apply to clothing, footwear, and fashion accessories for household use (or other use, for products with similar nature) listed in Annex I of the draft. Producers will finance the system through fees paid to SCRAPs that will be calculated on product weight, or in some cases, by number of units. These fees will be subject to eco-modulation criteria in line with the EU Ecodesign for Sustainable Products Regulation (ESPR), considering design features such as durability, recyclability, and use of recycled content.

Retailers are directly impacted, as they may only sell products from duly registered producers. Those with a sales area greater than 400 m² must also dedicate part of their store to second-hand or “prepared for reuse” textile and footwear products. Where retailers place in-scope products on the market under their own brand or import them directly, they will themselves be considered producers and required to register and join a SCRAP.

SCRAPs will be responsible for meeting national collection and reuse objectives: 50% separate collection by 2030 (70% by 2035), with at least 20% prepared for reuse by 2030 (35% by 2035). They will also be required to publish annual data on volumes placed, collected, and managed, ensuring transparency in how targets are achieved.

The draft is currently open for public consultation and, once adopted, Spain would join a handful of EU countries with nationwide EPR systems for textiles.

September 2025 Newsletter Read More »

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.

More:

 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 »

May 2024 Newsletter

Newsletter: May 2024

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

May 2024: Special Edition Newsletter

Upcoming USA Registration Action for Packaging Producers

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.

More:

 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

Packaging Extended Producer Responsibility (EPR) by individual US states has become a rapidly evolving topic, with several states actively implementing or considering legislation. While many states already have other active EPR legislation, including for e-waste, batteries, mattresses, and paint, packaging EPR has become a prominent focus area.

Maine and Oregon passed packaging EPR laws, followed closely by California and Colorado. In 2024, Minnesota passed HF 3911, which details a Packaging EPR program, bringing the total to five US states with packaging EPR. Maryland and Illinois also passed packaging laws requiring a needs assessment of their recycling systems, setting the stage for potential future EPR implementation.

For the 2024 legislative session, seven states—Massachusetts, New Jersey, New York, New Hampshire, Rhode Island, Tennessee, and Washington—have packaging EPR bills under consideration. Circular Action Alliance (CAA) has emerged as a key player in EPR implementation, serving as the Producer Responsibility Organization (PRO) in California, Colorado, and Oregon. CAA’s involvement extends to Maryland, where it represents producers’ interests on the advisory board as they move forward with a needs assessment. Looking ahead, Maine is slated to begin the PRO selection process in 2025, with a selection expected by 2026.

For those states with active regulations, obligations exist for entities involved in the production, distribution, or importation of products using covered packaging materials. These producers must register in each applicable state, join a PRO by specified deadlines, or manage individual programs, ensuring compliance with recycling and packaging standards set by respective states.

Covered materials subject to regulation vary by state but typically include food service ware, paper products, and various packaging materials. The earliest compliance deadline for producers is set for 2025, with preliminary PRO registration requested by July 1, 2024, to aid in program fee development. Accerio is assisting our clients in registering with CAA and preparing for state requirements. Producers are advised to start collecting packaging data promptly to meet reporting requirements by 2025.

For producers uncertain about their obligations in California, Colorado, Oregon, Maine, and Minnesota, Accerio can provide preliminary assessments and ongoing support as producer requirements are evolving through final rulemaking processes. With EPR laws gaining traction across the US, proactive engagement and preparation are essential for producers to navigate this evolving regulatory landscape effectively.

May 2024 Newsletter Read More »

December 2021 Newsletter

Newsletter: December 2021

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

Current & Upcoming USA Packaging Laws

2021 was a very active year for the development of EPR packaging laws across the United States. Maine became the first state to pass an EPR packaging law in July of 2021. Maine is now entering a two-year rule making process to establish the program itself. The law obligates both local and foreign brand owners, and importers who are importing on behalf of foreign brand owners. Obligated companies who do not qualify for the small producer exemption will be required to either implement a takeback and recycling program or join the Packaging Stewardship Program once it is approved by the State for all obligated packaging materials.

Just one month later, Oregon passed the Plastic Pollution and Recycling Modernization Act in August 2021. Oregon’s law comes into force in July 2025, obligating local and foreign brand owners, licensees of brands, and importers who import on behalf of foreign brand owners. Oregon’s scope of obligated materials and small producer exemptions are similar to Maine’s; however, Oregon has a more aggressive timeline for implementation and higher fines for non-compliance.

Currently there are 10 other states with draft EPR packaging legislation, mostly under review by state legislators. We encourage all producers selling to US states to reach out to Accerio for state-level assessments of current WEEE, battery, and packaging obligations.

Draft Packaging Law in Spain

To update their 20-year-old packaging waste regime, Spain has introduced a draft Royal Decree on Packaging and Packaging Waste. If implemented, the Royal Decree will repeal the existing legislation, replacing it with requirements in line with EU Directive 2018/52 of 30 May 2018, which modified Directive 94/62/CE on packaging and packaging waste to incorporate principles of circular economy and reuse of packaging. Additionally, the Decree will apply the content of EU Directive 2019/904 of 5 June 2019 (SUP Directive) on single use plastic packaging and the reduction on the impact of these products in the environment. The new regime will establish an EPR program for all packaging materials & sectors, as well as a deposit, refund, and return system for all packaging and packaging waste.

For obligated producers, compliance can be direct with the national authority or through a collective organization. The fee structure under collective compliance includes eco-modulations following circular economy criteria, including penalties for materials that do not meet the efficiency criteria.

The public consultation period ran through October 2021, followed by introduction of the draft to Spanish Parliament for discussion and approval. Please contact us for more information on compliance options and the provisions of the draft Decree. Accerio will contact impacted clients once the Decree is approved.

New Waste Act in Finland

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Beginning in July of 2021, the obligated producer definition expanded in Finland’s new Waste Act to all foreign producers, including foreign producers and distance sellers of batteries and packaging. Before the reform, foreign producers were only obligated under the WEEE legislation. Additionally, Foreign producers can now voluntarily take over the EPR obligations of their Finnish resellers and distributors.

The Act also includes stricter provisions on products themselves, with requirements for safety, quality, and sustainability during the manufacturing process. For example, the producer must ensure that products do not have excessive or unnecessary packaging. And considerations must be taken during the design phase, such as ensuring that EEE containing integrated batteries/accumulators can be easily removed, to encourage a longer lifespan for devices.

If your company is selling into Finland, please contact us to begin an assessment and the registration process. The first deadline for producer registrations is rapidly approaching at the end of 2021.

December 2021 Newsletter Read More »

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