Global EPR: Mitigating future risk with Ecoveritas

Ensuring compliance in today’s world can feel like a game of chance. 

Not only do businesses have to meet their obligations under a tangled web of regulations that can vary wildly between countries, states, and local authorities,  but they have to make decisions with one eye on the future, as that web grows more complex every year. 

Many different international compliance programmes exist placing different obligations on producers, and those schemes are all changing and maturing at different rates around the world. Even in a country as relatively small as the UK, the devolved governments enforce different rules in England than they do across the border in Scotland. 

It means our offer of compliance services for programmes worldwide, complete with systematic examinations of globally available packaging and environmental legislation information to identify potential threats, risks, emerging issues, and opportunities for our clients is more sought after than ever. Simply put, we take the guesswork out of compliance and put the power of data in your hands. 

From analysing the future, considering how emerging trends and developments – both in legislation and markets – might potentially affect business processes and performance to working directly with brands across the globe to quickly assess their obligations by country and provide an efficient, cost-effective, outsourced solution to registration and reporting needs. From managing scheme registrations and memberships to paying compliance scheme fees, Ecoveritas simplifies the entire administration process to simplify your life! 

So, as the focus righty turns to what the new year may bring, who better to ask than Ecoveritas’ Global EPR team to talk us through the changes you need to know about. 


Country  Policy name  Enforcement  Summary 
Austria  The Amendment to the Waste Management Act 2002 (refillable quotas)  01-Jan-2024 (applicable to reusable containers)  Retailers that sell beverages will be obligated to ensure that a certain percentage of different kinds of beverages they sell are sold on reusable containers.  
Belgium  Royal Decree to limit the placing on the market of single-use products harmful to the environment and to increase the recycled content of certain products  01-Jan-2024  From January 1st, 2024, the following is prohibited: any single-use plastic container intended to distribute food or drink for immediate consumption on the spot or taken-away, non-compostable labels for fruit/vegetables, single-use plastic packaging used for unprocessed fresh fruit/vegetables, shrinkable sleeves/materials made of plastic film, plastic rolling containers for waste, plastic nursery pots and trays, urban furniture with plastic parts, plastic confetti, glitter, plastic sticks, plastic skewers, plastic coffee, tea/herbal bags, single-use coffee capsules containing plastic and aluminium, cutlery and plates, laminated advertising cards, advertising or non-addressed printed matter with packaging containing plastic, single-use cups made of cardboard with a plastic coating and packaging containing PFAS. 
Belgium  Decree of the Flemish Government amending the BVR containing general and sectoral provisions regarding environmental hygiene  01-Jan-2024  The use of plastic compost barrels and compost bins that are not produced on the basis of recycled plastics is prohibited from the 1st of January 2024. The minimum content of recycled plastic is set at 1° 80% from the 1st of January 2024, and of this percentage at least 75% must consist of post-consumer plastics.  

The use of plastic roll containers for waste that is not produced on the basis of recycled plastics is prohibited from the 1st of January 2024. The minimum content of recycled plastics is set at: 1° 50% from 1 January 2024, of which at least half consists of postconsumer plastics.  

The use of plastic cultivation pots, cultivation trays and plant trays used for flowers and plants (not those produced on the basis of recycled plastics) are prohibited from the 1st of January 2024. The minimum content of recycled plastics is set at: 1° 80% from the 1st of January 2024, consisting entirely of post-consumer plastics.  

The use of furniture with plastic parts in public outdoor areas, where plastic parts are not produced on the basis of recycled plastics is prohibited from the 1st of January 2024. 

Denmark  Order on Registration and Reporting of Packaging  01-Jan-2024  From the 1st of January 2024, Danish producers will need to maintain a digital producer register of manufacturers who market packaging and representatives of producers.  
Finland  Regulation on Packaging and Packaging Waste 1096/2022 pursuant to the Waste Act – 646/2011-SECTION 48 – Producer Responsibility  01-Jan-2024 (for producer responsibility of single-use plastic products and beverage cups)   From this date, producers of single-use plastic products (including drinking beverage cups sold empty to end-users and their caps and lids which are considered to have been produced by the manufacturer or importer will be responsible for the single-use plastic products and beverages. 
France  Environmental Code Book V, Title IV, Chapter I, Section 9 (Environmental Labelling Requirements, Decree 2022-748)  01-Jan-2024 (this enforcement date is applicable to the listed obligations)  1.) It is prohibited to label packaging as ‘biodegradable’ or ‘environmentally friendly.’ 2.) Producers must provide information on various characteristics of a product such as its recyclability (including household packaging, batteries etc), and the presence of precious metals. 3.) There are specific requirements on how these categories are defined and producers must make available these qualities, any characteristics and additional information on penalties and premiums from eco-modulation. 4.) This obligation will apply from the 01-Jan-2024 for companies that have an annual turnover of more than 20 million euros and are liable for the placing on the market of at least 10,000 units of obligated packaging. 
France  Circular Economy Law – no. 2020-105 Amendment to Environment Code (sanitary textiles)  01-Jan-2024  From the 1st of January 2024 this law will provide for the creation of a polluter-pays sector for sanitary waste that includes household wipes, make-up removers, baby wipes, disposable nappies, and tampons.  
Germany  Packaging Act (VerpackG) (Expansion of the Deposit Obligation)  01-Jan-2024  From the 1st of January 2024, milk, mixed milk beverages and all drinkable milk products offered in one-way plastic beverage bottles with a filling volume of 0.1 to 3.0 litres will carry the DPG deposit logo. The Packaging Act has stipulated a deadline-related regulation for the expansion of the deposit obligation as of the 1st of January 2024. 
Germany  Single-Use Plastics Fund Act  01-Jan-2024  This levy is set to come into force from the 01-Jan-2024 for manufacturers of certain single-use plastic products: food containers, bags and foil packaging, beverage containers (up to 3 litres), beverage cups (with caps and lids), lightweight plastic carrier bags, wet wipes, balloons (excluding those for professional and industrial use, and tobacco products. This will be determined by statutory decree according to standards laid down by law.  
Hungary   Government Decree on the detailed rules for the establishment and application of deposit fees and the marketing of products with a deposit fee (DRS)  01-Jan-2024 (there are various sections that will come into force)  This law requires non-reusable products with a mandatory deposit fee are subject to the payment of HUF 50 per item. To place a product with a mandatory deposit fee on the market after 1 January 2024, the producer shall initiate the registration of the product until 15 November 2023. 
The Netherlands  Decree of 6 March 2020 to amend the Packaging Management Decree 2014 (Single-Use Plastics Ban)  01-Jan-2024  From 1 January 2024, disposable plastic cups, food packaging, and cutlery will no longer be allowed to be served in offices, festivals, and on restaurant premises; reusable items will need to be used in place of these disposable items.  
Poland  Regulation on rates of the fee for single-use plastic products being packaging  01-Jan-2024  The rate of fees on the obligations of entrepreneurs in the field of management of certain waste and on the product fee of the 11th of May 2001 per item of single-use plastic product: 1.) PLN 0.20 – in the case of beverage cups (including their covers and lids), 2.) PLN 0.25 – in the case of food containers such as boxes, with or without lids, used to contain food that is a.) intended for direct consumption, on-site or take-away, b.) usually consumed directly from the container and c.) ready for consumption without further processing such as cooking or heating (except from beverage containers, plates, packages, and wrappers containing food).    

Updated: 1.) PLN 0.10 per KG of food containers, packs and wrappers for food, beverage containers (up to three litres), drinking cups (including cover and lid), and light plastic shopping bags, 2.) PLN 0.01 per piece of tobacco products with filters. The rate of fee for cleaning and transporting SUP products shall be PLN 0.01 per unit of wet wipes and balloons (except for industrial and professional use). 

Portugal  Decree-Law No. 78/2021 (Consumption reduction)  01-Jan-2024  Establishments supplying ready-to-eat meals in SUP fast food containers must make reusable alternatives available. All restaurant and beverage establishments, except non-sedentary ones, must only serve reusable utensils. Producers of these containers must through EPR schemes or individually promote research and development of sustainable alternatives and present them to the ministry.  
Republic of Ireland  Waste Management (Environmental Levy) (Plastic Bag) Regulations, 2001  01-Jan-2024  A levy will be charged and paid by customers, at the point of sale of goods or products placed in bags or plastic bags at any supermarket or retail premise. This levy will be 22 cents for each plastic bag.  
Republic of Ireland  Separate Collection (Deposit Return Scheme) Regulations 2021   01-Feb-2024  This DRS will come into early in the new year and this scheme focuses on maximising the volume and the quality of materials collected and reprocessed. 
Spain  Preliminary Draft Law on Waste and Resources of Catalonia  01-Jan-2024  The Catalonian government are preparing a draft waste law which would implement several policies to support the circular economy in the region. 
Spain   Act 7/2022, of 8 April, on waste and contaminated soils for a circular economy (Plastic Tax)  01-Jan-2024  As of the 1st of January 2024, it will be necessary to obtain a certification and to join a certification scheme from this date. From this enforcement date, it is important to certify claims on recyclability in relation to plastic.  
Sweden  Regulation on Disposable Products (Reduction targets)  01-Jan-2024  From the 1st of January 2024, any business that professionally supplies or uses these items must effectively contribute to reduce the consumption of single-use plastic cups and food containers by 50% from 2022 figures to 2026. 
Sweden  Ordinance on Single Use Plastics: Regulation on Disposable Products (Reusable packaging requirements & confetti ban)  01-Jan-2024  Anyone who provides beverages in a single-use cup or fast-food container must offer to serve the drink in a reusable cup and take effective action so that the reusable cups, lids, and food containers go through the return system several times. Providers should inform customers of this option and the environmental benefits of doing so.  
Sweden  Ordinance on Single-Use Plastics: Regulation on Disposable Products (SUP ban)  01-Jan-2024 (for SUP cups)  From this date, single-use cups that contain more than 15% of plastic are banned from being placed on the Swedish market. 
Sweden  Ordinance Amending the Producer Responsibility for Packaging Ordinance (2022:1274): Regulations on Determining Packaging Taxes Taking into Account Recyclability  01-Jan-2024 (for municipalities collecting waste from Households/certain businesses)  From this date, municipalities have the operational responsibility for collecting packaging waste from households as well as certain businesses as well as informing households on the preventative measures and sorting packaging waste.  
Sweden  Ordinance Amending the Producer Responsibility for Packaging Ordinance (2022:1274): Regulations on Determining Packaging Taxes Taking into Account Recyclability  01-Jan-2024 (Levy)  A Producer Responsibility Organisation (PRO) shall levy a higher financial contribution from a producer of plastic packaging. This is still set to apply from the 01-Jan-2024.  
United Kingdom (Northern Ireland)  The Producer Responsibility Obligations (Packaging Waste) (Amendment) Regulations (Northern Ireland 2023  01-Jan-2024  There are new amendments to the recycling targets for the following specific materials for 01-Jan-2024: glass 82%, plastic 61%, aluminium 69%, steel 87%, paper and board 83% and wood 42%.   


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