Understanding Global Extended Producer Responsibility (EPR)

Producers and importers of service packages, packagers (presumed brand owners) and importers may be legally obligated under producer responsibility laws. Your company may join a packaging compliance scheme in Austria if it supplies packaged products to consumers in Austria using distance communication.

The packaging concerned is either household packaging or commercial packaging, both of which requires companies to join a compliance scheme.

January 1st, 2025, Austria has implemented their deposit return scheme (DRS) for plastic beverage bottles and beverage cans between 0.1 and 3 litres. Products subject to the DRS must be marked with the relevant logo to ensure their proper return.

If your company manufactures and sells EEE under its brand, resells under its own brand EEE produced by other suppliers and imports EEE into Austria to sell, it may be legally obligated under producer responsibility laws. Obligated parties must adhere to the guidelines and distinct data reporting and registration requirements. Distance sellers are required to appoint an Austrian-based authorised representative that is responsible for meeting their obligations under the Elektroaltgeräteverordnung (EAG-VO).

Any company with residence in Austria dealing with batteries (irrespective of the selling technique used) may be obligated, including the manufacturers and importers of batteries. Your company may be obligated under new regulations that prohibit batteries and accumulators placed on the market that exceed the threshold of mercury, lead, and cadmium. Producers of portable batteries must fulfil their take-back obligation by joining a compliance scheme.

Belgium has a unique EPR structure in that EPR systems are set-up between the three key regions as well as on a federal level: Brussels-Capital Region, Flanders Region and the Walloon Region. On a federal level, companies that package more than 300kg of packaging waste annually are required to comply to Belgium’s EPR regulations. The obligation is on companies who package products, have them packaged in Belgium to market them in Belgium under your brand name or a neutral brand name, import packaged goods or have them imported to bring them onto the Belgian market, consume or unpack industrially packed products in Belgium and produce or import service packaging (packaging used at the point of sales, such as disposable carrier bags, pizza boxes, wrapping paper).

Aligned with EU legislation and the Packaging and Packaging Waste Directive, Belgium may amend packaging directives that would impact companies and brand owners due to potential changes in packaging requirements, for example, introducing material bands, reducing excessive packaging and new requirements for recycled content.

A company not registered in Belgium (without a Belgian VAT number) has no obligation to comply with Belgian regulations unless the company makes distance sales directly to the consumer. It is possible for a foreign company to voluntarily join the compliance scheme and report; however, the legal responsibility remains with the Belgian company that must ensure the foreign company complies.

If your company places EEE and batteries on the Belgian market (manufacturer or importer) it will be obligated and must comply with the registration and data reporting requirements. Belgium’s EEE and battery regulations are aligned with EU Directives that dictate the waste management activities, labelling and design, administrative requirements and take-back schemes.

Brazil has a National Solid Waste Policy that regulates the management of various types of solid urban waste based on a system of Reverse Logistics (this encompasses extended producer responsibility and deposit return scheme principles). Reverse Logistics is implemented through a mixture of Sectoral Agreements, Terms of Commitment and State legislation. If your company produces, imports, distributes or sells any of the products listed in this policy, it may be obligated under producer responsibility laws when managing any post-consumer packaging waste generated from that product. This includes batteries, EEE products and their components.

Packaging in general (products wrapped in glass, metal and plastic packaging, and other products and packaging) is regulated uniquely depending on individual States, for example, companies that trade within the State of Rio de Janeiro must comply with producer responsibility laws in force on packaging waste in general. Therefore, companies and brand owners will be obligated differently depending on material and state regulations.

Along with regulating packaging, Brazil and its various individual States have created various measures that include prohibitions on plastics that range from bags, and straws, to bottles. Other measures include the need for plastic packaging that is placed on the market to be returnable and recyclable.

Bulgaria has multiple EPR packaging regulations, taxes, and bans. Importers and producers of packaging and packaged products, service producers and sellers who add packaging to goods, and retailers may be obligated under producer responsibility laws. Obligated companies must take fiscal responsibility for the collection, recovery, and treatment of their packaging. Businesses will meet their obligations by joining a compliance scheme, registering with the relevant authorities, accurately and periodically declaring information regarding packaging placed onto the market and paying the appropriate fees.

The Minister of the Environment announced in early 2024 the plan for potentially introducing a deposit return scheme (DRS) for certain packaging waste (beverage packaging for bottled water, soft water, beer and cider from 0.1 to 3 litres) within Bulgaria. This has yet to move forward but with the adoption of the Packaging and Packaging Waste Regulations, there may be more additional updates concerning the implementation of a DRS.

If businesses place any electrical equipment, batteries, or accumulators on the market in Bulgaria, you may be obligated under the relevant EU Directive that dictates the waste management activities, labelling and design, administrative requirements and take-back schemes.

Canada has a complex regulatory framework, with extended producer responsibility regulations separated by the provinces and territories. While there are federal-level regulations around materials, such as the Federal Plastics Registry, there are some further EPR components that businesses will be obligated under. All the provinces have or intend to implement packaging EPR, EPR, or packaging-related schemes, with a large majority being involved in beverage deposit return schemes. It is the relevant company’s responsibility to ensure compliance with the individual state’s specialised legislation. Currently, the only provinces without an EPR system in place for packaging include Prince Edward Island, Newfoundland and Labrador, Nunavut and the Northwest Territories.

If your company manufactures, sells or imports EEE or batteries into a province in Canada it may be legally obligated under producer responsibility legislation. Depending on the province, producer responsibilities for EEE and batteries will be different, however in a majority of the state’s producers placing batteries or EEE on the market must join an approved product stewardship plan. Throughout all the states obligated parties are required to register with a relevant authority and comply with annual data reporting requirements.

If your business places any of the following materials onto the Colombian market; plastic, glass, metal, paper or cardboard packaging and any electronic waste of batteries you will be legally obligated under producer responsibility legislation. Colombia has dedicated EPR waste collection schemes, with four schemes focused solely on EEE streams (including batteries, tyres, bulbs and computers). Packers, producers, importers, and fillers that place or circulate products within the market in Colombia are required to submit individual or collective waste management plans to the National Environmental Licensing Authority for approval.

The Ministry of Environment and Sustainable Development has a designated registry where producers need to register. To fulfil their obligations producers must organise and finance the collection and treatment of waste products through either individual or collective management systems and meet collection and recovery targets. To fulfil their obligations producers may either have an agreement between the varying producers or through a legal entity (for example, a Producer Responsibility Organisation). Producers will need to assume these costs throughout the collection, storage, transportation, and final disposal cycle. Producers will further be responsible for designing and financing any information campaigns to raise awareness for the schemes.

As well as enforcing regulations on packaging, Columbia has various regulations on prohibiting single-use plastics. Since July 2024, Columbia has been enforcing a law that will prohibit certain single-use plastics as well as regulate these harmful plastics that are not encompassed in this prohibition within their own EPR sector. Regulations concerning this will be developed by the appropriate authority.

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