![]() Michelle Carvell | All wrapped up: understanding packaging waste complexitiesMichelle Carvell, director of client services at Lorax Compliance, explains the legislation behind the EPR directives.
Manufacturers across Europe have been under the environmental reporting spotlight for many years. Since the early 1990s, European countries have been implementing packaging regulations. These were established to encourage the recycling, recovery and reuse of packaging waste under the umbrella of EPR (extended producer responsibility) The first packaging directive in 1994 required countries to enact legislation to meet EU-wide targets for recovery and recycling. Two major amendments to the directive in 2004 and 2013 aimed to clarify terms around the definition of packaging and to increase the recycling targets of specifc packaging materials in each member state. This gave waste recycling a much higher profile within government and industry. Batteries included: expanding the reach of EPR However, the reach of EPR does not just stop with packaging. The first electronics and batteries directives were passed in 2003 and 2006. These have seen revisions to their original mandate to increase targets and to bring more products under the legislative scope. By 2018, all electronic items must be reported. Within the European directives, there is no single standard for waste reporting. Each country can, and has, implemented the directive in its own way. This brings a huge level of complexity to the process and places a compliance burden on multinational companies. Information by country The data companies must report varies in complexity and detail, depending on where they are based and how they trade in Europe. This ranges from reporting simple material tonnages (for example, the total plastic, paper or metal used) to providing details about all the packaging components held in a packaging bill of materials (BOM). Additionally, some countries require companies to report product origin or to declare which step of the waste lifecycle they are at. For example, are they packaging manufacturers, packer-filers, brand-holders, retailers or a combination? Likewise, some countries only have a requirement for household products reporting, but others will need the details for all products placed on the market. You may even find that products within your range are excluded in some markets but included in others. Some schemes also have incentive programs. These either reward the use of recycled materials or award discounted fees if you are promoting your products’ packaging recyclability. EPR: an evolving regulation Waste legislation is constantly changing, as countries update their regulations on a frequent basis. This can vary from a simple fee change to the introduction of new reporting categories or the addition of new items to the scope of the reporting process. We have seen a few countries recently make significant changes to their reporting requirements. For example, Austria has introduced changes to share packaging waste costs across the supply chain. Austrian manufacturers may now be required to divert valuable company resources to regulatory research to ensure compliance. End
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