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.

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. For producers of industrial batteries, it is not compulsory.

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.

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 through 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.

If businesses place any electrical equipment, batteries, or accumulators on the market in Bulgaria, you may be obligated under the relevant EU Directive that dictate 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, 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.

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.

Croatia currently has several regulations and legislative acts that regulate plastics and packaging waste. Obligated businesses will need to meet requirements regarding the design, collection, storage and processing of packaging waste. There are two systems of regulation in Croatia: one for the packaging of drinks and dairy beverages, and one for all other packaging. Currently, foreign companies can only register or provide services in Croatia if you are an EU/EEA or a third-country national. If you are in either group, you do not need to register with the Croatian authorities, however, you have to deliver a statement on the cross-border provision of services to the competent authority, by e-mail.

Croatia has implemented bans on certain single-use plastics, products made with oxo-degradable plastics and plastic carrier bags. Croatia currently has a Deposit Return System or refund fee system for single-use beverage packaging made of PET, Al/Fe and glass based on the volume of the container. Obligated businesses have to ensure that the products placed on the Croatian market meet the conditions prescribed for the product, that it has the prescribed label and information, and the prescribed notifications are put in place of sale. The producer is further responsible for recording and delivering accurate data to the relevant authorities.

Producers and distributors of obligated EEE products must pay a waste management fee to the Environmental Protection and Energy Efficiency Fund (EPEEF). If your company manufactures, sells or imports EEE or batteries in Croatia it will be legally obligated under producer responsibility legislation and are required to register with the relevant authorities and comply with data reporting requirements.

China has packaging EPR in place focusing on paper-based composite beverage packaging and most recently excessive packaging. There are strict requirements around the EPR legislation on characteristics of packaging including dimensions and recyclability.

China has introduced a single-use plastic ban, prohibiting the production and sale of non-degradable plastic bags and other disposable plastic products.

If your company manufactures, sells or imports EEE into China it will be legally obligated under producer responsibility legislation.

Companies that introduce packaging or packaged consumer goods into the national market, except for reusable containers, may be obligated under producer responsibility laws. The EPR scheme emphasises that producers who place products onto the market in Chile must comply with certain obligations including registering, organising and financing waste management, meeting the recovery and collection goals and lastly ensuring the authorised handlers perform the treatment for the collected waste. Businesses providing products with lubricating oils, EEE, batteries, containers, tyres, beverage cartons, metal, paper, glass, and plastic will be obligated under the relevant producer responsibility legislation.

Chile’s EPR legislation includes bans on disposable materials and labelling requirements. Producers finance waste management in proportion to the amount of packaging placed on the market by each producer, as well as registering with The Pollutant Emissions and Transfer Register and carrying out reporting obligations.

If your company either produces, imports, distributes or distance sells packaging or packaged products onto the Cypriot market it will be legally obligated under producer responsibility laws. Cyprus has several EPR and packaging legislations, including a ban on certain single-use products.

Your company will be legally obligated under producer responsibility laws if you produce, import, distribute or distance sell EEE and batteries onto the Cypriot market.

Producers, importers, manufacturers, and distributors are obligated under the Czech Republic Packaging Act and other producer responsibility laws if they place packaged or packaging goods on the national market. Producers would be responsible for registering with the appropriate authority or organisation, paying registration and administrative fees, and presenting quarterly packaging reports. Companies are exempt from the take-back, recovery and registration requirements if they place less than 300 kg of packaging on the market each year, and if their annual turnover does not exceed 25 million CZK.

The Czech Republic has additional EPR-related legislation, including a ban on the production and sale of certain single-use plastics as of October 2022 and a Deposit Return Scheme for glass bottles.

Companies that produce, manufacture, import or distribute EEE or batteries onto the market in the Czech Republic are obligated under EEE and battery legislations. There are few thresholds under the Czech EEE Regulations, except for military and security equipment and some specialised products. Batteries sold separately and as part of electrical equipment are under obligation.

Denmark’s EPR participation was previously levied exclusively through tax and only on Denmark-based companies, however, as of the 1st of January 2025 this legislation will shift more towards producer responsibility. Manufacturers will now include companies established in another EU Member state or a third country that sell or fill packaging for commercial purposes using distance selling, in addition to manufacturers and importers established in Denmark.

Manufacturers and importers of packaged products shall, in proportion to their market share of packaging, arrange for the take-back and separate handling of packaging marketed as part of a packaged product and waste. Producers will now have to compensate municipalities for collection at households and sorting.

Denmark enforces other EPR-related legislation, namely a Deposit Return Scheme with aluminium, glass and plastic from bottles and cans, packaging tax, labelling requirements and a ban on plastic bags.

Producers and importers of EEE will be obligated in Denmark under the Executive Order on Electronic Waste. Producers, importers, or their representatives of EEE and Batteries must register and provide annual reports, separately, in addition to context-specific obligations under producer responsibility legislation. Producers and importers of batteries to resell them in Denmark must contribute to the financing and organisation of take-back and management of those batteries at their end of life.

The primary EPR regulation, the Packaging Act, in Estonia ensures that manufacturers, importers, exporters, transporters and online sellers are responsible for their products throughout the product’s life cycle. If your company is involved in the production or distribution of paper, carton, beverage cartons, aluminium, glass, plastic, wood, and ferrous metal you will be obligated under the Packaging Act. Obligated parties will be responsible for the registration, taking back, recovery, payment of fees and reporting of packaging waste.

There are now lower quantity thresholds, although recovery obligation only applies to packaging that weighs more than five tonnes. However, all companies must still join the Packaging Register and report information.

As a member of the EU, Estonia adhere to the EU EEE and battery and accumulator Directives. Producers, importers, exporters and online sellers of EEE must register with the relevant authority submit regular reports about the amount of EEE products placed on the market. Obligated parties under the WEEE directive must finance the collection, treatment, recovery, disposal, and sustainable design of their products and packaging.

Estonia enforces other EPR-related legislation, namely a Deposit Return Scheme on beverage containers, packaging tax and a single-use plastic ban, aligned with the EU.

As of 2024, Finland will extend its packaging producer responsibility to businesses of all sizes, superseding the previous threshold that obligated companies were only companies with a turnover exceeding one million euros. The updated legislation classifies obligated parties as any company that packages in Finland or delivers their products to Finland through remote selling, i.e. online retailers. The obligated companies are responsible for all packaging introduced into the Finnish market throughout its life cycle. All packaging categories within commercial, group or transport sectors are subject to producer responsibility legislation.

Obligated companies must either register with the compliance authority ELY Center Prikanmaa or join a maker community, for example, a Producer Responsibility Organisation (PRO). The relevant parties will be responsible for the organisation and payment of administrative fees and reporting all quantity data of products and packaging placed onto the Finnish market.

Online sellers registered in another country can handle producer responsibility by joining a manufacturer association or appointing an authorised representative in Finland who will manage producer responsibility obligations.

If your company contributes to the placement of WEEE products or batteries to the Finnish market from within Finland or distance sales directly to consumers in Finland, it must comply with producer responsibility laws. Obligated parties will be responsible for the costs and organising of their products’ waste management, promoting reuse and recovery where possible.

France has a thorough and fast-developing legislature including packaging, textiles, furniture, EEE and batteries. All producers, importers, retailers, and distance sellers that place packaging, EEE, batteries and/or any product within the EPR category onto the French market are obligated under French EPR regulations. The EPR system in France includes bans on single-use plastic bags, a system of modulated fees for packaging waste systems and labelling requirements in addition to an extensive policy framework of EPR regulations.

To fulfil their waste obligations manufacturers who place any quantity of packaging, EEE or batteries on the French market, must either register with the relevant authority or a Producer Responsibility Organisation (PRO). For all categories of EPR the registration will include the payment of an eco-fee. An authorised representative, for companies established outside of France, is not required but can be appointed to assist with the registration in the PRO and to implement further required steps.

Producers and obligated parties are required to submit detailed reports for packaging and EEE. Different declarations must be submitted depending on various thresholds describing the amount of packaging placed on the market each year by packaging producers. However, obligated parties that place batteries onto the French market must provide quarterly reports following a guided schedule.

Germany’s Packaging Law (VerpackG) replaced the previous German Packaging Ordinance (VerpackV). VerpackG established a national authority, significantly increased targets for material recycling, and added new registration and data reporting requirements. There are continuous amendments to VerpackG that ensure the thorough management of packaging and packaging waste in Germany.

Distance sellers (online retailers), producers, importers, distributors and intermediaries that place and deliver packaging to the German market are obligated. Manufacturers are required to register with the relevant authority and the specialised packaging register, prior to placing the packaging on the market. Germany has additional mandatory EPR regulations and requirements including a single use plastics levy as of the 1^st of January 2025, a Deposit Return Scheme for beverage containers, a plastic ban and requirements that cover the full life cycle of packaging and packaging waste.  The single use plastics levy will make it mandatory for producers and importers of single-use plastics to pay a levy to the German Federal Environment Agency “Umweltbundesamt”.

Companies that introduce EEE or batteries to the German market, regardless of the selling method, it will be legally obligated under producer responsibility laws. All manufacturers, distributors, online retailers, and importers are bound by the requirements for EEE presented in the German Act, Elektro G. Batteries in Germany are covered by the EPR requirements in the Batteriegesetz or BatterieG (Batteries Act) and are applicable to battery producers, importers, authorised representatives of non-EU based producers, distributors, and resellers of batteries.

If your company imports, produces or sells packaged products in the domestic market, it must comply with extended producer responsibility laws. All companies aiming to sell to consumers in Greece must join a packaging register with the relevant authority and register as packaging producers with Greece’s take-back system. As of December 2023, importing manufacturers of packaging and packaging waste must develop and arrange alternative management systems for packaging they place on the Greek market. Obligated parties are required to comply with various EPR regulations and annual requirements relevant throughout the design, manufacturing and disposal process of packaging and packaging waste.

If your company places any EEE or batteries onto the Greek market, it may be obligated under extended producer responsibility legislation. Greek legislation outlines the requirements for batteries placed on the Greek market, ensuring all obligated parties must join a collective alternative management system, are required to register in the Paray Register of Producers and prohibit certain batteries containing mercury and cadmium exceeding the threshold amount. EEE products are managed throughout their life cycle according to the EU WEEE Directive and the Greek Joint Ministerial Decision 23615/651/Ε.103/2014 legislation.

All foreign companies are required to appoint an authorised representative.

Companies that distribute, import or produce packaging that will be placed on the Hungarian market will be obligated under extended producer responsibility legislation. As of the 1^st of July 2023, a new EPR scheme with accompanying EPR product fees has been introduced into Hungary’s legislation, mainly affecting the production and distribution of circular economy products, including packaging. The updated EPR scheme extends the responsibility to include foreign online retailers and where obligated parties must organise and manage their waste, is responsible for the redemption and take-back of returned product, the collection of waste, pay an EPR fee and the Green Tax. EPR legislation in Hungary requires businesses to store and report packaging quantity data quarterly. Additionally, international retailers that provide the relevant products or package products in Hungary are obliged by EPR Compliance registration. However, Obligated parties established outside of Hungary are not required to appoint a representative but have the option to do so.

Companies may be obligated under Hungary’s prohibition on single-use plastics and the mandatory deposit return scheme that was implemented as of January 2024.

Companies that contribute to the placement of more than 100kgs of EEE products and/or batteries onto the Hungarian market may be obligated under producer responsibility laws. EEE products are included within larger EPR schemes and are currently aligned with the EU WEEE directive. Some compliance schemes for batteries are in operation to take on producer obligations. The Green Tax and EPR fee include the importing, production and distributing of EEE and Batteries.

Israel’s primary law concerning EPR is the Packaging Law, introduced in 2011. There are several smaller laws that are common across the EU, that aim to reduce the volume of waste produced. Producers of household and industrial packaging waste, manufacturers that place more than 1000kgs of packaging on the Israeli market and large retailers may be obligated under these laws. Obligated parties are required to pay a per tonne fee and produce bi-annual and annual reports. Producers of beverage containers are obligated to report the number of products sold, collected, and recycled under their Deposit Return Scheme law. Additionally, Israel has placed a single-use plastics ban on plastic that are thinner than 20 microns.

If your company manufactures or imports WEEE and batteries it may be obligated under Israel’s Electrical and Electronic Equipment and Batteries Law. Obligated parties are required to treat their waste products, either in house or through an accredited company, submit annual data reports and arrange collection of e-waste and provide battery collection boxes available to anyone. Obligated parties are further required to recycle up to 50% of WEEE and over 25% of batteries produced on an annual basis.

Iceland has a long-standing history of plastic and paper packaging EPR, introducing all other types of packaging since the 1st of January 2023. All producers and importers of packaging must register with the Icelandic Recycling Fund, also known as the processing fund. The processing fund is responsible for all the administration surrounding the processing fees and produces annual reports on the collection and allocation of processing fees.

EPR schemes are operated by the Icelandic Recycling Fund, which is responsible for charging manufacturers and importers with recycling and take-back fees. Where Iceland differs from other EU Member states is that once a product is imported into Iceland it triggers a report to the Icelandic Recycling Fund. A registration process will be required with the relevant Customs Authority for foreign entities, while local manufacturers must register with the Internal Revenue Department. Furthermore, Iceland has other EPR-related legislation such as a thorough deposit return scheme.

Companies that produce and import WEEE and batteries may be obligated under producer responsibility laws in Iceland. WEEE and batteries are aligned with EU Directives and thus adhere to the exact collection, labelling, design, registration, treatment, recovery, and reuse requirements.

India has numerous EPR regulations and guidelines obligating all manufacturers, importers, distributors, and brand owners of packaging, WEEE and batteries. The primary EPR regulation that governs packaging EPR in India is the Plastic Waste Management Rules. Brand owners, importers and producers of plastic packaging are required to use eco-friendly designs, establish collection systems for collecting and organising their waste and send annual reports outlining their procedures for managing plastic waste and the quantity of waste being collected, recycled and disposed of. Obligated parties can establish collection centres with a PRO or waste management organisations. Plans for the collection systems must register with either the local or central Pollution Control Board depending on if they operate in more than two states.

If your company sells, imports or produces EEE and batteries in India you may be obligated under EPR regulations. Similarly, to packaging, producers of EEE and batteries in India are required to create or participate in the development of collection facilities and must register with the relevant State Pollution Control Board. Additionally, producers are expected to create and submit a strategy report for their planned management, collection, transportation, and recycling of EEE and battery products. Furthermore, producers of batteries in India are required to organise recycling consumer education campaigns on how to dispose of batteries.

Manufacturers, importers, vendors, distributors, and online retailers that place packaged products, packaging or package products in Italy will be obligated under producer responsibility legislation. National obligated parties are required to register with the relevant authority to obtain a packaging register number and ensure packaging is labelled correctly. In Italy, packaging management extends to the handling and management of biodegradable and compostable plastic packaging.

The obligated parties must comply with the current single-use plastic ban, the requirement to make eco-contributions, EPR fees, annual data reporting and the new plastic tax obligations as of July 2024.

Foreign-obligated parties are required to appoint an authorised representative in Italy to fulfil packaging law requirements; however, registration is voluntary.

As a member of the EU, Italy has integrated EU WEEE and battery and accumulator Directives into national legislation. Producers, distributors, importers and exporters of EEE, batteries and accumulators are required to finance and organise the collection, recovery and recycling of the products they place on the Italian market. Obligated parties are required to finance and manage EEE retroactively. Obligated parties for batteries and accumulators must join a collective system and register with the National Register of Battery and Accumulator Manufacturers. EEE and battery legislation limit hazardous components such as lead, mercury and cadmium.

The Containers and Packaging Recycling Act was established in the late 90s as the primary EPR regulation for packaging in Japan. Wholesalers, manufacturers and importers of packaging may be obligated under Japan’s EPR regulation. The main responsibility of waste collection, sorting, and transport falls to municipalities, while producers must finance the recycling of the collected waste packaging. Producers must either register with the JCPRA or apply for an individual recycling system. Producers are also encouraged to promote and organise educational activities and information for consumers. Japan has several EPR-related regulations such as a charge on plastic carrier bags, reduction targets, labelling requirements and recycling requirements.

Retailers of EEE, specifically home appliances, for a take-back scheme where they collect household appliances and organise products to be recycled by manufacturers. Batteries within these household appliances are included in the take-back system.

The Kenyan Government implemented their voluntary EPR Roadmap that covers an extensive number of materials and products, however the government is working towards implementing mandatory EPR regulations If your company produces or distributes packaging, batteries or EEE in Kenya, you may participate in the packaging scheme in Kenya . In Kenya, each producer may join or participate in establishing a PRO or Individual Producer Scheme that is registered with the National Environment Management Authority. The PRO will be responsible for the collection, sorting, recovery, recycling, treatment, and end-of-life management of products. The PRO will be responsible for carrying out the obligations of the EPR legislation. In addition, the roadmap includes national recycling targets and restrictions on certain single-use plastics.

All manufacturers, online retailers, merchants, retailers, importers and intermediaries of packaging who generate more than 300kg of packaging per annum, in Latvia, will be obligated under producer responsibility regulations. Even if your company produces less than 300kg per year, they will still be subject to a Natural Resources Tax. Companies receive a 100% exemption from paying the Natural Resources Tax by ensuring compliance with the recovery regulations for used packaging and various other materials by establishing an individual EPR system and following various other requirements. Obligated parties are required to register through the electronic system TULPE to obtain an EPR number, acquire certification with a registered Producer Responsibility Organisation and submit a report on activities and quantities to the PRO.

Manufacturers, importers and waste managers for EEE and batteries may be obligated under producer responsibility laws in Latvia. Manufacturers or their representatives must provide quantity and catalogue reports to the State Environmental Service and register with the relevant authorities. The producer responsibility laws for EEE and batteries ensure that producers establish collection systems for waste and adhere to labelling requirements.

In Latvia, an authorised representative is not required for packaging as foreign companies can act independently. However, EEE will be required to appoint an authorised representative.

Manufacturers, importers, intermediaries, sellers, and waste handlers of packaging that place more than 500kg on the Lithuanian market annually may be obligated under producer responsibility laws. Companies that do not exceed the 500kg threshold must still register with the relevant packaging authority and keep detailed records. Lithuania has a thorough DRS system in place for reusable packaging and beverages. Obligated parties in Lithuania are required to register with the relevant authority, must obtain certification through a Producer Responsibility Organisation (PRO), will be required to pay environmental taxes on packaging waste and submit annual returns.

If your company manufactures or imports EEE and batteries it may be obligated under producer responsibility laws. Lithuanian legislation is aligned with EU WEEE and battery directives. Unlike packaging EPR there is no threshold for obligations when parties place EEE onto the Lithuanian market. Furthermore, domestic producers are required to register with one government department, while foreign obligated parties are required to register with two separate departments.  EEE producers can either establish a PRO or join a certified PRO, but they must submit detailed quantity and activity reports to the relevant authority. Additionally, batteries placed on the Lithuanian market are subject to tax and have restrictions on the hazardous substances within them.

With regards to packaging foreign obligated parties are not required to appoint a local authorised representative. However, under EEE producer responsibility foreign obligated parties may appoint an authorised representative to undertake the obligations.

Luxembourg has thorough EPR legislation that obligates all producers, distributors, importers, and manufacturers that place packaging and packaged products on the Luxembourg market for the first time. The primary EPR scheme includes all obligated parties that place the relevant products onto the market, with no minimum quantity thresholds. Under the EPR scheme producers are required to register with an eco-operator (Responsible Extended Organisation) to obtain certification, submit annual reports.

Luxembourg has implemented a single-use plastics ban, plastic bag charges, labelling requirements and a variety of EPR-related laws that have been announced that producers may be obligated under.

Luxembourg has had long-standing regulations on batteries and WEEE. Obligated parties of WEEE are required to register with the Ministry for Sustainable Development, declare the products placed on the market and finance the collection, treatment, recycling and recovery of WEEE placed on the market. Producers of batteries are obliged to finance the take-back and recycling of the waste of portable batteries. It is not mandatory to join a compliance scheme, but producers have the option to do so with a fee.

Foreign companies must appoint an authorised representative to fulfil packaging legislation requirements in Luxembourg.

If your company supplies packaging, packaging materials or packaged goods for distributing, consumption, packing or filling in Malta they may be obligated under producer responsibility laws. The regulation covers a wide variety of materials. Obligated parties are required to register with the Environment and Resources Authority that must be annually renewed. Obligated parties are required to recycle and recover a set proportion of the packaging they place on the market each year. In 2022 Malta introduced a deposit return scheme where producers, importers, retailers and distributors must register with BCRS Malta and adhere to a specialised set of requirements. Malta has created separate requirements for packaging that remains with the manufacturers and distributors, and retailers and customers.

Manufacturers, producers, distributors and importers of EEE are required to register with the relevant authority and to submit data declarations. Producers of batteries are required to register with the relevant authority and to ensure compliance obligated parties can join an existing collective system or individually.

Foreign companies with no physical presence in Malta must appoint an authorised representative to fulfil their obligations.

There are no specific obligations for the producer responsibility of companies in Mexican legislation on a national level, rather the principle of Shared Responsibility is established in the national legislation. This includes the principle that the waste generator must assume the costs of its disposal and mandates that individual states respond to this law with their local policies and programmes.

Similar to the Brazil, United States of America, Australia and Canada, the majority of EPR legislation in Mexico is mandated and enforced on a state or regional level. If your company produces, imports or manufactures packaging waste onto the Mexican market you may be obligated under regional legislation. The states have created and are implementing EPR on a regional level including plastic and other non-recyclable products bans and various other waste management requirements that producers are obligated under.

Currently, Mexico does not have separate WEEE and battery legislation, the Solid Waste Law waste management specifications for WEEE. Further legislation for batteries and WEEE can be seen on the state level.

Manufacturers, distributors, brand owners and importers that place or dispose of more than 50,000kg of packaging on the Dutch market will be obligated under producer responsibility legislation. Obligated parties are required to register with the packaging waste fund, that will assume the responsibility on the behalf of entities. However, obligated parties are required to provide extensive information and annual reports to the packaging waste fund to fulfil their obligations. Obligated parties are liable to pay a contribution rate that is calculated on a fixed rate and the weight and type of plastic packaging. As of January 2024, a new Tariff Differentiation (2.0) was implemented which includes new model rates and administrative requirements. Obligated parties in the Netherlands will be subject to the above as well as single-use plastics bans, a DRS for bottles, labelling requirements, reduction targets and other specialised EPR requirements.

Producers, importers, distributors and recyclers of EEE and batteries may be obligated under producer responsibility legislation. Unlike packaging there is no threshold for EEE placed on the market and any amount of EEE placed on the Dutch market will be subject to the relevant requirements. Obligated parties of EEE and batteries are required to register and submit reports to the relevant authorities and organise the handling of waste. Obligated parties are required to register with the relevant authorities. For EEE entities are required to enrol in the national Register and can join the compliance scheme. For batteries entities are required to notify the authority, provide annual reports and can join the authorised compliance scheme.

Foreign obligated parties are not required to appoint an authorised representative for packaging legislation, however under EEE and battery legislation all foreign obligated parties are required to appoint an authorised representative.

New Zealand has developed extended producer responsibility regulations that ensure producers, importers and retailers of packaging, EEE and batteries will be responsible for the disposal and waste of certain products. The primary regulations introduced take-back services, deposit fees and labelling requirements that obligated parties are required to follow. The New Zealand government declared six priority products for regulated product stewardship that place the responsibility for end-of-life product management onto the relevant entities. Three of the six priority products include plastic packaging, farm plastics EEE products, including large batteries. To fulfil obligations the product must be declared and verified as a ‘priority product’, a product stewardship should be developed and obligated parties need to apply for accreditation. Additionally, obligated parties need to adhere to several single-use plastics bans and cosmetics products bans.

Manufacturers and importers of packaging and EEE products in Nigeria may be subject to extended producer responsibility regulations on the collection, treatment and handling of packaging waste. The Nigerian government has set out a proposal to help manage plastic waste by creating a Plastic-Waste Fund and setting several new requirements and procedures to effectively manage waste. All manufacturers and importers of food and beverage products need to submit a proposal for a consumer product stewardship programme and participate in a buy-back programme for the bottles and packaging waste. As of January 2024, the state of Lagos has banned the use of non-biodegradable single-use plastics and Styrofoam.

If your company is an importer, exporter manufacturer, assembler, distributor or retailer of EEE products they may be obligated under Nigeria’s extended producer responsibility laws. Obligated parties are required to manage products throughout their life cycle and have a take-back system to manage their waste. EEE in the Nigerian legislation excludes electrical equipment exceeding 1000 volts for alternating currents and 1500 volts for direct currents. Additionally, in 2022 the Nigerian Government implemented a National Policy on Waste Battery organised by the Nigerian Energy Support Programme (NESP) that provides detailed procedures on the management of waste batteries while encouraging the use of local battery recycling facilities.

Manufacturers, producers, product and packaging importers that place more than 1000 kg of packaging on the Norwegian market could be obligated under extended producer responsibility regulations (EPR). However, if your company meets other requirements, it may be obligated under EPR regulations even if the company contributes less than the threshold amount. Obligated parties are required to register with the relevant authority, submit detailed quantity reports to the Ministry of the Environment and adhere to the precise EPR requirements. To promote the use of recyclable packaging obligated parties will have lowered environmental fees if recyclable packaging is utilised. There a several separate regulations that govern how packaging is managed on the market in Norway, including a single-use plastics ban, a deposit return scheme for beverage containers, household recycling schemes, an environmental fee on beverage containers and a take-back system for packaging, EEE and batteries. Although Norway is not an EU member is it a part of the EEA agreement and is aligned to selected EU Directives concerning packaging, EEE and batteries.

Producers and importers of EEE and batteries in Norway will be obligated under producer responsibility legislation. As Norway aligns with the EU WEEE Directive, they are required to join a compliance scheme and register with the Norwegian Pollution Control Authority. There are several collective compliance schemes, registered with the Norwegian Environment Agency, that obligated parties may join that will manage the treatment, collection and disposal of EEE and batteries.

Foreign companies for packaging, EEE and batteries are required to appoint an authorised representative, this can be the government-certified compliance scheme.

Manufacturers, importers, packers, distributors, and retailers of packaging may be obligated under Peru’s producer responsibility regulations. Peru’s focus on reducing the impact of packaging on the environment is focused on single-use plastics and has several plans to encourage and incentivise reuse, recycling and composting plastic packaging for 2025. Significant single-use plastic bans were implemented in Peru where it is prohibited to manufacture, import, distribute or market the various types of plastic and Polystyrene.

The Peruvian Ministry of Environment (MINAM) implemented the updated WEEE Decree within the Solid Waste Law which obligates anyone who places EEE products on the Peruvian market for the first time. This will include importers, online retailers, assemblers, and manufacturers. In Peru, obligated parties may either fulfil obligated individually or through a producer responsibility organisation (PRO). Obligated parties will be responsible for a take-back system and ensure the design, treatment and collection of EEE products.

Producers, importers, distributors, and online retailers that introduce packaging or packaging waste of a variety of materials onto the Polish market in any quantity will be obligated under extended producer responsibility (EPR) legislation. Obligated parties in Poland are required to register through an e-portal database, must levy eco-contributions on each material type and submit annual data reports. Additionally, obligated parties in Poland must subscribe to single-use packaging fees and the deposit return scheme for beverage containers, which place the funding of costs for managing, collection and recycling of containers on the producers, importers and retailers.

Importers, producers, online retailers and distributors of EEE and batteries that introduce relevant products onto the Polish market may be responsible under EPR regulations. Aligned with EU directives for EEE and batteries it is the obligated parties’ responsibility to finance collection schemes. Both small and large producers of batteries are required to adhere to EPR regulations, although the process differs. Obligated parties for WEEE are required to register with the relevant authority and must organise the design, collection and disposal of EEE products. As of February 2024, the new EU Battery and Battery Waste Directive has been implemented that establishes new detailed requirements for increasing the sustainability, safety, labelling, collection and treatment of battery waste.

Foreign companies are required to appoint an authorised representative to fulfil obligations in Poland.  There are several other voluntary schemes that companies can join to ensure that their products are properly managed for their full life cycle.

From July 2022 the Philippines enacted the Extended Producer Responsibility Act. Enterprises whose total assets exceed a billion pesos are obligated to recover a portion of their plastic packaging waste, aligned with a predetermined annual target, or pay a penalty. The current legislation outlines the recovery of plastic waste as preventing the waste from leaking into the environment. This is done through various actions which include, but are not limited to, buying back material and waste from consumers and establishing a variety of waste disposal facilities and collection points.

Obligated parties include brand owners, manufacturers, and importers of packaged goods and service packaging with an asset value above 100 million pesos. Brand owners must form a collective PRO. Obligated parties are required to register with the relevant authority and submit detailed plans on their plastic waste management. While smaller enterprises are not required to register it is encouraged. The target is that by the end of 2028 and onwards the obligated parties will recover 80% of their plastic footprint of the previous year.

Hazardous EEE and batteries are regulated under government legislation in the Philippines under Solid Waste and Hazardous waste laws. The legislation regulates the importation, manufacturing, processing, handling, storage, transportation, sale, distribution, use and disposal of EEE and batteries containing toxic or hazardous chemicals. There are proposals to increase regulations on EEE and batteries, specifically the importation of waste.

Portugal has an extensive EPR regulation framework that details guidelines and requirements for managing specific waste streams. Portugal’s EPR aligns with and transposes EU Directives in the implementation of EPR, WEEE and battery legislations. All producers of packaging, packers, service packaging suppliers and importers are obligated under Portugal’s primary EPR legislation, Decree-Law no.152-D/2017. There is no minimum exception to EPR obligations, even solitary packaged products or product items under a variety of materials will be obligated. Manufacturers and packagers are required to register with the relevant authority and must annually report the quantity of packaging. In addition to their main EPR legislation, Portugal has a variety of regulations that will impact packaging and packaged product producers, distributors and importers, including a take-back system, a deposit return scheme and a single-use plastic ban. Obligated parties will be financially and operationally responsible for the end-of-life management of packaging and packaged products. To fulfil their obligations companies can apply independently or they can appoint a PRO.

If your company produces, imports or distributes EEE and batteries you may be obligated under Portugal’s producer responsibility laws. The producers will be responsible for EEE and battery products throughout their life cycle including their design, manufacturing and end-of-life management. Batteries that are sold are incorporated within EEE in an integrated system for the management of WEEE under Decree-Law No. 230/2004. Additionally, all EEE and battery producers will be responsible for financing, collecting, transporting and recycling of their products. Obligated parties are required to register with the Portuguese Environment Agency and submit annual and quarterly reports on the various actions carried out.

Foreign obligated parties of all packaging and EEE within and outside of EU Member States must appoint an authorised representative, through a written mandate, who will fulfil obligations as a packaging manufacturer. There are several other voluntary schemes that companies can join to ensure that their products are properly managed for their full life cycle.

Companies that place more than 10 tonnes of packaging or packaged goods onto the market in the Republic of Ireland each year and have a turnover exceeding €1 million may be legally obligated under producer responsibility laws as a major producer. The obligated packaging includes all packaging used to enclose or protect products for distribution, storage, sale and use. As of 2023, the EPR regulations were updated and obligated parties are now required to become a member of the approved body.

Alongside the primary EPR packaging regulations, Ireland is required to adhere to a mandatory deposit return scheme from the 1st of February 2024, new recycling and recyclability targets, a single-use plastic ban and additional legislation aligned with EU waste directives.

If your company sells, imports or manufactures EEE and/or batteries for Ireland you may be obligated under the Republic of Ireland’s primary legislation and EU Directives. Obligated parties of EEE and batteries can register with the compliance schemes in Ireland. Ireland is required to meet EU targets for WEEE and recycling and recovery targets for batteries, adhering to the collection, treatment and recycling measures set out by the EU Directive. Additional restrictions to EEE and batteries will apply if the products contain any materials classified as hazardous.

Foreign companies with no physical presence in the Republic of Ireland that are obligated under EPR and WEEE regulations must appoint an authorised representative to fulfil their obligations. There are several other voluntary schemes that companies can join to ensure that their products are properly managed for their full life cycle.

If your company manufactures, imports, packs or fills, sells or is the end user of packaging in Romania they could be obligated under EPR regulations. Obligated parties are required to register with the Administration of the Environmental Fund and to finance and organise the recovery and recycling of their produced packaging waste.  In Romania, obligated parties can fulfil obligations by joining a PRO or individual compliance. Obligated parties or their PRO must submit annual reports on their methods to meet recovery and recycling targets. In addition to the primary EPR regulations, obligated parties in Romania are required to follow a plastic bag and single-use plastics ban, a deposit return scheme, EU directives, a packaging tax and various other regulations.

In Romania, all manufacturers, importers, and sellers of batteries and EEE may be obligated under producer responsibility legislation. EEE producers are responsible for organising WEEE collection and can similarly opt to join a PRO. Obligated parties for WEEE and batteries that are outside of Romania must appoint a tax representative to comply with registration and reporting obligations in addition to an authorised representative.

Foreign-obligated parties of all packaging and EEE within and outside of EU Member States must appoint an authorised representative who will fulfil obligations as a packaging manufacturer.

As of January 2024, the original EPR guidelines of Russia have been amended. One of the key amendments is the shift of the responsibility for recycling packaged goods from the producers of the packaged goods to the producers of the packaging. Producers of packaging and importers are obligated and are responsible for the collection and recycling of the relevant waste. However, there are different specifications for importers that are a part of the member states (EAEU), and those outside of member states. The primary EPR system is regulated, enforced, and monitored by the relevant government agencies. Russia will rely on two waste accounting systems simultaneously.

Obligated parties in Russia are required to adhere to other product-related regulations, for example, labelling and design requirements, that are implemented by the Eurasian Customs Union.

While, Russia does not have a consolidated legislative framework for the management of EEE or batteries, WEEE in the form of household electronic equipment waste is covered under Russia’s primary EPR regulation.

Spain recently issued the Royal Decree 1055/2022 on packaging and packing waste that establishes a range of EPR obligations for producers that either sell products packaged under their own or a distribution brand or import packaged products into Spanish territory. Spain has existing EPR systems that have adapted to the new legal framework, requirements of the different EPR regulations and the Spanish Plastic Tax. Therefore, producers are obligated throughout the design, manufacturing, distribution, and waste management processes of packaged products. Obligated parties in Spain are required to register with a PRO, register for a tax number and submit a variety of annual data reports.

If your company manufactures, distributes or imports EEE and batteries into the Spanish market it will be obligated under producer responsibility laws. Aligned with the EU WEEE Directive and national EEE regulations, a system is in place for the life cycle of EEE, ensuring that the design and production of EEE consider repair, possible upgrading, re-use, disassembly, and recycling. Following the Royal Decree 993/2022, additional control measures are enforced for importers of EEE and batteries in Spanish territory from 2023.

Foreign companies must appoint an authorised representative and register with a Spanish compliance scheme to fulfil the EPR requirements when selling packaged products, electronic and electrical devices, accumulators, and batteries within the Spanish market.

As of January 2023, Sweden implemented new EPR Guidelines that make all manufacturers, importers and producers of packaging and packaging waste are obligated. If companies manufacture packaging in Sweden, import packaging into Sweden, import a packaged product into Sweden or sell a packaged product or packaging to an end-user in Sweden from outside of the country they will be obligated under Sweden’s EPR legislation. Sweden has a thorough deposit return scheme, that producers may be obligated to participate in and contribute to. Obligated parties are required to appoint a PRO to register on their behalf and must submit waste data reports and pay the eco-fees.

Foreign companies are not required to appoint a representative in Sweden for packaging.

If your company places WEEE and batteries on the Swedish Market it is obligated under producer responsibility laws and is financially responsible for the management and collection of the waste. Entities that manufacture, design or market WEEE under their trademark, engage in the resale of EEE, introduce EEE from a foreign country or remote sellers are responsible for the management and recycling of EEE. Furthermore, obligated parties must register with the Swedish Environmental Protection Agency and either of the two approved Swedish EEE collective systems. Obligated parties will be required to produce waste management reports, pay contribution fees and adhere to specific labelling requirements. Before batteries are placed on the Swedish market a report must be sent to the Swedish Environmental Protection Agency.

Under EEE regulations obligated parties must appoint a representative to fulfil obligations.

Companies that manufacture, distribute, pack or import packaging or packaged products for the market in Slovakia will be obligated under Slovakia’s EPR regulations. The primary EPR regulation in Slovakia is the Waste Act, covering a wide variety of materials including, but not limited to, aluminium, glass, plastic and wood.

Obligated parties are required to obtain an EPR number by registering with the relevant authority, be contracted into take-back schemes, pay eco-fees aligned with governmental allocations and submit a quarterly packaging and packaging waste report. Similarly, to most EU countries the current focus for Slovakia is on single-use plastics, with requirements being implemented in 2023 and others entering the regulations list in 2024 and 2025.

Slovakia has a variety of additional EPR-related regulations including a tax on disposable plastic bags, a deposit return scheme and labelling requirements.

Slovakia has thorough EEE and battery legislation that obligates any importers, producers, manufacturers of EEE and batteries, and any entity that markets batteries and accumulators. Obligated parties are responsible for the take-back, collection, transport, recycling and recovery of WEEE and batteries. There are several other voluntary schemes that companies can join to ensure that their products are properly managed for their full life cycle.

Foreign-obligated parties are required to appoint an authorised representative based in Slovakia to fulfil obligations.

The Department of Forestry, Fishers and the Environment (DFFE) introduced an EPR framework and regulations that obligates brand owners, manufacturers and importers of packaging to adhere to specialised waste management practices to encourage obligated parties to consider the environmental implications from the design to the products end of life. The EPR regulation includes standard packaging materials such as cardboard and plastic, but it also includes WEEE and portable batteries.

Obligated parties are required to register with the DFFE, join a PRO, pay the relevant fees produce annual packaging quantity, performance and waste reports to the DFFE, and participate in the take-back and recovery of waste produced.

At present there is no Extended Producer Responsibility legislation for packaging in Thailand. In an effort to improve waste management legislation the Draft Sustainable Packaging Management Act (Draft Packaging Act) is being developed.

While currently, no EPR legislation obligates companies under producer responsibility laws for WEEE, a draft is being developed for a WEEE act to implement an EPR framework for WEEE products. However, in 2020 Thailand placed a ban on the importing of electronic waste under B.E. 2563.

Currently, there is no EPR legislation regarding batteries.

Turkey’s primary EPR packaging legislation is defined in the Environmental Act No. 2872 on Waste Management Ordinance and the Ordinance on the Management of Packaging Waste. The EPR legislation emphasises the importance of packaging being recyclable and encourages the use of recyclable packaging over single-use plastics. Turkey has introduced a producer responsibility tax in the form of Recycling Contribution Shares that importers and distributors are expected to pay. All producers, marketers, importers, and suppliers of packaging are obligated under Turkish regulations.

Producers can fulfil their obligations individually or by joining an approved compliance scheme. Producers in Turkey EPR legislation are responsible for implementing methods to encourage the most efficient use of products to promote reuse, repair, and recycling.

As of January 2023, Turkey has enforced a mandatory Deposit Return Scheme on disposable sales packages prioritising glass, aluminium, and PET beverage containers.

If your company introduces and circulates EEE and batteries on the Turkish market it will be obligated under waste management and hazardous substances EPR regulations. In Turkey, WEEE management regulation focuses on the need to promote recyclability, reuse and repair through eco-design and production. Within EEE and battery legislation hazardous components such as lead, mercury and cadmium are limited to thresholds.

Companies that produce more than 25 tons of packaging and have a turnover exceeding £1 million will be obligated under a degree of producer responsibility laws.  However, companies with a turnover of over £2 million and producing more than 50 tons of packaging are classified as large companies and are obligated under all EPR requirements. Packaging in the United Kingdom (UK) covers a wide range of materials from glass, plastic and aluminium to wood and steel.

The UK has implemented a plastic packaging tax that requires all companies that manufacture or import a minimum of 10 tonnes of plastic packaging to register with the HMRC and submit quarterly returns with detailed information on the characteristics and production of the plastic packaging. Deposit Return Schemes for Scotland and the rest of the UK are aspiring for implementation in 2025.

If your company manufactures under its brand, re-brands, imports or sells EEE and batteries to household customers in the UK it may be legally obligated under producer responsibility laws. If obligated parties place less than 5 tonnes of WEEE they can register directly with their environmental regulator. If the entity exceeds this threshold, it must join a producer compliance scheme (PCS). The PCS will be responsible for financing the collection, treatment, recovery and disposal of EEE. The obligations for batteries will depend on their type. Obligated entities are required to report on both WEEE and batteries separately.

On a federal level the United States of America has enforced the EPR packaging legislation, Break Free From Plastic Pollution Act. This EPR system has the main goal of reducing single-use plastic in packaging and managing packaging throughout its life cycle.

Currently, in the US, most extended producer responsibility laws are administered on a state level with 5 states introducing legislation covering packaging since 2011. 40 states have EPR packaging regulations in force that are mandatory and carry an obligationCurrently, at least 25 states have passed legislation solely placing the responsibility on WEEE and batteries, with more states included WEEE and batteries within larger EPR regulations.