In order to reduce the impact of packaging and products on the environment, Finland has adapted its EPR (Extended Producer Responsibility) regulations. Registration with a collective system has been mandatory in Finland since 2024, whether for big players or newcomers. By removing the exemption limit for companies with a turnover of less than one million euros, Finland is taking a major step towards protecting the environment and resources. The adjustment in the Finnish definition of a producer is entirely in line with EU regulations.  

This means that all companies in Finland, regardless of their turnover or size, must now fulfil their extended producer responsibility for their packaging.  

There are also changes in the area of service and agricultural packaging. Producers or importers of service packaging, such as pizza boxes or coffee-to-go cups and agricultural packaging intended for agricultural products, now also fall under the definition of producer in the Finnish Packaging Act. Since then, the producer is responsible for the packaging, not the companies that actually fill the packaging and hand it out to customers. The regulation relieves the burden on small shops and restaurants. 

If you are a foreign company packaging products for the Finnish market or importing packaged products and have a permanent location or branch in Finland or sell packaged products from abroad to Finnish end customers, you are responsible for fulfilling your Finnish EPR obligations.  

Your obligations include registering with a collective system such as Rinki (where you pay a one-off registration fee and annual customer fees) and preparing an annual report on the quantities of your own packaging waste for the Finnish authorities. You also pay annual recycling fees depending on your packaging volumes. If you do not register with a collective system, you are free to set up your own system for collecting, sorting and recycling your packaging, but this involves a lot of bureaucracy.

Saving fees with recyclable packaging? It’s possible! To encourage companies to use recyclable packaging, Finland, like some other EU countries, is implementing eco-modulation.  

This means that you can reduce your recycling fees for packaging based on its recyclability. Fees for packaging made of mono-material, i.e. packaging made of only one type of plastic, are therefore lower than for packaging made of different types of plastic.   

Finland has been implementing this regulation since 2023. At the beginning of 2024, the regulation was expanded to include categories for metal and paper.

With the extension of the EPR obligations in the packaging sector by removing the turnover limit, almost 30,000 companies in Finland will be made more responsible. Costs will be distributed more fairly and recycling will be more effective. Although this increases the administrative burden for some companies, the extension represents an opportunity for the circular economy and thus for environmental and resource protection.

Eco-Fee Modulation is an instrument to promote the European circular economy. It is intended to incentivise companies to increase the use of recyclable packaging. Some EU countries are already using it to differentiate the licence or recycling costs in their respective EPR systems.  

Specifically, modulation aims to incentivise the development of sustainable packaging designs by differentiating the licence fees for sales packaging. In short, companies that use environmentally friendly packaging pay lower licence fees to the EPR systems and thus save costs. On the other hand, packaging that does not fulfil the requirements of eco-modulation is taxed more heavily and is therefore more expensive. This approach is an important step towards an environmentally conscious economic policy that promotes ecological sustainability. 

In the European Union, the Packaging Directive requires companies that put packaging into circulation to ensure its disposal. This principle is known as extended producer responsibility (EPR). However, the specific requirements and obligations vary from country to country, as each country has developed its own laws to implement the EU directive. However, the basic principle remains the same everywhere: companies that put packaging into circulation pay a licence fee to an EPR system that is responsible for the collection, sorting and recycling of packaging waste.

In Germany, for example, companies fulfil their obligations by registering and reporting data in the LUCID packaging register and licensing their packaging with a dual system such as Interseroh+ via Lizenzero. Do you ship to the EU? With our licensing service, we can easily fulfil all your obligations per country for you! 

The standardisation of the eco-fee at European level is a desired goal, but implementation currently varies greatly from country to country. While certain materials are already taxed in some countries, others have not yet introduced eco-fees. Incentive models in the form of eco-fee modulation have already been introduced in France, the Netherlands, Belgium and Finland. However, the exact structure varies from country to country.   

In principle, however, the recyclability of packaging, on which the eco-fee is based, is orientated towards the following criteria:  

• Sortability and separability  
• Source material (paper, plastic, metal, glass)  
• Residual emptiability
• Contaminants in the material 

Do you ship to different EU countries? We take care of your packaging licensing! On top of that, we can also check for you whether the design of your packaging meets the requirements of Eco-Fee modulation in your target markets. If the design of the packaging does not yet meet the Eco-Fee requirements, we can also support you in adapting your packaging to the standards on request.

On 1 July 2023, Hungary tightened the regulations regarding extended producer responsibility in the country. Since then, online retailers in particular have been held more accountable. If you sell goods and packaging to Hungary, they must be licensed with an EPR system from the first kilogramme. This now also applies to retailers who do not have a Hungarian VAT number. Foreign companies that are obliged to obtain an EPR licence must appoint a Hungarian representative for this purpose.  

In addition to the licensing of packaging, there are further obligations for companies that fill packaging with goods for the first time or have it filled and sell it to private individuals. Additional registration with the MOHU licence company and the Hungarian environmental authority is required. In addition to packaging, some product categories are also subject to the new EPR levies.

Until now, packaging did not have to be licensed in Hungary. However, companies above a certain annual turnover with a VAT number pay a product fee through the environmental tax. Since July 2023, however, all distributors of packaging, with or without a VAT number, are now obliged to contribute to the recycling costs. The new EPR requirements replace the previously applicable “product fee for environmental protection”. Since April 2023, the companies concerned have had to register on the MOHU Partner Portal and with the environmental authority.   

The registration and payment obligation always applies to the first Hungarian distributors and also applies if an online shop based outside Hungary sells goods to end consumers in Hungary.   

Unlike in France or Italy, however, there is no labelling obligation for packaging.

In addition to packaging, the new EPR regulations also apply to textiles, wooden furniture, batteries and WEEE products (electrical and electronic equipment).  

If you sell these products in or to Hungary, registration with the above-mentioned bodies and an EPR levy are also mandatory. Retailers are also responsible for the effective disposal of these products. 

The extension of the EPR obligations for manufacturers and retailers in Hungary presents them with new challenges in terms of their registrations, but also due to the costs associated with the EPR levy.    

At the same time, however, these adjustments will also trigger the implementation of more sustainable practices, which in turn will benefit the environment. In addition, the circular economy is strengthened and environmental protection is promoted.  

You need support in implementing your obligations in Hungary? We are happy to help!

As in many other EU countries, single-use plastic is increasingly under scrutiny in the Netherlands to protect the environment. Based on the Single-Use Plastics Directive (EU) 2019/904 of the European Parliament, more and more EU member states are implementing regulations to reduce the environmental impact of certain plastic products. 

Since July 2023, for example, Dutch consumers have been paying an additional fee for their single-use plastic cups or containers, especially for to-go products. The fee also applies to paper cups with a plastic lining and to-go packaging available in supermarkets. Since January 2024, the additional regulation on Single-Use Plastic has been in force. As a result of this regulation, various single-use plastic products are no longer available in Dutch stores. Instead, there is a shift towards environmentally friendly and reusable alternatives. 

In addition to this regulation, a ban on the use of microplastics in cosmetic products has come into effect. The ban on these tiny plastic particles, which are found in many personal care products, is intended to help improve water quality and protect our marine ecosystems.

• Plastic bags, straws, single-use plastic cups 
• Single-use plastic containers, tableware, and cutlery 
• Styrofoam cotton swabs, balloon sticks, and stirrers 
• Styrofoam food packaging 
• Microplastics in cosmetic products    

The new regulation distinguishes between consumption or consumption on-site and consumption on the go, resulting in slightly different interpretations for trade and gastronomy. The Dutch government sets guidelines for the surcharge that consumers must pay for single-use plastic products. For instance, the proposed surcharge for cups is 25 cents per cup, 50 cents per meal, and five cents for small storage containers.

Consumers pay an additional fee for single-use containers with plastic content for ready-to-eat meals at places like supermarkets, bakeries, or kiosks where on-site consumption is not provided. The amount of the surcharge can be determined by the respective companies. However, the costs must be listed separately on the receipt so that consumers can clearly see what they are paying for the use of single-use plastic products. There is no additional fee for containers with food that are not directly ready to eat and, for example, need to be heated before consumption. 

If on-site consumption is offered, single-use containers with plastic may not be provided. Instead, retailers must offer a reusable option or allow customers to bring their own containers.

For on-site consumption, it is prohibited for restaurateurs to provide single-use containers made of plastic. Instead, reusable tableware must be used or the use of customers’ containers must be offered. 

However, for takeaway or delivery of food, single-use containers can be used as long as customers pay an additional fee for the containers. Again, the surcharge must be listed separately on the bill. Alternatively, reusable alternatives with a return system or customers’ containers can also be used here.

Since 2024, the ban on single-use plastic also applies to corporate canteens, offices, or institutions. Washable tableware must be used here. Alternatively, reusable containers or customers’ containers can also be used. An exception is made for healthcare facilities such as hospitals.

With these measures, the Netherlands is implementing the EU directive to reduce single-use plastics. The measures are intended to reduce the large amounts of single-use plastic waste and strengthen the use of reusable alternatives. In the long term, this should protect the environment and strengthen the use of recyclable materials.