The PPWR will change the definition of a producer next year
The requirements of the PPWR will enter into force in stages. The first significant change to the extended producer responsibility is the new definition of a producer, which will be applied as of 12 August 2026. For any given situation, the definition specifies which company is obliged to report packaging under extended producer responsibility and the fees to be paid.
The most significant changes to the definition of a producer concern transport packaging and situations in which a company has packaging or packaged products manufactured under its own name or trademark, says Maija Peltola, Rinki’s Customer Service Manager.
The definition of a producer of transport packaging is set to change
The producer of packaging is usually a company that packs a product in Finland for the Finnish market or imports a packaged product from another country to Finland. A company established in another country is defined as a producer if it sells a packaged product directly to an end user, which can be a consumer or company in Finland.
However, if the packaging is service or grower packaging, the producer is the manufacturer of the packaging in Finland or the company that imports the packaging to Finland. Under the PPWR, the producer of transport packaging is defined in the same way as the producer of service and grower packaging.
Example: Company A, located in Finland, packs its products in a cardboard box to be transported to its customer in Finland. Company A has purchased the cardboard boxes from its manufacturer in Finland.
· Under the current legislation, Company A bears the producer responsibility for all packaging used to pack its product, including the cardboard boxes used as transport packaging.
· Under the PPWR, as of 12 August 2026, Company A is no longer responsible for the cardboard boxes used as transport packaging. The manufacturer of the packaging in Finland bears the producer responsibility for the boxes.
Having packaging or packaged products manufactured under a company name or trademark
Under the PPWR, a company that has packaging or a packaged product manufactured under its own name or trademark is considered the manufacturer. For example, if a company located in Finland has own-label products or transport packaging that it uses under its own name manufactured in Finland, the manufacturer bears the producer responsibility for these types of packaging. However, the Regulation includes an exception for micro-enterprises, which do not bear producer responsibility for packaging they have manufactured.
Changes to the definition of a producer need to be taken into account when reporting 2026 packaging data
Companies need to take the changes to the definition of a producer into account when reporting their packaging data for 2026. The current definition of a producer will be applied until 11 August; from 12 August onward, packaging will be reported by the company that is the producer under the new definition.
According to Peltola, it is unfortunate that the definition is set to change in the middle of the reporting period.
There is also remarkably little time to prepare for the change, as the details of the definition of a producer still need to be clarified. An unclear definition increases the risk that packaging is not reported at all or that the same packaging is reported by several companies, says Peltola.
There will also be changes to the reporting requirements
The PPWR will also change the requirements for reporting packaging data. Under the Regulation, packaging placed on the market is reported under 22 packaging categories, 13 of which are plastic categories. The simplified reporting model will only be available for companies that place less than 10 tonnes of packaging on the market per year.
The date from which the new reporting requirements will apply has not yet been published, as it will depend on the date of publication of the implementing acts by the Commission. At the latest, the requirements will apply to the reporting of 2029 packaging data.