Packaging data for 2024 must be reported in January – Rinki’s specialist shares tips

The deadline for the annual reporting of packaging data is approaching. Companies with producer responsibility must submit their 2024 packaging data to Rinki in January.

Producers need to be aware that the deadline is now one month earlier than in previous years, 31 January. Many things remain the same, but there are some changes that need to be taken into account.

A change in the definition of ‘producer’ ended and created producer responsibility obligations

One of the biggest changes affecting the reporting process is the change in the definition of ‘packaging producer’. As of 1 January 2024, the turnover limit of one million euros was removed, and the producer of service and grower packaging is now the importer or manufacturer of the packaging in Finland.

This is the first year that companies that pack their products in service and grower packaging are not the ones to report these types of packaging. From now on, service and grower packaging must always be reported by the manufacturer in Finland or the company that imports it to Finland,” explains Jasmiina Myllys.

Manufacturers and importers of service and grower packaging are responsible for reporting such packaging on all the required declaration forms.

However, if the company that packs the product is also the manufacturer or importer of the packaging, the company’s producer responsibility obligation remains unchanged.

“If, for example, a café imports single-use cups to Finland and ‘packs’ coffee in the cups for customers, the café bears producer responsibility, because it is the importer of the service package, i.e. the cup,” explains Myllys.

The change means that some companies that only use service and grower packaging will no longer be subject to producer responsibility obligations and will not need to be part of the producer responsibility system for packaging.

Companies with a turnover of less than one million euros that joined this year, on the other hand, will have to report their packaging data for the first time. Tips for small companies regarding the reporting can be found on Rinki’s website.

Minor changes to the SUP declaration form

The basic declaration forms for packaging data, i.e. the light and detailed forms, will be the same as those used for reporting the 2023 packaging data, and the SUP declaration form remains almost the same.

The SUP declaration form is used to report certain types of single-use plastic packaging. A separate report for SUP packaging was introduced this year.

Certain types of SUP packaging must be specified in the report according to whether the packaging is made entirely or partly of plastic. In this year’s SUP reports, it was necessary to assess whether a specific type of SUP packaging was made entirely or partly of plastic for each part of the packaging. The instructions on the form for the reporting of SUP packaging data for 2024 will be amended so that the plastic content of packaging is assessed at the level of the entire packaging, taking into account all the components of the packaging. For example, a plastic yoghurt cup that has a metal lid is now classified as partly made of plastic on the basis of the entire packaging.

“The guidelines were changed so that it would be possible to obtain the data in the required format to monitor, for example, how well the targets for reducing the use of SUP packaging are met,” says Myllys.

Read more about SUP packaging and reporting in Rinki’s SUP databank.

Kilograms instead of tonnes and the introduction of a new reporting period

An important change is that the weight of packaging is now reported in kilograms instead of tonnes.

“The reason for this is that the removal of the million-euro turnover limit led to many small companies now being within the scope of producer responsibility, so it became necessary to be able to report small quantities of packaging,” explains Myllys.

Producers should be aware that there will be a new reporting and invoicing period for reporting 2025 packaging data, which will already affect the invoicing of 2024 packaging data. Due to the transition period, recycling fees will only be charged in certain cases on the basis of the 2024 data.

“The transition will give rise to an exceptional situation in which recycling fees will only be paid on the basis of the 2024 packaging data by companies with a turnover of less than one million euros that have joined the system as new customers and by manufacturers or importers of service and grower packaging for packaging that they now have producer responsibility for due to the change in the definition of a producer,” says Myllys.

For more information on the new reporting and invoicing period, please watch Rinki’s video (in Finnish).

Other companies have already paid their 2024 recycling fees in full based on the 2023 packaging data. SUP fees will be invoiced to all companies that have reported SUP packaging on the basis of the data reported for 2024.

Tips for smooth reporting of packaging data:

• All declaration forms must be returned to Rinki by the end of January, even if there is nothing to report.
• SUP packaging as well as service and grower packaging must also be reported on the basic declaration form.
• If you use the detailed declaration form, familiarise yourself with the difference between consumer and B2B packaging so that you can submit the data correctly.
• The light declaration form cannot be used to report any reuse of packaging. Reuse of packaging must be reported on the detailed declaration form. Packaging designed for reuse includes wooden pallets and steel roller cages. Reuse of packaging designed for single use is not reported at all.
• Reporting instructions can be found on the Rinki website. There is also a short video with instructions for each form to help with reporting.
• Rinki’s training sessions provide useful information about reporting. You can find the recordings of the previous training events on the Rinki extranet instructions page.
• Rinki’s business customer service team is happy to help you with issues related to producer responsibility.