Service and grower packaging reported for the first time in January under the new model

Legislation that defines packaging producers changed at the beginning of 2024. The one-million-euro turnover threshold for packaging producer responsibility was removed, and responsibility for service and grower packaging is now covered by the manufacturers or importers of packaging. Previously, responsibility was covered by the company that filled the packaging. 

Ki-Sal tackled challenges with Rinki 

Ki-Sal Oy is a Finnish family business that has supplied high-quality packaging materials to its customers since 1977. The company supplies service packaging to a wide range of customers, including shops, restaurants, retailers and bakeries. Ki-Sal is a Sumi Oy customer. 

With the changes to the waste law, the instructions for reporting service packaging were clarified. 

“What we found the most difficult was the fact that some packaging may or may not be considered service packaging, depending on what the customer uses it for. Bakeries, for example, have producer responsibility for packaging that is used to pack products on the premises. Any packaging that is used for packing products for consumers directly at the point of sale is counted as service packaging, meaning that Ki-Sal has producer responsibility for it. This was not clear to us or our customers at first,” explains Karoliina Järvensivu, Marketing and Sustainability Manager at Ki-Sal. 

The reporting model took some studying, but once the issues were clarified in cooperation with Rinki, the model became very clear.  

The system was updated to support changes 

Ki-Sal’s ERP system was updated to ensure that reporting can be carried out according to the new model.  

“We defined what constitutes service packaging in the system and clarified who has producer responsibility for that packaging,” Järvensivu explains. 

“There was a lot to define, and what was particularly difficult is that not all packaging defined as service packaging is considered such from a reporting perspective. The same packaging could fall into two different reporting categories.” 

“At first it seemed clear what constituted service packaging, but then we realised that we also had to consider its use. The definition of service packaging depends on who uses the packaging and for what purpose,” Järvensivu explains. 

Accurate reporting initially required close cooperation with Rinki and careful investigation was needed to ensure all packaging was reported correctly.  

“We asked for a lot of help from Rinki, and it was very valuable. They clearly understood that this would be difficult initially,” Järvensivu praises. 

After the definitions were clarified, the focus was on communicating with customers to ensure that packaging was reported correctly according to the new model and that customers understood the reasons for changes in pricing.  

“Transparency is very important to us, which is why we explain the Rinki fees to our customers on our invoices,” says Järvensivu. 

The greatest challenge is knowing who is responsible for reporting 

Rinki has noticed that the most challenging aspect of the new reporting model has been identifying reporting responsibilities. The problem has been that packaging in itself does not necessarily help to define who is responsible for reporting it, but it is still necessary for identifying the use and the user. 

There are also difficulties in long supply chains in terms of identifying where a company falls in the production chain. If there are wholesalers and importers in the chain, it is not always easy to know who is responsible for reporting.  

“The reporting responsibility lies with the Finnish manufacturer or importer of the service and grower packaging who first introduces the packaging to the Finnish market,” explains Heidi Plattonen from Rinki. 

More service and grower packaging was reported than in the previous year 

The reporting process was largely successful, but Rinki’s inspections identified errors, which were corrected in collaboration with companies. 

“It’s great that large packaging manufacturers are alert and have understood the change. I believe that everything will run smoothly next year,” says Plattonen, who points out that service and grower packaging will be reported on the basic form with other types of packaging in the future, with the separate form for service and grower packaging no longer being used. 

According to statistics collected by Rinki, the amount of service and grower packaging reported last year increased by a third on the previous year. This was expected, since packaging supplied to small companies that were previously excluded from the statistics were included in the most recent reporting cycle. “We have a good understanding of the companies that should have reported service and grower packaging because we conducted our own internal investigation of companies last year,” says Plattonen. 

Rinki has also been careful to ensure that packaging is not reported twice, as this would increase the amount of packaging waste reported and thus lower the recycling rate. 

Service packaging is packaging used for packing food and other products directly for consumers at the point of sale. 

It includes, for example, bags offered or sold in stores to pack purchased products, bags for fruit and vegetables, all take-away packaging for food and drink, packaging for pastries sold loose and wrapping and bags used for packing vegetables or meat and fish products at the point of sale. Service packaging is filled at the same premises in which it is sold to the consumer (e.g. café or shop).