What changes will there be to the definition of a packaging producer in 2024?

There will be changes to the annual turnover threshold for companies with producer responsibility for packaging and to the definition of a producer. The one-million-euro turnover threshold for producer responsibility will be removed, which means that an estimated 30,000 new companies will fall under the scope of producer responsibility. The definition of a producer of service and agricultural packaging will change so that the responsibility for reporting will pass to manufacturers and importers of packaging.

Producer responsibility for packaging has previously not applied to companies with a turnover of less than one million euros. This situation will change at the beginning of 2024, when the turnover limit is removed. An estimated 30,000 companies previously excluded from producer responsibility obligations will have to start paying for the recycling of the packaging of products they put on the market.

The definition of a producer will also change for service and agricultural packaging at the beginning of 2024. Service packaging refers to packaging used at the point of sale for packing food and other products. Shopping bags and packaging for take-away food are examples of service packaging. Agricultural packaging refers to packaging used for unprocessed agricultural or horticultural products intended for sale outside the farm, such as a box for strawberries.

The Finnish manufacturer or importer of such packaging will be considered to be the producer. With the new definition, the reporting obligations of some companies with producer responsibility will change. Producer responsibility obligations will be easier on companies that use service and agricultural packaging and heavier on manufacturers and importers of these types of packaging. For example, the producer or importer of service packaging – not the company that actually fills it – will be considered to be its producer. This means that the producer of a cup that comes with coffee purchased in a café or a paper bag for carrying a new pair of jeans will be the manufacturer or importer, not the company selling them, unless this company is also the manufacturer or importer.

The change to the definition of a producer will make it easier for companies that only use service or agricultural packaging, such as small shops and restaurants. The change will also reduce the number of companies with producer responsibility obligations and, consequently, the administrative burden related to the system.

Reform in line with European practices

In Finland, producer responsibility for packaging has been the only area of producer responsibility in which companies with a turnover of less than one million euros have not been obligated to pay any recycling fees. There has been no threshold for producer responsibility for tyres or waste from electrical and electronic equipment, for example. Removing the turnover limit will harmonise the practices related to producer responsibility obligations in Finland. Packaging producers will also be treated more equally as everyone will pay for their share of the recycling of packaging. The changes are based on the 2022 Waste Act reform.

The turnover limit for producer responsibility is not widely used in other European countries, and there is no justification for it in EU legislation.

Do you want to know more about the changes to producer responsibility? Rinki will keep companies informed – contact us!