Compliance Contributions Overview 2020 - EXPRA
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Contents Introduction .................................................................................................................................................. 2 1. Belgium: Fost Plus ..................................................................................................................................... 3 2. Belgium: VAL-I-PAC (responsible only for industrial and commercial packaging) .................................... 6 3. Bosnia and Herzegovina - Ekopak ............................................................................................................. 7 4. Bulgaria: ECOPACK .................................................................................................................................... 8 5. Canada: Éco Entreprises Québec .............................................................................................................. 9 6. Green Dot Cyprus .................................................................................................................................... 12 7. Czech Republic: EKO-KOM ...................................................................................................................... 13 8. Estonia: ETO ............................................................................................................................................ 16 9. Finland: FINISH PACKAGING RECYCLING RINKI LTD. ............................................................................... 17 10. Greece: HE.R.R.Co. ................................................................................................................................ 19 11. Hungary: ÖKO-Pannon .......................................................................................................................... 20 12. Italy: CONAI ......................................................................................................................................... 22 13. Israel: TAMIR ......................................................................................................................................... 23 14. Luxembourg: Valorlux ........................................................................................................................... 24 15. Macedonia: PAKOMAK d.o.o ................................................................................................................ 25 16. Malta: GreenPak ................................................................................................................................... 26 17. The Netherlands: Afvalfonds Verpakkingen ......................................................................................... 27 18. Norway: Grønt Punkt ............................................................................................................................ 30 19. Romania: ECO-ROM AMBALAJE ............................................................................................................ 32 20. Slovakia: ENVI-PAK ................................................................................................................................ 33 21. Slovenia: Slopak .................................................................................................................................... 34 22. Spain: ECOEMBALAJES ESPAÑA, S.A. (ECOEMBES) ............................................................................... 35 23. Spain: ECOVIDRIO ................................................................................................................................. 37 24. Sweden: FTI ........................................................................................................................................... 38 25. Turkey: CEVKO ...................................................................................................................................... 39 1
Introduction Every country has implemented the European Packaging Directive in a different way, inter alia putting different obligations to obliged industry. Therefore, the costs for compliance with obligations contain different factors affecting the cost levels which should be taken into account when comparing the relative costs of compliance across various European schemes. Key factors influencing relative compliance costs include the following: • Existing collection and recovery infrastructure in the waste management sector. • Packaging sources being used to meet national recycling quotas (household only or all packaging): household packaging waste is more expensive to collect and recover than packaging waste arising at industry’s back door. • Proportionate share of costs being borne by industry. This can be the full costs for collection, sorting and recovery of used packaging up to the so called additional costs for the separate collection and sorting. • Respective recycling quotas and the effect of derogations. • Collection systems used affect charges: bring systems are generally less expensive than door-to-door collection, but they usually collect less packaging. • Geographic location and population density: remote and sparsely populated regions will generally be more difficult and expensive to collect from. • Enforcement regimes influence costs; the more companies who participate in the scheme, the greater the spread of the cost base. • Labour costs and general overheads differ depending on the prevailing local economic conditions. Just recently, the new Waste Framework Directive introduced a number of changes, among which the concept of ‘EPR schemes’. Under their scope, eco-modulation has become an obligation to boost packaging recyclability under the general, minimum requirements outlined for these schemes. The new Waste Directive calls for the fees to be modulated, where possible, for individual products or groups of similar products. EXPRA is currently conducting a research on the various approaches that could be feasible and comparable, with a specific focus on the “product category”. A first assessment of this exercise shows that some compliance schemes have already moved onto introducing additional fee modulation. The latter generally follows an approach based on the “shared balance sheet according to the economic cost of packaging recyclability”. This document gives an overview of the current costs for compliance with the respective national recovery systems for packaging and packaging waste. All data have been sent to EXPRA by the respective systems (as of March 2020), and have been compiled to the best of our knowledge. Nevertheless, this information is subject to change at any time, especially in the light of the COVID 19 crises and we therefore cannot guarantee its accuracy and applicability to each type of packaging. We therefore kindly ask you to get in touch with the respective system of your country of operation to obtain the latest information relevant to you. Should you have any further question, please feel free to contact me via phone or e-mail. Best regards, Joachim Quoden Managing Director of EXPRA 2
1. Belgium: Fost Plus 2021 Compliance tariffs per material in EUR / kg: Materials Category Rate (EUR/kg) excl. VAT Recycled Glass 001 0,0499 Paper-cardboard (> 85%) 002 0,1189 Steel (> 50%) 003 0,2114 Aluminium (> 50% and > 5op) 004 0,0462 Beverage cartons 008 0,4453 PET - Bottles and flasks - Transparent colourless 005-01 0,2004 PET - Bottles and flasks - Transparent blue 005-02 0,3297 PET - Bottles and flasks - Transparent - other than colourless and blue 005-03 / 011-04 0,4706 PET - rigid packaging other than bottles and flasks - Transparent 011-05 1,1337 HDPE - Bottles, flasks and other rigid packaging 007 / 011-03 0,3647 PP - Bottles, flasks and other rigid packaging 011-01 0,4754 PS - Hard packaging, except for EPS 011-02 0,9968 PE - Films 011-07 0,9102 Other plastics - Films, except for compostable 011-09 0,9102 Valorised Composite materials in which paper-cardboard accounts for the greatest weight 012 1,1520 Aluminium smaller than 5op, non-composite 013 1,1520 PET - Bottles and flasks - Opaque 011-06 1,1520 Other plastics - Hard packaging, except for compostable plastics and 011-08 EPS 1,1520 Other plastic packaging - whether or not composite - where plastic accounts for the greatest weight, including compostable plastics and 014 1,1520 EPS Wood, cork, textile, ... 016 1,1520 Non-valorised Composite packaging in which glass accounts for the greatest weight 017 1,4400 3
Composite packaging in which steel accounts for the greatest weight 018 1,4400 Pottery, ceramics, porcelain, ... 019 1,4400 Hazardous household waste (HHW) Household packaging that must be sorted as HHW after use 1,1133 Obstructive packaging Household packaging that obstruct the collection, sorting or recycling 2,2674 How do you apply the Green Dot rates? General rules: ❖ All packaging elements must be declared based on their material category. Examples: ❖ Jam packaged in a glass jar with a label and a lid. The jar must be declared at the ‘glass 001’ rate, the label at ‘paper-cardboard 002’ and the lid at ‘steel 003’. ❖ Smartphone packaged in a cardboard box. The cardboard box should be declared as ‘paper-cardboard 002’. The charger and the earphones are each in a separate PE-bag with a paper label. These bags should be declared in the ‘PE films 01107’ category, the two labels in the ‘paper-cardboard 002’ category. ❖ Distinction between hard and soft packaging. a. Hard or rigid packaging will automatically return to its original shape after buckling. This includes bottles, flasks, containers, pots, trays and other blow-moulded or injection moulded plastic packaging. Hard packaging is usually comprised of dimensionally stable packaging which may or may not be combined with various packaging elements which can be separated from the actual packaging (e.g. label, cap, lid, sealing foil). b. Soft or flexible packaging is not rigid and buckles easily. It includes sacks, bags, envelopes, stand-up ppouches, removable sealing films, wrappers and similar flexible packaging articles. Soft or flexible packaging consists of one or more layers made of a variety of materials, including plastic film, paper, aluminium or a combination of these. The construction may be unprinted, printed, coated and/or laminated. ❖ Distinction is made between transparent versus opaque PET-packaging. a. With transparent PET packaging, its content is clearly visible through the material. b. With non-transparent or opaque PET-packaging, its content is not or barely visible through the material ❖ Distinction between colourless versus coloured transparent PET-bottles and flasks. a. Most transparent PET-bottles and flasks are colourless which means that they have not been coloured, eg by adding a colouring pigment b. The coloured transparent PET-bottles and flasks were coloured by the producer, eg by adding a colouring pigment. The transparent coloured PET-bottles are split in blue, green or other colours. The colour of the PET-bottle is best seen at the injection point (at the bottom of the bottle) or in the neck (on which the closures fit) ❖ The “Hazardous Household Waste” rate applies to the following household packaging that has to be sorted as HHW after use: : ❖ Packaging of paints, lacquers and varnishes ❖ Packaging of glues, silicones and resins ❖ Packaging of lubricating oils, fuels, engine oils and mineral oils ❖ Pesticide packaging (herbicides, insecticides, fungicides, ...) ❖ Disposable gas cylinders and metal aerosols, except for aerosols for cosmetics or food ❖ Packaging with compulsory child-resistant closure (CRC) 4
RECYCLED VALORISED • Glass (001): applies for bottles, flasks and jars in glass. • PET - Bottles and flasks - Opaque (011-06): applies This does not apply for packaging in Pyrex, crystal or for bottles and flasks in non-transparent PET. natural opal glass that contains more than 600 ppm • Other Plastics - Hard packaging, with exception of fluorine. EPS and compostable (011-08): applies for hard • Paper-cardboard (002): applies for all packaging ele- packaging elements consisting exclusively of plastic ments in paper-cardboard that consist of at least 85% that do not fall under the previous material paper fibre. categories. This includes e.g. non-transparent PET • Steel (003): applies for all packaging elements that con- trays and hard plastic packaging consisting of tain more than 50% steel. various types of polymers. • Aluminium (004): applies for all packaging elements that • Category 012 to 016: applies for all packaging contain more than 50% aluminium in weight and have a elements that do not fall under the application thickness greater than or equal to 50 p. conditions of the previous material categories, but • Drinks cartons (008): applies for any packaging element are valorised: in laminated cardboard - with or without a cap - that con- - 012: composite packaging in which paper- sists of cardboard/plastic/aluminium or cardboard accounts for the greatest weight cardboard/plastic, with a minimum of 50% paper fibre. (total paper fibre < 85%). This is usually used to package liquids, mainly dairy - 013: Packaging made of aluminium thinner than products and fruit juices. 50p. • PET - Bottles and flasks - Transparent, colourless (00501): - 014: Other packaging - whether or not applies for colourless bottles and flasks in transparent composite - where plastic accounts for the PET. greatest weight, eg • PET - Bottles and flasks - Transparent, blue (005-02): » Laminated plastic packaging with an applies for blue bottles and flasks in transparent PET. aluminium film • PET - Bottles and flasks - Transparent, green (005-03): » EPS (styrofoam), packaging from other types applies for green bottles and flasks in transparent PET. of plastic (eg PVC) and compostable plastics • PET - Bottles and flasks - Transparent - Other than - 016: Wood, cork, textile, ... colourless, blue or green (011-04): applies for bottles and flasks in transparent PET, with another colour than NON-VALORISED colourless, blue or green. • PET - Hard packaging other than bottles and flasks - • Category 017 to 019: applies for all packaging Transparent (011-05): applies for hard packaging ele- elements that do not fall under the application ments, other than bottles and flasks, which consists of conditions of the previous material categories: transparent thermoformed PET, like trays, cups and so - 017: Composite packaging in which glass on; note, this category does not apply for opaque accounts for the greatest weight, e.g. packaging thermoformed PET for which the category ‘011-08 in pyrex, crystal or opal glass that contains more Other plastics - hard packaging’ applies. than 600 ppm fluorine • HDPE - Bottles and flasks (007): applies for bottles, - 018: Composite packaging in which steel flasks and caps in HDPE. accounts for the greatest weight • HDPE - Hard packaging other than bottles and flasks - 019: Pottery, ceramics, porcelain, (011-03): applies for hard packaging elements other than bottles, flasks and caps, consisting of HDPE. • PP - Bottles, flasks and other hard packaging (011-01): applies for hard packaging elements consisting of PP, including bottles, flasks and caps. • PS - Hard packaging, with exception of EPS (011-02): applies for hard packaging elements consisting exclusiely of PS, except for EPS (styrofoam) for which INFO: the category ‘valorised 014’ applies. The contribution per packaging unit (as • PE - Films (011-07): applies for flexible packaging ele- described on 1 packaging file) amounts to ments of PE. at least EUR 0.000001. If the weight-based • Other Plastics - Films (011-09): applies for other flexible packaging elements consisting exclusively of plastic, contribution is lower, it will be increased to other than exclusively PE, except for compostable EUR 0.000001 plastic packaging and aluminium film laminated plastic, both for which the ‘valorised 014’ category applies. More information can be found here 5
2. Belgium: VAL-I-PAC (responsible only for industrial and commercial packaging) The annual charge per declaration type is calculated depending on: • the type of material which you put on to the market/for which you are responsible (e.g. plastic) • its properties (recyclable or not) • the amount of material (number of tonnes) Packaging material 2020 tariff per tone Recyclable cardboard 14,50 Recyclable metal 14,50 Recyclable wood 14,50 Recyclable glass 14,50 Recyclable natural fibers 14,50 Recyclable plastic 39,50 Recyclable plastic from the construction 49,50 industry Other recyclable materials 14,50 Non-recyclable materials (including non- 53,00 recyclable plastic) • this table refers to the cost of the declaration with effect from the year of membership (tariff as at 01.01.2020) • Retroactive membership A special retroactive fee is levied in the first year of membership. The VAL-I-PAC system is open to companies which wish to regularize their position with respect to the take-back and information obligation. VAL-I-PAC has to apply a retroactive membership fee for the five calendar years prior to the year of joining. The minimum funding contribution is 50 Euros per year (or 250 Euro for the retroactive membership fee for the five calendar years prior to the year of joining). 6
3. Bosnia and Herzegovina - Ekopak Packaging fees for 2020 Compliance Costs* Compliance Costs* Packaging material (BAM /ton) (€/ton) Glass 25 12,78 Metal 9,20 18 Paper 25 12,78 Plastic 35 17,89 Wood 16 8,18 Multilayer, and/or other materials 30 15,33 Packaging containing and /or 34 17,38 contaminated by hazardous materials * VAT 17% is not included 1 EUR = 1,95583 BAM Note: Clients of Ekopak can reduce costs up to 15% through the loyalty program. 7
4. Bulgaria: ECOPACK 2020 After 10% After additional discount for 20% discount for Base timely report timely payment Material Compliance cost submission (15th day of the (25th day of the month) month) Plastics 0.137 0.123 0.099 Paper and Cardboard 0.145 0.1305 0.104 Glass 0.165 0.1485 0.119 Metals 0.041 0.037 0.0295 Aluminum 0.089 0.080 0.064 Composites 0.194 0.175 0.140 Wood 0.098 0.088 0.071 Others 0.259 0.233 0.186 Fees are in BGN, per kilogram, excluding VAT Indicated fee discounts apply only for reported quantities in excess of 10 tons per annum. Minimum annual fee for 1 obliged company BGN 150, excluding VAT EUR 1 = BGN 1,95583 8
5. Canada: Éco Entreprises Québec Schedule 2019 Reference Year : 2018 CLASS and Material ($/tonne) PRINTED MATTER Newsprint inserts and circulars printed on news paper 203,74 Catalogues and publications 293,65 Magazines 293,65 Telephone books 293,65 Paper for general use 293,65 Other printed matter 293,65 TOTAL - PRINTED MATTER 234,15 CONTAINERS AND PACKAGING Paperboard • Corrugated cardboard 182,70 $ • Kraft paper shopping bags and paper packaging 182,70 $ • Boxboard / Other paper packaging 200,23 $ • Gable-top containers 190,50 $ • Paper laminants 286,73 $ • Aseptic containers 233,71 $ TOTAL - Paperboard 201,06 Plastic • PET bottles 283,38 • HDPE bottles 108,44 • Plastic laminants 471,46 • HDPE and LDPE plastic film 471,46 • HDPE and LDPE plastic shopping bags 471,46 • Expanded polystyrene food 789,39 • Expanded polystyrene protection 789,39 • Non-expanded polystyrene 789,39 • PET containers 283,38 • PVC, Polylactic acid (PLA) and other degradable plastics 789,39 • Other plastics, polymers and polyurethane 286,18 TOTAL - Plastic 357,19 Aluminium • Aluminium containers for food and beverages 179,87 • Other aluminium containers and packaging 179,87 TOTAL - Aluminium 179,87 Steel • Steel aerosol containers 171,61 • Other steel containers 171,61 TOTAL - Steel 171,61 Glass • Clear glass 172,18 • Coloured glass 172,26 TOTAL - Glass 172,23 9
TOTAL - CONTAINERS AND PACKAGING 236,99 TOTAL 236,37 $1.4503CAN = 1 EURO (Bank of Canada – 2020-01-03) * For the calculation of the contribution for the 2019 Obligation Year, the Targeted Persons must declare the materials that were marketed in Québec for the twelve (12) months comprised between January 1st and December 31st of the Reference Year, which is 2018. * A credit of 20% for the payable contribution is granted to Targeted Persons that generate materials of which the percentage (%) of recycled post-consumer content reaches or exceeds the established benchmark, when the Materials report is submitted within the prescribed delays. The credit is granted by way of a distinct invoice that is issued in the year following the deadline to submit the Materials report. The appropriate documentation and samples to determine the content of post-consumer recycled material must be provided to Éco Entreprises Québec before the first deadline date to pay the contribution. The content of the recycled material is an element which is taken into consideration when calculating the payable contribution pursuant to section 53.31.14, paragraph 2 of the Environment Quality Act. Options to facilitate compliance with small companies and low volume producers The following table presents the flat fees for the 2019 Schedule of Contributions : Options for low-volume producers 2019 Schedule Rates 1 to ≤2.5 tonnes $450 Based on tonnage >2.5 to ≤5 tonnes $945 >5 to ≤10 tonnes $1885 >10 to ≤15 tonnes $3150 ≤ $1 M $0 Based on sales >$1 M to ≤ $2 M $3150 Based on the number of points of = 1 point of retail service
* For the calculation of the contribution for the 2018 Obligation Year, the Targeted Persons must declare the materials that were marketed in Québec for the twelve (12) months comprised between January 1st and December 31st of the Reference Year, which is 2017. * A credit of 20% for the payable contribution is granted to Targeted Persons that generate materials of which the percentage (%) of recycled post-consumer content reaches or exceeds the established benchmark, when the Materials report is submitted within the prescribed delays. The credit is granted by way of a distinct invoice that is issued in the year following the deadline to submit the Materials report. The appropriate documentation and samples to determine the content of post-consumer recycled material must be provided to Éco Entreprises Québec before the first deadline date to pay the contribution. The content of the recycled material is an element which is taken into consideration when calculating the payable contribution pursuant to section 53.31.14, paragraph 2 of the Environment Quality Act. Options to facilitate compliance with small companies and low volume producers The following table presents the flat fees for the 2018 Schedule of Contributions: Options for low-volume producers 2018 Schedule Rates 1 to ≤2.5 tonnes $420 Based on tonnage >2.5 to ≤5 tonnes $890 >5 to ≤10 tonnes $1775 >10 to ≤15 tonnes $2965 ≤ $1 M $0 Based on sales >$1 M to ≤ $2 M $2965 Based on the number of points of = 1 point of retail service $0 retail service Targeted Persons To be considered as a targeted person, a company should meet the following three criteria: • It generates containers, packaging and/or printed matter ultimately intended for Quebec consumers; • It has a place of business or an establishment in Quebec; • It is the owner of a brand, a name or a distinguishing guise. However, if the owner has no domicile or establishment in Québec, the first supplier in Québec of the products, or the containers and packaging, or of the printed matter, other than the manufacturer, may be required to pay the contribution, whether or not that supplier is the importer. Éco Entreprises Québec may accept that a third party whose domicile or establishment is outside Québec and who is the owner of a brand, a name or a distinguishing guise becomes a voluntary contributor. A third party may be recognized as a voluntary contributor after having concluded an agreement with Éco Entreprises Québec to this effect. 11
6. Green Dot Cyprus Material EUR per tonne Household Packaging 2013 Glass 27,61 Carton 44,78 Metal 90, 62 Aluminium 20,31 PET 100,60 HDPE 100,60 Cardboard Liquid Containers 116,61 Other reusable 124,50 Other non-reusable 149,41 Commercial/Industrial Packaging Corrugated carton 41,14 Plastic 36,04 Wood 11,80 Other 47,70 12
7. Czech Republic: EKO-KOM Remuneration structure for ensuring compliance with the obligation to return and recovery of packaging waste through the EKO-KOM Reusable packaging1 One-way packaging2 Valid from 1.1.2020 CZK/t EUR/t* CZK/t EUR/t* Soft plastics 0,00 0,00 5 848 224,92 Rigid plastics 0,00 0,00 5 848 224,92 Rigid plastics above 5L 0,00 0,00 4 386 168,69 Corrugated board 0,00 0,00 2 426 93,31 Paper 0,00 0,00 2 586 99,46 Sales packaging Glass 0,00 0,00 1 930 74,23 Metals Fe 0,00 0,00 2 004 77,08 Metals Al 0,00 0,00 2 666 102,54 Metals above 5L 0,00 0,00 1 106 42,54 Beverage cartons 0,00 0,00 4 478 172,23 Combined materials 0,00 0,00 6 346 244,08 Wood 0,00 0,00 1 199 46,12 Textile 0,00 0,00 1 199 46,12 Others 0,00 0,00 6 346 244,08 Plastics 0,00 0,00 632 24,31 Corrugated board 0,00 0,00 326 12,54 Group packaging Paper 0,00 0,00 326 12,54 Metals Fe 0,00 0,00 542 20,85 Metals Al 0,00 0,00 542 20,85 Combined materials 0,00 0,00 632 24,31 Wood 0,00 0,00 343 13,19 Textile 0,00 0,00 343 13,19 Others 0,00 0,00 632 24,31 Plastics 0,00 0,00 632 24,31 Corrugated board 0,00 0,00 326 12,54 packaging Transport Paper 0,00 0,00 326 12,54 Metals Fe 0,00 0,00 542 20,85 Metals Al 0,00 0,00 542 20,85 Combined materials 0,00 0,00 632 24,31 1 4 Reusable packaging, to meet § 13 Article 2 of Act No. 477/2001 Coll., as amended by later regulations 2 Packaging which does not meet § 13 Article 2 of Act No. 477/2001 Coll., as amended by later regulations. * Payments are made in CZK. Exchange rate of January, 2020 is: 1 EUR ~ 26 CZK 13
Wood 0,00 0,00 343 13,19 Textile 0,00 0,00 343 13,19 Others 0,00 0,00 632 24,31 Plastics 0,00 0,00 632 24,31 Corrugated board 0,00 0,00 326 12,54 Industrial packaging Paper 0,00 0,00 326 12,54 Glass 0,00 0,00 1 930 74,23 Metals Fe 0,00 0,00 542 20,85 Metals Al 0,00 0,00 542 20,85 Combined materials 0,00 0,00 632 24,31 Wood 0,00 0,00 343 13,19 Textile 0,00 0,00 343 13,19 Others 0,00 0,00 632 24,31 Compliance cost discount based on the Article VI., Paragraph 7 500 19,23 of the Contract Compliance costonunder Collective Compliance the Agreement on(per year) Comprehensive 1 600 61,54 Fulfilment of Part III., Article VI, valid from 1.1. 2011 (per year) Compliance cost for registration in the system of collective compliance 1) Reusable packaging, to meet § 13 Article 2 of Act No. 477/2001 Coll., as amended by later regulations 2) Packaging which does not meet § 13 Article 2 of Act No. 477/2001 Coll., as amended by later regulations *) Payment are paying in CZK. Exchange rate of 2020 is: 1 EUR ~ 26 CZK !!! The fees in EUR are just for information!!! DEFINITION: One-way packaging Packaging which do not meet the requirements of the Section 13, article No. 2 of Act No. 477/2001 Col. as amended by later regulations e.g. package for milk, juice, biscuits). Reusable packaging Packaging which meet the requirements of the Section 13, article No. 2 of Act No. 477/2001 Col. as amended by later regulations. It is the packaging which executes a specific minimal number of rotations or cycles during its lifecycle; it is re-filled or re-used. That definition is met, for example, by palette, a plastic container, a beer bottle, a gas bottle, etc. The difference between soft plastic packaging and rigid plastic packaging The group of solid hollow plastic comprises all plastic beverage packaging (for example, PET bottles). It also includes blown detergent bottles, fabric softener bottles, etc. The group of soft packaging comprises all the types of packing foils, bags and very light packaging. Combined materials In case of packaging which consists of a few parts of various materials it is problematic to weight those components accurately; (that applies, for example, to a glass bottle metal cap, an aluminium aerosol can metal cap, a paper label, a self-adhesive label on packaging, plastic cap, etc.). The §48 of the Packaging Act specifies that in case of record- keeping in accordance with the §15 of the Act packaging containing one type of specific material which represents at least 70 per cent of the packaging weight is viewed as one material packaging. Therefore, for example, a glass bottle + a metal cap + a paper label are viewed for those purposes as consumer packaging of one material - glass. 14
Similarly, in case of an aerosol can, an aluminium container + a metal cap + a plastic pressure sprayer + a plastic cap + a vinyl self-adhesive label are viewed for those purposes as consumer packaging made of aluminium (providing, aluminium represents more than 70 per cent of the total weight). In case of a big production firm it is possible and correct to report those items separately. In the case that any part of the package does not exceed 70% by weight, it is necessary to cover in the statement included in the box combined materials. The same box can be placed on the packaging and combined materials (packaging of the components made of different materials that cannot be manually separated from each other) as packaging for fresh butter (aluminium foil, paper) cups for dairy products (paper, plastic film) or blister from drugs. 15
8. Estonia: ETO Compliance costs for of ETO, 2020 € per kg € per kg Material Bundling and commercial transport Plastics 0.102 0.093 Cardboard 0.105 0.109 Glass 0.409 0.128 Metal 0.255 0.041 Wood 0.041 0.093 Other 0.102 0.109 VAT will be added to the service fees in amount of 20%. Reusable packaging is not charged as long as being in reuse. For further details please contact eto@eto.ee or visit eto.ee. 16
9. Finland: FINISH PACKAGING RECYCLING RINKI LTD. RINKI LTD’S REGISTRATION AND CUSTOMER FEES The customer fee invoicing will be based on the price list and the packaging quantities the company used the previous year. There will be no registration fee in 2020. Fee type Fee * Unit Customer fee 1.60 €/ton Customer fee, minimum 265 €/year/contract Customer fee, maximum 4 500 €/year/contract Registration fee 0 €/company *) Value added tax is added to the fees. RECYCLING FEES FOR PACKAGING The company’s material-specific recycling fees in 2020 are based on the 2020 recycling fees below, as well as the company’s 2019 packaging volumes. MATERIAL Recycling fee * €/ton FIBRE Corrugated cardboard packaging for 9.50 consumers Corrugated cardboard packaging for 9.50 firms Industrial wrapping and sacks 14.00 Industrial cores 14.00 Carton and paper packaging 49.50 Carton liquid packaging 105.00 PLASTIC Plastic packaging for consumers: Conventional plastic packaging ** 119.00 Biodegradable plastic packaging 119.00 Conventional shopping bags ** 119.00 Biodegradable shopping bags 119.00 Conventional small bags ** 119.00 Biodegradable small bags 119.00 Plastic packaging for firms 54.00 METAL Aluminium packaging for consumers 126.00 Aluminium packaging for firms 26.00 Tinplate packaging for consumers 126.00 Tinplate packaging for firms 26.00 Steel packaging 26.00 GLASS Glass packaging (non-deposit) 98.0 WOOD FIN pallets (stamped 100 x 120 cm) 1.45 EUR/EPAL pallets (stamped 80 x 120 1.45 cm) Rental pallets 1.45 17
Other wooden pallets 1.90 Cable reels 1.45 Other wooden packaging 1.90 OTHER Other packaging - *) Value added tax is added to the fees. **) Conventional plastic packaging refers to non-biodegradable plastic packaging, including bio-based plastic packaging that is not biodegradable. If a company is invoiced a material-specific recycling fee of more than EUR 10,000, RINKI will invoice it in two equal instalments at the same time so that the second one is due four months after the first but not later than October 2020 Late declaration fee and estimate-based invoice for packaging data According to the terms of contract, companies must report to RINKI Ltd annually the packaging materials and quantities that they have used to pack their products and placed on the market or imported together with its products. The 2019 packaging data must be submitted by 29 February 2020. Reporting the packaging data is essential for the producer responsibility system to work as it directly affects the system's financing, invoicing and operations. If a company submits the 2019 data after 29 February 2020, RINKI Ltd will collect a fee for the late declaration. The fee is EUR 200 (+VAT) for each delayed month or part thereof and it will be charged for a maximum of three months If the company has not submitted the 2019 packaging data by the end of May 2020, RINKI Ltd will invoice the late declaration fee as well as estimate-based customer and recycling fees, which will be based on the packaging data available to RINKI Ltd. 18
10. Greece: HE.R.R.Co. Monetary contributions for 2020 Contributions € cents per unit Fixed contribution 0.04 Contribution by weight (€/tonne) Cardboard & paper 52.50 Paper cartons for liquids 57.00 Plastics 66.00 Aluminium 8.80 Metal 21.00 Glass 10.90 Wood 9.50 Other 66.00 *The above prices do not include VAT Financial contribution calculation rules 1. All the material constituting the manager’s consumption packaging is charged based on the weight depending on the price of their material according to the monetary contribution tables hereof (contribution by weight). The consumption packaging articles are charged as a total with one more fixed contribution according to the monetary contributions tables (Annex B1) hereof (fixed contribution). 2. All the material constituting the other packages is charged by weight based on the price of their material according to the monetary contributions tables hereof (fixed contribution). Every component per unit of other packaging is charged with one more fixed contribution according to the monetary contribution table hereof (fixed contribution). 3. The glues, the adhesive tapes, the tax tapes, the metal connections that are part of a packaging (e.g. a carton) and the user booklets or manuals are not considered packaging components. 4. The total contribution of a packaging is the aggregate of the contributions by weight of the material that constitute all packaging (consumption & other packaging) plus the proportionate fixed contributions by applying the previous rules. 19
11. Hungary: ÖKO-Pannon According to the legislations in Hungary all companies are obliged to pay an environmental tax (official name: environmental product charge) to the National Tax and Customs Administration (abbreviated Hungarian name: NAV). The object of the charge is the packaging material instead of the packaging and therefore packers are directly not subject of the law for domestic products. In case of products produced abroad the importer company is responsible for the charge, i.e. the company who imports, and sells the product in Hungary at the first time (with the first HU-VAT Nr. invoice), or uses it for their own purposes. Green Dot trademark - Isolated use of the Green Dot trademark Our company provides the legal usage of Green Dot trademark for producers, importers and retailers as well. We offer 2 types of contract: 1. If the company has little amounts of packaging, it is reasonable to choose a simplified contract. In this case the Licensee shall send the Licensor a packaging emission report once a year and pay 0.5 HUF/kg by the amount of the packaging emission. 2. The normal contract provides possibility to choose from 2 types of payment: • 0.5 HUF/kg by the amount of the packaging emission quarterly. • according to categories presented in the following chart: Annual amount of the packaging Annual fee Packaging category emission above 10,000,000 kg HUF 3,000,000 A between 5,000,000 – 10,000,000 kg HUF 2,000,000 B between 3,000,000 – 4,999,999 kg HUF 1,000,000 C between 1,000,000 – 2,999,999 kg HUF 500,000 D Services of ÖKO-Pannon Consultancy service Due to a legislation of environmental product charge put into force in January 2012, ÖKO-Pannon Plc. has launched consultancy service on compliance with actual environmental product charge and waste law for packaging emitters. 20
• Notification obligation • Environmental product charge declaration • Environmental product charge refund process • Providing the use of Green Dot trademark • Optimization consultancy with relation to products liable to product charge (packaging, WEE – electric and electronic waste, battery, tyre, advertisement paper) including: o interpretation and use of laws in force regulating product charge with consideration to the company’s range of products o classification of packaging materials o creating the system of taking over the liabilities o forming the textual content of invoices (incoming, outgoing) o classification of product packaging into the proper product charge category o updating background administration in accordance with new laws o preparing reports to NAV (National Tax and Customs Administration) o review of NAV reports both in terms of running year and previous years o continuous availability o on-site consultancy o petition of stance from NAV • Consultancy on individual exemption and coordination • Preparing for compliance with the actual law on waste management • Preparing for compliance with the packaging regulation • Supervision related to the fulfilment of recovery and recycling obligation and product charge reports • Consultancy in the field of fulfilment of international recovery and recycling obligation (sending in contracts and reports) • Packaging or not packaging – providing professional opinion according to the laws in force 21
12. Italy: CONAI Environmental Contribution for Packaging – 2020 Material Compliance cost (EUR/tonne) 3,00 €/t Steel 15,00 €/t Aluminium 35,00 €/t 55,00 €/t for poly-laminated packaging Paper with a prevalence of carton suitable for containing liquids 9,00 €/ton Wood Level A: 150,00 €/t Level B1: 208,00 €/t Plastic Level B2: 436,00 €/t Level C: 546,00 €/t 27,00 €/t Glass Full details link: http://www.conai.org/en/businesses/environmental-contribution/ 22
13. Israel: TAMIR Financial contribution tariff per material 2020: NIS per tonne NIS per tonne Material household commercial Glass 280 40 Cardboard &Paper 178 139 Drinking Carton 210 40 PET 423 84 HDPE 448 84 LDPE 474 84 PP 584 84 PS 782 84 Other plastic/material 782 84 Metal 210 55 Wood 31 31 1 Euro=4 NIS 23
14. Luxembourg: Valorlux Material Compliance contribution 2020 (EUR/kg.) Glass (bottles and jars) 0,0137 Paper / cardboard 0,0441 Steel 0,0206 Aluminium 0,0246 PET bottles 0,3245 HDPE bottles 0,2397 Beverage cartons 0,3055 Other recoverable products 0,6297 Other non-recoverable products 0,7186 Contribution for commercial packaging in 2020 €/kg HTVA The fees for the commercial packaging remain unchanged. Commercial Paper/Cardboard 0,0145 Commercial Wood 0,0145 Commercial Others 0,0395 24
15. Republic of North Macedonia: PAKOMAK d.o.o The compliance costs for the companies responsible in Macedonia are presented in the table below: Compliance Contributions 2019 in EUR/tonne Packaging Material 1 Paper/cardboard 18.75 2 Plastics 22.76 3 Glass 20.39 4 Metal 21.42 5 Composite materials 22.66 6 Wood 21.84 *1 EUR = 61,6 denars. * Fees are calculated without 5% VAT . In case of devaluation, PAKOMAK DOO reserves the right for adequate correction of the exchange rate of EURO. es for obligated companies in Macedonia Green Dot fees 2019 in EUR/ton Type of packaging waste 1 Paper/Cardboard 2.53 2 Plastic 4.88 3 Glass 1.83 4 Metal 3.45 5 Aluminium 3.45 6 Composite materials 5.36 7 Wood 1.63 1 EUR = 61,6 denars. * Fees are calculated without 5% VAT 25
16. Malta: GreenPak The membership Compliance Costs for the year 2020 are presented below: Material iFees €/metric tonne Plastics 67,95 packaging Transport Paper/Cardboard Store & 67,95 61.20 Metals 61.20 27.00 27.00 Wood 65,70 Other 72,00 Plastics 99,00 Paper and Cardboard 75,60 Consumer Packaging Glass 110,00 106.00 Metals 106.00 58.50 58.50 Wood 73,80 Other 135,00 *Fees are excluding VAT and are calculated to the nearest 100kgs (0.1 metric ton) Notes: a) Fee is calculated to the nearest 100kgs (0.1 metric tonnes). b) Fees are applicable from 1st January 2020. c) Above fees are exclusive of VAT. d) Minimum charge is €150 (incl. ERA registration + VAT). Payment Terms Yearly Participation Fee excl VAT Payment terms € 150 to € 2,500 On invoice € 2,501 to € 12,000 50% on invoice, 50% by 1st July € 12,001 to € 46,000 4 pro-rata quarterly payments due 1st week of each quarter. € 46,001 and over 12 pro-rata monthly payments due 1st week of each month. More information on the Payment Terms you can find here: 26
17. The Netherlands: Afvalfonds Verpakkingen The following companies are responsible for registering and contributing to the system: Regular producer/importers of packed products This is the first Dutch company who: 1°. places substances, preparations or other products on the market in a packaging; and/or 2°. commercially imports substances, preparations or other products in a packaging and disposes of the packaging; and/or 3°. commercially instructs another to provide the packaging of substances, preparations or other products with its name, logo or brand; and/or 4°. places a packaging on the market which is intended to be added to substances, added to substances, preparations or other products to be provided to the user; Foreign distance sellers (e.g. online sales) Foreign companies that fulfil the functions as described above, but do so by selling directly to a private consumer (i.e. not to a company). In cases where foreign companies sell packed products to Dutch companies, the Dutch company is seen as the obliged company. The packaging waste management compliance costs in 2020 are listed below: Material Fee 2019 (€/kg) ex. VAT Glass 0.0560 Paper/Cardboard 0.0220 Plastics (including biodegradable plastics) 0.6000 Plastics, differentiated fee (only upon request) 0.3400 * Aluminium 0.0500 Other metals 0.0800 Wood 0.0200 Other materials 0.0200 27
General fee (company can’t or doesn’t want to specify the material) 0.7700 Beverage cartons 0.3800 Bottles in a deposit system 0,0200 Plastic bottles > 0.75 l that do not take part in the mandatory deposit € 0.25 per bottle scheme The fees are calculated based on the principle of activity-based costing. This means that the most recent historical costs of expenses of collection and sorting of packaging waste, including the management of the organisation, are taken into account. Lower fees for certain commercial/industrial packaging Companies who are mainly active in a b2b-environment may be entitled to apply lower fees. Please contact us at info@afvalfondsverpakkingen.nl for the possibilities. Differentiated / modulated fee There is a modulated fee for rigid plastics that are recyclable and that have a positive market value at the point of sale to the recycler. The fee can only be applied upon request and is liable to the evaluation of Afvalfonds Verpakkingen. In the process of evaluation, the Recycle Check, developed by Kennisinstituut Duurzaam Verpakken, will be used. More information about the differentiated fee can be found (in Dutch) on https://afvalfondsverpakkingen.nl/verpakkingen/gedifferentieerd-tarief. Composite packaging Composite packaging is packaging that consists of several, non-separable types of materials (for example laminates). The obliged company must pay the Packaging Waste Management Contribution on the various types of material of which the composite packaging consists and declare these material types separately on the Provisional Statement and Declaration. Packaging components Packaging components and ancillary elements integrated into packaging shall be considered to be part of the packaging into which they are integrated. Ancillary elements hung directly on, or attached to, a product and which perform a packaging function shall be considered to be packaging unless they are an integral part of this product and all elements are intended to be consumed or disposed of together. Reporting threshold Only companies that place 50,000 kg or more on the Dutch market in a calendar year are obliged to register and pay the according packaging fees. For the first 50,000 kg, companies are not invoiced. Please be aware that companies should provide documented proof that they place less than 50,000 kg of packaging on the Dutch market, if they claim so. For companies that place less than 50,000 kg packaging on the Dutch market, Afvalfonds Verpakkingen investigates the weight of “packaging on the market” by means of market research. Financing The financing of EPR for packaging in the Netherlands is executed by Afvalfonds Verpakkingen, who is responsible for the organization and reaching recycling targets and who delegates certain operational tasks to Nedvang. Because of a binding agreement between Afvalfonds Verpakkingen 28
and the vast majority of obliged companies, all obliged companies with more than 50.000 kg of packaging put on the market have to register with Afvalfonds Verpakkingen and pay for the organization of EPR for packaging. This payment is called the packaging waste management contribution. All packaging, including packaging from companies and industry, is included in the Dutch EPR scheme. The budget is spent on the following items: • Control of the companies’ declarations of packaging on the market • Identification of additional customers / free riders • Estimate of the weight of packaging put on the market by companies that put less than 50.000 kg. per year on the market on an individual basis • Estimate of the weight of transport packaging put on the market • Cooperation with municipalities and waste management companies to gather data on collection and recycling of packaging waste • Communication to enhance the collection and recycling of packaging waste • Calculation and reporting of recycling rates • Logistics, sorting and sale of plastic packaging waste from households • Structural contribution to a clean and litter free environment • Financing of an independent and neutral organization to gather knowledge on packaging waste management and sustainability. 29
18. Norway: Grønt Punkt LICENSE FEES FROM GR0NT PUNKT NORGE AS FOR 2020 Changes in bold print Prices in NOK Plastic Packaging 01.01.2020 01.02.2020 Plastic film with producer payment 0,50 kr per kg 0,50 kr per kg Expanded plastic (Airpop, EPS, EPX etc.) 2,20 kr per kg 2,20 kr per kg Industrial packaging: Hard plastic and packaging for chemicals and hazardous substanses 1,36 kr per kg 1,82 kr per kg Polypropene (bag and liner) 0,84 kr per kg 1,13 kr per kg Silage film , clear polyethylene film with thickness of 70 ^ (mu) 2,43 kr per kg 1,56 kr per kg Other agricultural films (mulch, nonwovens and nets) 4,00 kr per kg 4,00 kr per kg Household packaging (f.pak) and service packaging: Film 1,38 kr per kg 1,85 kr per kg Hard plastic, packaging for chemicals and hazardous substanses and polypropene bag 1,38 kr per kg 1,85 kr per kg Other service packaging 1,38 kr per kg 1,85 kr per kg Gardening and agricultural packaging 1,38 kr per kg 1,85 kr per kg Carrier bags under 10 liter 0,0138 kr each 0,0185 kr each Carrier bags over 10 liter 0,0253 kr each 0,0339 kr each Packaging with environmental tax: Film, e.g. stand-up pouches, bag in box, bottles 1,38 kr per kg 1,85 kr per kg Fibre based Packaging Cardboard packaging base weight > 150 gr/m2 0,29 kr per kg 0,29 kr per kg Moulded fibre packaging for eggs etc. 0,29 kr per kg 0,29 kr per kg All Liquid board packaging containers 0,030 kr each 0,030 kr each Corrugated board and solid board > 600 gr/m2 0,05 kr per kg 0,05 kr per kg Glass Packaging containers Packaging without environment tax Volume 0 - 250 ml 0,099 kr each 0,099 kr each Volume 251 - 500 ml 0,198 kr each 0,198 kr each Volume over 500 ml 0,296 kr each 0,296 kr each Packaging with environment tax Volume 0 - 250 ml 0,138 kr each 0,138 kr each Volume 251 - 500 ml 0,276 kr each 0,276 kr each Volume over 500 ml 0,413 kr each 0,413 kr each Metal Packaging containers 30
Volume 0 - 250 ml can/tin 0,058 kr each 0,055 kr each Volume 251 - 500 ml can/tin 0,130 kr each 0,124 kr each Volume over 500 ml can/tin 0,219 kr each 0,208 kr each Tubes 0,064 kr each 0,061 kr each Table serving item 0,016 kr each 0,015 kr each Aluminiumform 0 - 500 ml 0,064 kr each 0,061 kr each Aluminiumform > 500 ml 0,143 kr each 0,136 kr each Lids 0,011 kr each 0,010 kr each Crown cork 0,004 kr each 0,004 kr each Packaging with environment tax Volume 0-250 ml 0,058 kr each 0,055 kr each Volume 251 - 500 ml 0,130 kr each 0,124 kr each Volume over 500 ml 0,219 kr each 0,208 kr each Hazardous waste Hazardous contents 0 - 1,0 liter 0,281 kr each 0,267 kr each Hazardous contents 1,0 - 9,9 litres 0,732 kr each 0,695 kr each Hazardous contents 10 litres 1,591 kr each 1,511 kr each Hazardous contents > 10 litres 3,379 kr each 3,210 kr each Members with packaging use corresponding to up to NOK 5.000 per year pay a fixed annual amount of NOK 3.000 without reporting packaging amounts. VAT is added to all license fees. Financing The costs of running the collection and recovery schemes are covered by the compliance costs paid by Green Dot Norway's members, which depends on the pro rata consumption declared per period. The fee is then distributed to the five material companies. Depending on the member companies’ packaging use, they submit a form to Grønt Punkt Norge six, four or once a year. Green Dot Norway is a non-profit organisation owned by five material companies. About the figures: • VAT not included; • EUR 1 = NOK 10.54 (2020) • NOK 1 = 100 øre 31
19. Romania: ECO-ROM AMBALAJE Recycling and Recovery Fees 2020 The national legislation transposing the European Directive for Packaging and Packaging Waste stipulates that the recovery and recycling objectives pertain to the entire quantity of packaging placed on the market by the obliged industry, regardless of the waste stream (i.e. household/municipal or the industrial-commercial sector), for which distinct targets are yet to be set. However, as of January 2019 the EPR schemes (PROs) have to calculate and publicly disclose distinct fees for the obliged industry for the primary packaging, on one hand, and secondary and tertiary packaging, on the other hand. The quantities declared to PROs are exclusively based on the monthly declaration of the obliged industry related to packaging placed on the market during the previous month. For the packaging waste generated in the household/municipal waste stream, PROs are obliged to cover the net costs incurred by delegated operators (municipal or private) related to separate collection, transfer, sorting and recovery (if recycling is not possible), while the industrial-commercial waste stream is still market-driven by the demand-supply mechanism. Rate in euro/ton* for Rate in euro/ton* for Type of material industrial-commercial household/municipal packaging packaging Glass 99 115 PET 147 164 PE 105 115 PVC 105 115 Plastic PP 105 115 PS 105 115 Other 105 115 Paper-cardboard 84 94 Steel 89 94 Aluminium 147 173 Wood 89 94 *prices do not include VAT and were calculated for an average currency exchange rate of 4.775 lei/euro 32
20. Slovakia: ENVI-PAK The price for ENVI-PAK´s compliance costs are based on t h e weight and material type of packaging. The materials are separated in 10 types: • Glass • Plastics PET • Other plastics besides PET • Paper / Cardboard • Composite beverage carton • Miscellaneous composites • Metals aluminium • Metals steel • Wood • Other packaging materials In determining the fee, the packaging must first be separated into all its parts, sorted by fractions. The weight, multiplied by the price for each material is the fee for the participation in our packaging recovery system. Prices can be ordered upon request. Interested companies can order an offer via the customer portal. There is no payment connected with the registration into the ENVI-PAK system. 33
21. Slovenia: Slopak PACKAGING FEES 2020 PACKAGING MATERIALS PACKAGING FEE EUR/tonne (VAT not included) GLASS Glass 19,00 PAPER Paper Sales 17,00 Paper Group and transport 17,00 PLASTICS Plastics Sales 249,00 Plastics Sales PET 185,00 Plastics Group and transport 249,00 Plastics PVC 249,00 METAL Metal Aluminium 175,00 Metal Steel 219,00 WOOD Wood 39,00 OTHER MATERIALS Other materials Textile, Straw 249,00 Other materials Non-recyclable 249,00 COMPOSED MATERIALS Composed materials with predominant paper 17,00 Composed materials with predominant plastic 249,00 Multi-layered beverage carton 9,00 Hazardous waste packaging 1 650,00 1 Packaging contaminated with hazardous substances according to the legislation on chemicals and is marked as hazardous with security sheet for removal. Minimum amount of the packaging fee is 100 EUR (VAT not included) per year. The licence fee for the use of the trademark “The Green Dot” is already included in the packaging fee. 34
22. Spain: ECOEMBALAJES ESPAÑA, S.A. (ECOEMBES) Green Dot fees - Ecoembes The fees in effect were calculated to cover the cost involved in the selective pick-up of packaging waste and updated to account for the increasing number of people that are covered by the Selective Pick-up System. The cost of the Green Dot applicable to packaging depends on the type of material, meaning that for a given weight, aluminum packaging will not cost the same as packaging made of cardboard, plastic or steel. The fees for the different packaging materials are as follows: 35
Simplified Declaration Fees The fees applicable to this category are determined based on the tons of packaging marketed in the previous year. For additional information, click here 36
23. Spain: ECOVIDRIO (Glass packaging) Regarding glass packaging, green dot fee is composed of two pats: • One for packaging units placed on the market and • the other for the weight of those glass packages. Therefore, there will be one contribution in € per packaging unit plus a contribution in € per Kg. of packaging. In monetary terms, this frame is also a way to promote ecodesign and prevention, as heavy packaging or a high number of units of packaging must pay a higher fee. 2020 Green Dot fee = C1 x units of glass containers + C2 x kg of glass containers C1= 0,00348 €/unit C2 = 0,02451 €/kg 37
24. Sweden: FTI Packaging fees From April 1, 2019 From January 1, 2020 Item no. Material (SEK/kg) (SEK/kg) 310 Paper (high) 1.92 3.28 315 Paper (low) na 2.23 410 Plastic (high) 3.90 5.22 Household packaging 415 Plastic (low) 3.15 3.47 511 Aluminium 2.00 2.21 512 Steel plate 3.15 3.59 320 Paper 0.01 0.01 420 Plastic 0.03 0.03 Commercial 521 Aluminium 0.01 0.01 packaging 522 Steel plate 0.16 0.16 523 Barrels 0.04 0.04 524 Steel plate, wire 0.28 0.28 330 Paper (high) 1.73 2.63 335 Paper (low) na 1.79 Service packaging 430 Plastic (high) 3.51 4.18 435 Plastic (low) 2.84 2.78 531 Aluminium 1.80 1.77 More information is found here: https://www.ftiab.se/2934.html Note – a new fee structure for paper packaging is implemented January 1, 2020. All new fees are due from January 1, 2020. 38
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