Packaging producer responsibility system
The producer bears extended producer responsibility
The principle of extended producer responsibility (EPR) for packaging is that the producer is responsible for organising the appropriate waste management and recycling of the packaging it makes available on the market.
Under the EU Packaging and Packaging Waste Regulation (PPWR), a producer is an operator that makes packaging or a packaged product available for the first time in a Member State where the packaging is expected to become waste.
In Finland, the producer may, depending on the specific circumstances, be one of the following:
- an importer established in Finland that imports a packaged product or an empty service, transport or primary production packaging and is not the end user.
- a distance seller established outside Finland that makes a packaged product or an empty service, transport or primary production packaging available directly to a Finnish end user
- a manufacturer established in Finland (subject to certain conditions) that makes packaging or a packaged product available on the market.
- a company that has packaging or a packaged product designed or manufactured under its own name or trademark (excluding micro-enterprises with fewer than 10 employees and an annual turnover or balance sheet total below EUR 2 million).
The definition of producer may require case-by-case assessment, particularly in relation to branded packaging, and responsibility is not always unambiguous in all situations.
If no producer can be identified under the definitions above, EPR obligations may ultimately fall on another operator, such as a logistics company that is the first to unpack a packaged product in Finland without being its end user.
Producer obligations
- The producer must register in the producer responsibility system and organise the waste management, collection and recycling of its packaging. In practice, this is usually done by joining a producer responsibility organisation (PRO), which fulfils these obligations on behalf of the producer.
- The producer must report annually information on packaging it makes available on the market. Reporting covers packaging quantities by material, a breakdown by categories such as household and commercial packaging, and information on single-use plastic (SUP) packaging and beverage cups. Members of a producer responsibility organisation submit data to the PRO, which verifies the information and forwards it to the competent authorities. SPT customers submit packaging data through RINKI’s Extranet service.
- The producer must pay recycling fees based on its packaging reporting. These fees cover the costs of the collection and recycling system.
- Under extended producer responsibility, producers are also required to pay SUP fees. These fees cover municipal costs arising from the clean-up of litter from single-use plastic packaging and costs of awareness-raising measures aimed at preventing littering.
- The producer must retain documentation demonstrating compliance with its producer responsibility obligations.
- A producer established in Finland that sells products directly to end users in one or more EU Member States through distance selling must appoint an authorised representative in each destination country.
Packaging definitions
Packaging is an item designed and intended to contain, protect, handle, deliver or present products to another operator or end user.
Sales packaging is packaging intended to constitute a sales unit for the end user at the point of purchase. It protects the product and often contains product information.
Grouped packaging is packaging that groups several sales units together. It may be sold as a single sales unit or serve only to facilitate handling and shelf replenishment at the point of sale.
Transport packaging is packaging intended to facilitate the handling or transport of one or more sales units. It may also include packaging used for products sold through distance selling.
Service packaging is packaging intended to be filled at the point of sale. It may include paper and plastic carrier bags, disposable plates and cups, takeaway containers, pizza boxes, bakery bags, and film or foil used for packaging products.
Primary production packaging (formerly agricultural packaging) is packaging intended for packaging and sale of agricultural, horticultural, forestry, hunting, fishing and other unprocessed natural products.
Additional packaging definitions:
Under the PPWR, packaging also includes permeable sachets containing single portions of beverages, such as tea bags, as well as non-permeable coffee capsules.
Numerous components and auxiliary elements attached to or integrated into packaging are also considered packaging. These include caps, lids, closures, handles, pumps and dispensers.
For certain elements such as tapes and labels, the interpretation of producer responsibility obligations remains subject to clarification.
Companies must also report packaging used for products imported for their own use. The quantity of packaging does not affect the reporting obligation.
The role of a producer responsibility organisation
A producer responsibility organisation (PRO) is an entity established by producers subject to extended producer responsibility within a specific sector. It fulfils producer responsibility obligations on behalf of its members. A PRO may be founded by producer associations or other organisations representing the relevant industry.
To be approved for registration, a PRO must meet the following requirements:
- it must be established by producers and have legal capacity
- membership agreements and fee structures must be in place
- a sufficient collection network must be established, and agreements for collection, transport and recycling must have been concluded
- arrangements safeguarding financial solvency and contingency plans for exceptional situations must be in place
- operations must comply with the Waste Act and related regulations
Responsibilities of a producer responsibility organisation
- Organising, on behalf of its members, the collection, transport, waste management and recycling of products covered by extended producer responsibility.
- Submitting annual monitoring data to the Finnish Supervisory Agency, including quantities of products made available on the market, collected, recycled and otherwise recovered during the preceding year.
- Promoting reuse and supporting the achievement of recycling targets. This includes ensuring that reusable products remain intact during collection and are accessible to potential users.
- Providing regular information and guidance on topics such as collection points, waste prevention, litter prevention and reuse.
- Publishing information on its operations, including ownership structure, producer members, membership and recycling fees, procurement principles, separate collection arrangements, and reuse, recycling and recovery targets.
- Carrying out internal monitoring based on a documented control plan, including independent third-party audits.
The membership conditions and producer responsibility obligations applied by a producer responsibility organisation must be fair and non-discriminatory. Membership fees must be reasonable and proportionate to the quantity and characteristics of products made available on the market.
Recycling fees must be environmentally differentiated in accordance with product-specific criteria.
Partners in the recycling value chain
Finnish Packaging Recycling RINKI Ltd
Finnish Packaging Recycling RINKI Ltd is a non-profit service company and a close partner of Finnish Packaging Producers Ltd. In matters relating to packaging producer responsibility, Rinki primarily serves FPP’s customers.
In cooperation, Rinki:
- manages FPP’s customer agreements and maintains the customer register – agreements with SPT are concluded through RINKI’s online services
- receives annual packaging reports from companies and forwards the reported information to the competent authorities
- invoices recycling fees based on packaging reporting
- provides information, training and advisory services on producer responsibility, reporting obligations and packaging recycling.
Further information is available on RINKI’s website.
Logistics partners
Logistics partners play a key role in the practical implementation of the producer responsibility system and the recycling value chain. They are responsible for the collection and transportation of packaging waste and for managing material flows from collection points to reception terminals and recycling facilities.
Their role is to ensure that packaging materials move through the recycling chain efficiently, safely and with due consideration for environmental impacts. Professional operators, extensive transport networks and advanced technologies help support the achievement of recycling targets and the overall cost-effectiveness of the producer responsibility system.
Reception terminal operators
Reception terminals act as logistical hubs within the recycling chain before materials are transferred to treatment and recycling facilities.
Packaging waste from producer responsibility schemes, bring-point collections and property-based separate collection systems is received at these terminals. The facilities are used for the reception, storage and sorting of packaging waste and may also carry out preliminary treatment of materials.
The terminal network consists of dozens of facilities across Finland. The materials accepted vary by location, meaning that not all terminals receive all packaging materials, such as plastic, glass, metal, wood, carton and paper.
FPP’s reception terminals can be found here (in Finnish).
Recycling facilities
Recycling facilities form the final and critical operational stage of the recycling chain. They process packaging waste and materials into forms suitable for recycling and use as secondary raw materials.
Typical processes include:
- receiving and inspecting incoming materials
- detailed sorting
- removal of contaminants
- processing materials into secondary raw materials
- delivering processed materials for further use
Most recycling facilities specialise in specific materials and processing methods.
- Fibre-based packaging is processed into recovered fibre used in the manufacture of new carton board, core board and packaging products.
- Glass packaging is processed into cullet to produce new glass products, glass wool and foam glass.
- Metal packaging is recycled into raw materials for new metal products.
- Plastic packaging undergoes technically demanding recycling processes resulting in secondary raw materials for new plastic products.
- Wooden packaging may be repaired and reused or processed into raw material for the panel industry and other wood-based products.
Municipalities and municipal waste management companies
Municipalities and municipal waste management companies are not the primary responsible parties under the packaging producer responsibility system.
However, as organisers and authorities within the waste management system, they often cooperate with producer responsibility organisations in the collection, transportation and reception of packaging waste.
Their key responsibilities typically include property-based separate collection systems, customer services and public guidance relating to waste management and recycling.