Key Considerations for EPR in the New Year

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The start of the year is a hectic period for companies engaged in Extended Producer Responsibility. Here’s the latest rundown on upcoming and ongoing concerns about sales and product data relating to the availability of turnover figures, handling re-registrations, and preparing for recurring audits.

Obtaining turnover figures is a critical aspect of the reporting process in several countries, including Ireland, Spain, Belgium, France, Portugal, and the United Kingdom. In Belgium and France, these figures influence the report type selection. Italy also requires turnover information depending on the specific scheme in use. Interestingly, turnover figures in the United Kingdom are not only necessary for reporting but also for the re-registration process for the new compliance year.

Annual re-registration is a significant requirement in the United Kingdom, Ireland, Malta, and Romania. The processes for re-registration are already in progress for the UK and Ireland and involve compiling a list of relevant brands, providing a turnover specification, and obtaining a director’s signature. In Romania, re-registration requires the preparation of various documents, signed by management, before further processing by the relevant schemes.

Beyond these considerations, recurring audits play a crucial role and can be either randomly chosen or legally mandated based on specific criteria. Legal audit requirements vary by country and may be based on factors such as volumes placed on the market, invoice volume with the compliance scheme, headcount, turnover, or total assets. Notable examples include annual packaging reporting audits in Germany, Spain, and Estonia. Denmark validates WEEE declarations through annual audits, while France imposes packaging audits on producers every three years. In the Netherlands, similar audits are applicable to WEEE. Lastly, Israel imposes annual audit obligations for WEEE, batteries, and packaging reports.

This comprehensive approach ensures that companies are well-prepared to navigate the complexities of Extended Producer Responsibility, addressing various aspects crucial for compliance and sustainability in the coming year.

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Les Griffith - Speakers

Business Development Director
RLGA

Les Griffith is currently the Business Development Director at RLGA and is tasked with expanding the company’s data management offerings for packaging EPR in the Americas. Les has over 30 years of industry experience in Environmental Services, Extended Producer Responsibility and Reverse Distribution. Les has spent these last 30 years working with organizations to develop progressively more sustainable solutions to the management of end-of-life materials. Prior to joining RLG, Les spent eleven years at Covanta most recently serving as the Business Development Director for the Healthcare Solutions division. His group covered North and Central America and specialized in providing a suite of services to healthcare PROs, take-back services to retail pharmacy and law enforcement and environmental services to the healthcare sector and reverse distributors. Prior to Covanta Les spent 10 years at Waste Management Inc. as an Area Manager for their Healthcare Solutions group.

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Andriana Kontovrakis - Speakers

Director of Compliance Services
RLG

Andriana Kontovrakis is the Director of Compliance Services for Reverse Logistics Group’s US team.  She manages a team responsible for ensuring manufacturer and retailer customer compliance with EPR laws for electronics, batteries, packaging, household hazardous wastes, and other consumer products across the US. Along with RLG partner the Household and Commercial Products Association, she is spearheading the development of the Household Product Stewardship Alliance, a stewardship organization forming under the guidelines of Vermont’s HHW EPR law.  Prior to working with RLG, she was a Policy Analyst with the global electronics recycler Sims Lifecycle Solutions where she managed programmatic implementation and customer and supplier accounts for the US EPR compliance unit and the Deputy Director for Waste Prevention for the NYC Department of Sanitation.

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