Extended Producer Responsibility Applicable to Distance Sellers of Packaged Products

Extended Producer Responsibility Applicable to Distance Sellers of Packaged Products

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In the past months, RLG has monitored a rising number of countries across Europe that extended the obligated parties subjected to EPR regulations (especially for the packaging fraction). We will take a look at Slovenia, Finland, Sweden, and Portugal. 

Since July 1st, distance sellers are now obligated producers in Slovenia. Thus, a company outside of the country selling packaged products directly to end-users must comply with the Slovenian Packaging and Packaging Waste Regulation. Furthermore, those companies need to appoint an authorized representative. 

Finland is another country that introduced new obligations for distance sellers. The revised waste law was adopted and entered into force on July 19th, 2021. As expected, foreign producers who sell their products online are now subject to producer responsibility for batteries and packaging. Until December 31st, 2021, they need to comply with the regulations by joining a producer responsibility organization (PRO), appointing an authorized representative, or establish a PRO in cooperation with other producers on their own. 

In the past, the legislation did not cover foreign online sellers for battery and packaging. As a consequence, Finnish producers bore the costs for these two waste fractions. Vice versa, Finnish online sellers who sell products to users in other countries, will also be made responsible for all waste fractions and must join a PRO or appoint an authorized representative in the country where they are active. Another novelty is that foreign operators will be able to take over producer responsibilities from Finnish producers. 

Next to Slovenia and Finland, Sweden plans to introduce packaging producer responsibilities for foreign companies with direct online sales to Swedish end-consumers. At the moment, foreign distance sellers would only have producer obligations for WEEE and batteries. This change represents an ongoing discussion in the country, expecting further developments in the following weeks.

Unlike Sweden, in Portugal, distance-sellers are obliged to comply already. The national authority announced that the obligation to use an authorized representative in registrations is finally put into practice for fractions other than WEEE starting 2022. Therefore, companies that are already registered must make the appropriate changes as well.

Leveraging our experience and expertise, RLG is your partner to determine these obligations and how to fulfill them.

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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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