Extended Producer Responsibility Applicable to Distance Sellers of Packaged Products

Extended Producer Responsibility Applicable to Distance Sellers of Packaged Products


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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