Key Considerations for EPR in the New Year


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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