Changes to producer responsibility raise questions – key topics for companies right now

The EU Packaging and Packaging Waste Regulation (PPWR) has changed packaging producer responsibility and introduced new obligations for companies. Many companies now need to look at their supply chains from a new perspective: Who has producer responsibility? In which country does the responsibility arise? And what does the company need to do in practice?

These questions also come up in Sumi’s discussions with customers. We receive inquiries from companies of all sizes and across different industries, with particular focus on the practical impacts of the PPWR.

Who has producer responsibility – and in which country? 

Two PPWR topics in particular are currently raising questions among companies: the appointment of an authorized representative for distance selling within the EU and the preparation of an EU Declaration of Conformity (EU DoC). Companies also have questions about who has producer responsibility for unbranded packaging.

Many companies are also figuring out which countries they need to fulfill their producer responsibility obligations in. With the obligations concerning branded packaging and distance selling, producer responsibility may extend beyond Finland to other EU countries. This is also reflected in the Nordic PRO Solution network, which has gained a record number of new customers this autumn. 

Private label arrangements can be particularly challenging. There is also some room for interpretation regarding producer responsibility for branded products and unbranded components within packaging hierarchies.

“We always try to explain as clearly as possible which operator has producer responsibility in each customer’s specific supply chain. The cases are not always straightforward,” says Anne-Mari Kulju, Sumi’s Head of Communications and Sales.

A company’s own waste management does not replace producer responsibility

However, not all customer questions are related to new regulatory changes. One common misconception that frequently comes up in discussions is that a company’s own waste management is the same as packaging producer responsibility.

These are, however, two separate obligations under the Waste Act. A company’s own waste management concerns waste generated by the company’s own operations and at its own premises. Packaging producer responsibility concerns the organization and costs of waste management for packaging placed on the market once the packaging enters the waste management system after use, anywhere in Finland.

In practice, the producer responsibility organization handles the nationwide separate collection, transport and recycling of this packaging waste on behalf of producers. Thanks to producer responsibility, consumers can dispose of packaging from consumer products in the designated collection containers free of charge.

Support is available for more complex questions too 

Customers need information not only about their obligations, but also how to fulfill them in practice. Guidance is needed, for example, on preparing the EU DoC and packaging data reporting.

Although preparing the EU DoC is not one of the core responsibilities of a packaging producer responsibility organization, Sumi also helps its customers with related questions. Sumi’s SumiOn reporting portal, in turn, makes packaging data reporting easier.

According to Kulju, the most important thing is to make complex regulation understandable for companies. Sumi’s role is to clarify what producers need to do, from joining a producer responsibility organization to reporting.

“At best, after the discussion, the customer has a clear understanding of their responsibilities and how to fulfill them. It is rewarding to hear a customer say at the end of a conversation, ‘Thank you for clarifying this. It’s not so difficult after all,’” Kulju says.

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