Registering with a producer responsibility scheme - what's involved?
by Annis Mapleston at 13:11 in Environmental, Emerging, Packaging, WEEE, Battery

​Countries around the world either have, or are implementing producer responsibility regulations for products including packaging, batteries, tyres, antifreeze and electronics. Obligated producers need to register either with a government agency (most often the country's Environment Agency) or a producer responsibility scheme - or both! But what's involved in this process?

The process varies in every country (and for every producer responsibility scheme - many countries have multiple schemes, even for the same product type). However, the majority follow broadly the same key steps.

Check whether you actually need to register at all.

In some countries, producers need to register from the time they place any products (e.g. a single battery) on the national market. Others, however, have thresholds to minimise the impact on small producers. These thresholds might relate to the amount of product the company places on the market, or to their annual turnover. Any companies that fall below the threshold may not need to register at all. Different countries also have varying definitions of which companies need to register: for example, some mandate that anyone who places a certain type of product on the market have to register, while others have exemptions for distance sellers that do not have any physical presence in the country.

​Complete the application forms and sign the contracts.

Every scheme will have their own application process: some will send out forms for completion (which will need to be sent back by email, or even in the post); others have an online application form, which needs to be completed before they can generate a contract. Many just need basic company information at this point, but others will require financial details and information about the products being placed on the national market.

It becomes more complicated when producers also need to register with a state agency: in some countries, this registration must be done before the producer responsibility schemes can enter into any agreements with the producers, whilst in others the scheme will be able to complete the state agency registration on their behalf.

Pay the registration fee.

Not all producer responsibility schemes or state agencies charge a registration fee, but many do... and some will not officially complete the registration process until this fee has been paid.

Submit your data.

​While some schemes won't want any data immediately, many will ask for something pretty quickly. This may be data relating to products placed on the national market in previous years or a forecast of what the company is expecting to sell in the future. It might be a comparatively simple request (e.g. a forecast for the current year), or something more complicated (such as sales data for the previous five years). It's also worth checking the deadline for submitting the data: some schemes will have timescales written into their contracts.

​Repeat for every obligated product that you sell, and every country that you sell into.

Confused? Wondering if there's something you need to do? Don't worry: we can help you with the whole process, from undertaking an obligation assessment to ensure that you register everywhere you need to (and nowhere else), to supporting you in completing the applications, to submitting your data. Sorry, we won't pay your fees for you though! Contact us today to talk to one of our consultants about how we can help you meet all your EPR obligations.

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