Lorax EPI

Registration with global compliance schemes and national waste management authorities
by Annis Mapleston at 11:32 in Circular Economy, Emerging, Environmental, Packaging

​Many companies are aware of the requirement to report their packaging waste to a compliance/stewardship scheme and pay for the costs incurred. But increasing numbers of countries also require producers to register with a national authority - and potentially report data or undergo period audits.​​

In Europe, this requirement stems from the EU's Packaging and Packaging Waste Directive​, which mandates that Member States must establish national databases on packaging and packaging waste (where they do not already exist). Similar requirements exist for WEEE and batteries. However, the Directive does not specify how national databases should be implemented, and we are seeing several models developing. This blog covers the most common systems, and provides some examples of the countries using each system.

​Producer registration and reporting to both national authority and compliance scheme

​Most commonly seen in countries with a competitive compliance scheme system or those which allow self-compliance, producers in some markets are required to register directly with both a national authority (typically the local Environment Agency) and a compliance scheme. It is then mandatory to submit data to both entities on a regular basis through separate reports, often identifying which compliance scheme is being used by each producer.

This allows national authorities to verify that all waste is being reported to a compliance scheme, by cross-checking individual producer data against that submitted by the compliance schemes.

Countries adopting this system include:

  • Denmark (DPA)
  • Germany (ZSVR, via Lucid portal)
  • Greece (EOAN)
  • Lithuania (GPAIS)
  • Portugal (APA, via SILiAmb portal)
  • Romania (AFM).

Producer registration to both national authority and compliance scheme, compliance scheme reporting​ only

Other countries require producers to register directly with both the national authority and a compliance scheme, but allow compliance schemes to submit data on the behalf of the producer (although note that not all compliance schemes will do so).

Countries currently using this type of system include:

  • Bulgaria (Environmental Executive Agency)
  • Italy (Ministro del Ambiente).

​​Compliance scheme registration and reporting​ only, details sent to national authority

​Especially commonly seen in countries with a single compliance scheme for each type of waste, schemes are sometimes able to register all of their clients with the national authority and complete all necessary reporting. Producers may be informed of their completed registration and their registration number / reporting portal login details, but there is no requirement for them to take any action other than compliance scheme registration and reporting.

Countries adopting this system include:

  • ​France (Ademe, via Syderep portal)
  • Slovakia (Ministry of Environment)
  • Spain (Ministry of Industry, Tourism and Trade).

​​National authority registration and reporting only, no compliance schemes​

​Some countries do not have any operational compliance schemes, but instead mandate that all obligated producers register directly with a national authority and submit reports solely to them. Registration and reporting in these contexts typically requires a detailed understanding of local tax or other administrative systems.

Countries currently using this system include:

  • ​Croatia (Environmental Protection and Energy Efficiency Fund, FZOEU)
  • Hungary (National Waste Management Office)​

Inevitably, there are countries which do not fit neatly into any of these models, and others which are in the process of moving from one system to another or implementing a national database for the first time and have yet to announce how it will function.

For information about how Lorax EPI can help navigate this complex registration and reporting landscape, please visit this page.​

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