Newsletter: November 2020
Singapore Packaging Update
The next phase of Singapore’s new suite of Extended Producer Responsibility Waste laws, incorporating Packaging, is ready to roll out in Q1 2021.
The spirit of intention of this legislation is to drive a reduction of packaging waste in Singapore, with a focus on packaging reduction and re-use, recycled content, and increased recyclability of packaging.
Actors who meet the definition of packaging producer in Singapore, include local entities who are importing regulated goods and packaging into Singapore.
Packaging Producers will be required to collect packaging data starting from January 1 2021 in order to be prepared for packaging reporting by the end of the year. The reporting required involves submission of plans that indicate initiatives to reduce packaging pollution, including specific targets and performance indicators and reviews of progress.
The Singapore Resource Sustainability Act focuses on definitions of exclusion, and most regulated goods and specified packaging are in scope, unless they meet any of the exclusion criteria. The list of regulated goods is available, and Accerio can help to determine if your products meet the definitions.
Penalties for non-compliance are not insignificant and include financial penalties with steep daily fines in some cases and imprisonment for persistent non-compliance and subsequent convictions.
If your company is importing regulated goods and packaging into Singapore, or if you unsure if your products fall into the definitions of regulated goods, please reach out to Accerio for assistance to register and be compliant with the Singaporean law.
EU Tax on Non-Recyclable Plastic
January 1, 2021 the EU non-recyclable plastics tax will come into effect. The tax is part of a Coronavirus recovery package. The €0.80 per Kg tax will be levied on EU Member state governments and will be calculated on the reported weight of non-recyclable plastic placed on the market in each country. Lesser economically developed countries will be granted exemptions.
Because it is individual EU Member States and not the non-recyclable plastics Producers themselves who are covered by this tax, it leaves a great amount of discretion for how this cost could be passed on to Producers, or not, as they see fit. Specific details are not yet available about which products the tax will apply to, or what exemptions may exist.
Because EU Member states will receive tax incentives from the EU Commission for higher rates of recycling, it is reasonable to expect that they will enact punitive economic instruments and policies targeting Producers who place unrecyclable plastics on the EU market. Whilst we cannot yet tell what the costs will be to Producers, what we can expect is enhanced scrutiny of plastics reporting by Producers, and almost certainly some kind of increase in fees and costs for Producers affected.
Regardless of the specific outcome of this tax, the trend is clear. There is a consistent push towards more recyclable packaging, and less of it, with taxes and laws coming into force in the next 12+ months in many European Member States. In anticipation of fee increases from this tax and other similar policies there is a window of opportunity now for Packaging Producers to analyze packaging used and work with supply chains to identify unrecycled plastics in use and possible recyclable alternatives, as well as potential to reduce the amount of packaging used.
Ontario 2021 WEEE Law Relaunch
On January 1, 2021 the new Ontario Electronic Waste law (The Electrical and Electronic Equipment (EEE) Regulation under the Resource Recovery and Circular Economy Act, 2016, O. Reg. 522/20: Electrical and Electronic Equipment) comes into force, obligating an expanded range of Electrical and Electronic Equipment. Products covered by the law include Telecommunications, Audio visual, and IT products, with spare parts and cables now included as well.
It is important to note that rechargeable batteries sold integrated in products were previously exempted, however all chemistries of integrated batteries will now carry obligations under the new E-Waste law. All standalone batteries, of all chemistries weighing < 5Kg are covered by Ontario’s new Battery law that commenced on July 1 2020 and was covered in our last newsletter.
The registration deadline with the Ontario authority was originally set for November 30, 2020, which didn’t permit much time to prepare, so this has been extended now until January 31, 2021. Registration requires submission of sales data from 2018 and 2019 in order to determine obligation thresholds, so Producers who have been selling Electrical and Electronic Goods, products with integrated batteries, or stand-alone or replacement batteries from that time frame should please contact Accerio as a matter of high priority for assistance in preparing reporting data in time for your registration application.
Please note that for Accerio clients who are currently already registered and complying through the collective EPRA will also need to register with the Authority (RPRA) but can continue complying through a collective organization, and your Account Manager will contact you to process this adjustment.
Year-End Reporting Preparation
2021 is almost upon us, and with it comes the end-of-year WEEE, Batteries, and Packaging reporting. All Producers selling these types of goods anywhere in the EU will be required to report, which makes for a lot of very tight deadlines at a busy time of the year.
As a reminder, here are a few tips to make the process as streamlined as possible; please let us know here at Accerio if:
- There have been any product changes that you may not have advised us of yet. Please send us SKU numbers, weights and technical specifications.
- There are new reporting staff and or change of email addresses. Please update our information so we can be sure to be in communication with the right people.
- There has been any takeback or recycling done by yourselves or any third parties, please send us the data and information. We may need a report directly from the recycling facility on how the take-back was recycled, so please ensure you know who to contact to obtain these reports.
It’s also a good idea to touch base with Authorized Signatories in your organization to remind them that some annual reports will require their signature, given it is an extra demand on them at a busy time of the year.
If you would like us to check through your data before the end of year to ensure that January is as stress free as possible, please feel free to contact your account manager.