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Reporting and obligation thresholds – what are they and how do they differ?

Reporting and obligation thresholds – what are they and how do they differ?
by Ellen Thornton at 14:40 in Battery, Environmental, Packaging, WEEE

Obligations and reporting thresholds for packaging, WEEE and battery schemes vary from scheme to scheme and country to country. Obligation thresholds are more typically implemented through packaging waste legislation and reporting thresholds can be seen in p​​ackaging, WEEE and battery legislation. However, many countries have not implemented thresholds at all which means companies are obligated from the first item they place onto the market.


Obligation thresholds

Some compliance schemes, such as in the UK and Finland, have thresholds in terms of business turnover or weight placed on the market below which there is no obligation for companies to pay for the packaging that they place onto the market. This exempts certain small businesses from the reporting system and from paying fees.

Simplified reports

Some schemes allow a simplified report to be submitted below a certain threshold, for example, Ecoembes​ (Spanish packaging) will accept a simplified report from companies who place less than 8 tonnes of packaging on the market.

Report submission frequency

Furthermore, schemes can change the frequency at which submissions are due based on their obligated fees to the scheme. For instance, ERA​​​ ​(Austrian battery scheme) require only an annual report from companies who pay an annual fee of less than 3,000 Euro. Above this threshold, quarterly reports from companies with fees less than 40,000 Euro and monthly reports from companies with fees over 40,000 Euro.

How it works


In the UK packaging waste obligations only apply to companies that produce/place on the market 50 tonnes or more of packaging and those who have a turnover of more than £2 million per year.  Companies with turnover below £5 million aren't obliged to complete full data submissions as they are 'small producers'. For a small business, this can be an advantage as they don't have the burden of complying with the regulations.


The Spanish packaging scheme, Ecoembes, provide a simplified declaration which can be used by companies who do not declare more than 8 tonnes of packaging material. Although, as soon as a small business exceeds this threshold, they are hit with the full obligation to submit the ordinary statement. This entails detailed information on the products, packaging and annual sales as well as calculations of the economic contribution to the Integrated Management System (IMS) compared to the packaged products marketed by the Spanish company in the previous year. Primary, secondary and tertiary packaging all counts as IMS packaging and all commercial packaging must be reported, although it is excluded from fees.


In contrast, Denmark's approach to packaging is fundamentally different in that they don't have typical Extended Producer Responsibility (EPR) like the rest of the EU. They have already implemented a packaging waste management system, in which there is no threshold for compliance, which enables them to reach EU targets. Instead companies who produce, distribute or introduce any of the following are required to pay a tax levy: beverage containers, carrier bags of paper and plastic, disposable tableware and PVC foils for food. This system of taxing products which contain disposable waste acts as a deterrent and encourages the use of less packaging. All companies who fall under this tax bracket must register with the Danish Tax and Customs Administration (SKAT) and pay a registration and collection fee to Dansk Returnsystem (DRS) regardless of turnover or volume of packaging. SKAT co-ordinates the recycling and treatment of packaging waste through private operators and local authorities using funds placed on the packaging materials.​​​

If you need any more guidance on EPR regulations, contact us here​.​

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