What’s to do?
You must keep records of your packaging quantities per calendar year for each country you ship to. It is important that you are able to tell the exact packaging weight in kilograms – divided by type of material. If, for instance, you ship t-shirts packaged in a plastic polybag in cardboard boxes to customers in Italy, you must be able to tell how many kilograms of plastic and paper/cardboard your sales to Italy generate every year.
Which material types are important in which countries differs by country. And our short questionnaires show you exactly what data are needed. Typically, classification is done by “paper”, “plastics”, “metals”, “glass” and “others”.
However, there are special cases in certain countries – e.g. a category for “composite materials”. Whereas in other countries composites are categorized by their dominant material. Always read the explanations in the little green help-boxes when you fill out our questionnaires. They hint to such special cases.
Explanatory note: The mentioned questionnaires are available to our clients in their member-dashboards. They should be filled out for our algorithm to determine which information are relevant to your online shop for fulfilling your compliance obligations from the EU packaging waste directive and other national packaging recycling regulations.
Why must these records of packaging quantities be kept?
After joining compliance schemes to fulfill your obligations, you are usually required to annual, half-annual, quarterly or sometimes monthly declarations of your packaging quantities to these schemes. This is in order to control fulfillment of the recycling quotas by material type. These are specified by the EU packaging waste directive or national recycling laws. In some countries you are required to report your packaging data directly to ministries or official government institutions. But even if you may not have any obligations in specific countries at all, e.g. due to minimum thresholds and exemptions for small businesses, you should always keep these records to be able to present them in the case of an audit.
How accurate must my packaging quantities be?
Most countries expect you to have 100% accurate data. In reality, this is oftentimes not possible, and you are forced to calculate with averages. In any case, try to calculate as exact as possible. (Don’t forget to include any adhesive tape or filling material in your carton which you may be using to avoid damage to your goods; these do also count as packaging material!)
We suggest to always round up rather than down! The difference in price per additional kilogram is usually not more than a few cents, and no government has ever sued anyone for paying too many fees or taxes.
Do I only have to license transport packaging?
In short: It depends…
If you sell products which you produce yourself (or let produce for your own use) or import from producers abroad, you are usually responsible for both, transport- as well as product-packaging.
If you sell products from other producers, it depends if said producer has already licensed the product-packaging (in the specific country you ship to).
A common case is that you sell products of company XY and company XY has already licensed the packaging in the country of origin. If you sell these to customers of the same country, you only have to license the transport packaging (which you added on top). This is if the product-packaging has already been licensed. However, if you sell the same products to customers abroad (in countries where they haven’t been licensed), you are responsible for both transport- and product-packaging. So include this in your calculations.
What else must I be aware of?
Besides your packaging quantities, here is what’s important to know: Your annual sales turnover in each country and globally, whether your company has an own entity or subsidiary in the specific countries and if you trade cross-border. These information are needed to evaluate whether you have obligations for packaging waste recycling in a country.