Things will get serious on 1 January 2019. This is when the new Packaging Act comes into force and replaces the Packaging Ordinance. Some types of packaging will now be subject to „system participation“ under the Packaging Act. This particularly affects secondary packaging and the shipping packaging of online retailers. Many companies are still unclear about how „service packaging“ must be handled. The Folding Carton Industry Association (FFI) has developed the factsheet „Folding Cartons and Packaging Act“ for its members in order to provide clarity.
When the new year Packaging Act comes into force, packaging manufacturers must register with the new Central Agency Packaging Register and report the quantities of packaging they place on the market. Manufacturers must still register the B2C packaging they place on the market with one of the current nine dual systems for proper disposal.
Although time is running out, not all companies have finalised their preparations for the Packaging Act. Care is advisable in this matter. Manufacturers who want to Reporting and registration obligations If packaging producers fail to comply properly, they may face sanctions such as a ban on placing packaging subject to system participation on the market on a commercial basis.
„In response to the many enquiries from our members, we have developed a fact sheet that we are making available to our members,“ reports Christian Schiffers, Managing Director of the Folding Carton Industry Association (FFI) in response to an enquiry from packaging journal. The Packaging Act already played a major role at the FFI Entrepreneurs' Day at FachPack 2018.
Exceptions apply to service packaging
There is still a need to explain the terms „manufacturer“ and „First placer on the market“, Christian Schiffers has learnt in contact with the FFI companies. The Packaging Act defines producers as those companies that supply filled packaging to private, public or commercial end consumers, where the packaging then accumulates as waste. „The term ‚Manufacturer‘ under the Packaging Act does not therefore refer to the producer of the packaging,“ emphasises the FFI Managing Director. Instead, this includes bottlers, brand owners or, in the case of private labels, retail companies. Companies that import packaging filled with goods from abroad would also be considered producers under the Packaging Act.
„It is in the interest of packaging manufacturers to provide their customers with competent and complete information and advice on the quantities of packaging they purchase.“
FFI Managing Director Christian Schiffers (Image: FFI)
Companies that are obliged to participate can fulfil their obligations, such as system participation, registration and Declarations of completeness to upstream parties in the supply chain. According to the Packaging Act, an exception only applies to the so-called Service packaging. According to Central Agency Packaging Register for example, bread roll bags, butcher's paper, trays for chips, coffee-to-go cups and bags for fruit and vegetables. Snack bars, supermarkets, bakeries and other distributors of service packaging can therefore demand that their suppliers fulfil their obligation to participate in the system and licence unfilled service packaging, explains Christian Schiffers.
Factsheet supports customer communication
The FFI wants to use its new Factsheet support the communication of its member companies with customers, says Christian Schiffers: „It is in the interest of packaging manufacturers to inform and advise their customers competently and completely about the quantities of packaging they purchase.“
The guidelines also cover future developments. From 2019, for example, the Licence fee be more closely aligned with the ecological criteria of the packaging materials used. The level of the fees will then be based on aspects such as the recyclability of the packaging materials, the proportion of Recyclates or the use of renewable raw materials.
