VANA provides proposals for solutions in the consultation response to the statutory order on packaging

VANA has also proposed solutions to some of the ongoing challenges that have arisen after the announcement of prices before the summer holiday in its consultation response. You can read more about that here.

VANA's consultation response points:

• Guarantee: VANA supports the proposal that gives producer responsibility organisations (PRO) easier access to the release of guarantees. However, there is still a need for clearer guidelines and deadlines for decisions on guarantees as well as the risk of double guarantees.
• Base service level & municipal producer fees: VANA strongly recommends that municipalities do not charge a producer fee for Q4 2025, as all municipalities have already collected waste fees for 2025 without considering producer responsibility, which will not have liquidity implications for the municipalities.
• Elimination of the packaging fee: Producers are already paying for packaging waste through producer responsibility and single-use plastic fees. The packaging fee is double regulation that creates competition distortion and should be eliminated based on the same principle as the deposit and return system.
• Clear frameworks for dialogue between producer responsibility organisations (PRO) to avoid competition law challenges.
• Key figures for commercial waste: VANA recommends that key figures and fractions be standardised, and that the connection to industry groups and codes are clarified.
• Non-packaging waste (Annex 11): The current calculation formula creates distortions and losses for producer responsibility organisations (PRO) – for example, for glass/metal, which is why it should be adjusted.

VANA has also sent proposals for solutions to the ongoing challenges regarding prices.