Report of reusable packaging
Companies that make reusable packaging available for the first time must register with the authorities (DPA) and report the quantities made available.
Reusable packaging is subject to reporting requirements the first time it is made available for the purpose of going through a number of trips or cycles by being refilled or reused for the same purpose.
Read more about what is considered reusable packaging
If you make reusable packaging available, you must register in the producer register (DPA). This applies to both companies that are already registered for single-use packaging and companies that only make reusable packaging available. Read more about registration, and find the Environmental Agency's guidance here.
Uncertainties - responsibility and reporting
There is still uncertainty regarding the allocation of responsibility and what needs to be reported in connection with the batch reporting of available reusable packaging in 2024.
What should be reported?
It is indicated on the Environmental Protection Agency's website what needs to be reported by June 1, 2025 - including that companies that made reusable packaging available before December 31, 2024, must report actual available quantities of reusable packaging in 2024 by material category.
VANA has long pointed out these uncertainties, and dialogue continues between DPA and the Environmental Protection Agency regarding whether the above is correct.
Placement of producer responsibility for reusable packaging
The Environmental Protection Agency has provided partial clarification regarding the placement of producer responsibility, for instance, when it is not the same company that markets the reusable packaging and is simultaneously responsible for the take-back and thus the recycling of the packaging in a reuse loop, as is the case for euro pallets and IBC tanks.
We are still awaiting an update of the Environmental Protection Agency's guidance with examples of reuse, but members of VANA can see the Environmental Protection Agency's text examples here.
We are working hard to get the authorities to provide clarification, and we will of course inform our members as soon as there is news.