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.
No reporting requirement for reusable packaging in 2025
VANA has been advocating for clarification on the reporting requirement for reusable packaging in 2025, as it has been stated on EPA's website that producers of reusable packaging would also need to report the actual quantities made available for 2024 by June 1, 2025.
EPA has now changed this, as indicated on the EPA-website here.
This means that you do not need to report the quantities made available for 2024 by June 1, 2025.
You do not need to take any further action now - more information about reporting and reporting of reusable packaging will be sent directly to VANA's members at a later time.
Since there are still significant uncertainties about the allocation of responsibility for reusable packaging, VANA is very pleased that the reporting requirement has been postponed for one year, allowing the authorities time to update the guidelines, so that they also address the specific challenges related to the allocation of responsibility for reusable packaging.
Uncertainties - 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.