Are there waste laws in the UK?

Packaging register abroad: You have to register in these countries

Everyone is familiar with the German LUCID packaging register. Since 2019, every company that brings packaged products to the market has to register in the packaging register. What is less well known is that there are also waste and packaging registers abroad.

Even abroad, companies sometimes risk high fines if they are not entered in the relevant packaging register. This is especially true if a foreign company sends to end customers in these countries via an online shop. German or Austrian online retailers are also affected when they deliver to the EU. In the following, we would like to present the most important, publicly accessible registers in other countries and what you have to pay attention to there.

These are the 5 most important packaging registers abroad

1. The BDO register in Poland

Just like in Germany, every company in Poland that brings packaged products onto the market is obliged to register with a central office. In Poland this central office is not called LUCID, but BDO.

The register can be consulted on its official website: https://bdo.mos.gov.pl/

Since the site and the registration process are only available in Polish, registration is not exactly easy for foreign companies. Nevertheless, German or Austrian online retailers are also obliged to register when shipping to Poland.

To register a foreign company, you first need a so-called PESEL number. You can then register via the official website of the Polish authorities and apply for the BDO entry. Since registration is very tedious without knowledge of the Polish language, we only recommend recycling systems in our digital advice service for Poland that offer support for registration in English or take over the registration completely. Since the licensing of the packaging with a Polish recycling system is mandatory from the first delivery to Poland, you save a lot of time and nerves.

After registering in the BDO register, the company is issued its own register number (BDO number). This BDO number is also mandatory on all official documents when selling to Poland. In particular, this number should be printed on the invoice (e.g. next to the VAT number), otherwise there is a risk of high sanctions.

According to the Packaging Act in Poland, the penalties for not registering or not providing the BDO number range from fines up to the equivalent of approx. 220,000 EUR to imprisonment. In general, Poland is one of the strictest countries in the EU, along with Germany, when it comes to implementing its waste laws.

Registration in the BDO register costs an annual contribution of around EUR 20 for small and around EUR 70 for large companies.

2. National Register of Producers in Lithuania

Not every company in Lithuania needs a packaging license, because there is an allowance for small retailers. Nevertheless, registration in the packaging register is mandatory for everyone.

Online retailers are also affected here. B. deliver from Germany or Austria to end customers in Lithuania. And that from the very first delivery.

The PPWIS producer register is available in English under the following link: https://www.gpais.eu/en

Since many of the auxiliary items at PPWIS are only available in the national language, we provide our customers with step-by-step instructions for registering and reporting quantities in the Lithuanian packaging register. However, if you include your packaging in a recycling system in Lithuania, you can also count on support there in English.

3. Register of the Ministry of Environment in Greece

Although registration in the packaging register in Greece is compulsory for everyone, the state does not make it easy for you. For one, the website itself and all instructions are only available in Greek. On the other hand, it is also possible for foreign companies only with a branch in Greece or with a Greek representative to register.

Such an authorized representative could e.g. B. be a tax consultancy in Greece. This is particularly useful for online retailers who are subject to VAT in Greece. For smaller retailers who only send a few parcels to Greece, it should hardly be financially worthwhile. The only thing left is to exclude shipping to Greece for the time being, or to take the legal risk. After all: the Greek authorities currently seem to be less strict about controls than in Germany or Poland, for example. Will that change with the increasing flood of plastic, the pressure from the EU through higher recycling quotas and the EU market surveillance regulation?

Registration in the Greek EMPA waste register can be requested here: https://empa.eoan.gr/register.php

Unlike in the other countries, it is not publicly available to competitors.

4. Waste Register of the Slovak Republic

Similar to Lithuania, there is also a free allowance for micro-users in the Slovak Republic. Nevertheless, everyone who sells across the border to private individuals must be registered in the national waste register and report the packaging quantities annually.

The registration and reporting process is hardly digitized here. You have to fill out a form and send it to the Ministry of the Environment either by post or by email. We also offer our customers instructions on how to complete this. Presumably because of this complexity and the language barrier, relatively few foreign companies are currently registered despite the obligation.

The Slovak packaging register can be found here: https://obaly.sazp.sk/index.php

5. UK Packaging Register

Finally, good news: in the UK, small retailers are currently not required to register in the packaging register. The obligation only applies to an annual turnover of 2 million pounds or more or 50 tonnes of packaging waste.

The UK packaging register, like the waste register for WEEE and batteries, can be viewed here: https://npwd.environment-agency.gov.uk/

High complexity in international trade

What is already indicated in the various packaging registers abroad continues with the obligations and implementation of packaging licensing in the EU. Due to the EU packaging directive, each country has its own requirements and laws. Anyone who acts internationally should urgently check and adhere to the compliance requirements for each country. With our digital consulting service, you can call up your individual compliance requirements at any time at a reasonable price. Feel free to contact us at any time if you have any questions or find out more in our extensive FAQ area.

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