Eastern European Packaging Mandates: Navigating a New Minefield

As the 10 new Eastern European members of the European Union struggle to meet newly mandated package recycling targets, exporters are facing a confusing set of taxes, fees, deposits and labeling requirements.

Top policy expert David Perchard will provide an overview of new and existing producer responsibility (EPR) laws in the Eastern European countries at noon EDT September 13 at the second Take It Back! teleconference, produced by Raymond Communications, publisher of Recycling Laws International, College Park, MD.The focus of the event will be on how to cope with new packaging requirements.

The Eastern European countries now have to reach the recycling targets set by the Directive on Packaging and Packaging Waste, and they have nearly all adopted producer responsibility legislation to ensure this, Perchard explains.

Per-capita income is about half that in Western Europe, and Perchard says that nearly all financing for packaging collection will have to come from industry. The current package recycling rates vary -- from as little as 2 percent to 25 percent.

"Five new members (and two candidates: Bulgaria and Romania) impose a tax on unrecycled packaging," he says. "These tax rates have usually been set according to political criteria, but unless they bear a clear relationship to collection and sorting costs, they risk destabilizing the national recovery organizations in those countries." He adds that the income from packaging taxes has frequently not gone for recycling projects.

Other challenges include:

• Poland and Slovakia require packs to be marked with EU material coding symbols, even though the EU only makes them voluntary. Perchard says that it is uncertain whether local governments will enforce the labeling requirements -- meaning exporters must comply or risk possible prosecution.

• Some countries have a new profusion of collection schemes, but since they are competing with one another, there is no public information on fees, making it difficult for companies to choose a scheme or plan ahead.

• Slovakia has softened its PVC ban, but still has a requirement for phase-down in use of the material.

• Latvia and Estonia have enacted new deposits on various refillable bottles. Perchard fears that if deposits pull bottles out of standard consumer recycling programs, the costs for collection of other non-deposit packaging will increase.

Raymond Communications publishes the newsletters Recycling Laws International and State Recycling Laws Update, covering EPR policy for packaging, batteries and electronics worldwide.

David Perchard, principal partner of Perchards consultancy, St. Albans, UK, has been tracking and analyzing European recycling policy for 20 years. He serves major corporate, government and association clients.

Future teleconferences will cover different aspects of implementation of the Restrictions on Hazardous Substances directive; WEEE/RoHS in China; EPR laws in South Korea, and other compliance issues. The next regular Take it Back! Conference will be held March 7-8, 2005, in Alexandria, Virginia.

For information on the conference, visit http://www.raymond.com/ or phone 301-345-4237.

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