Packaging data reporting


How do we distinguish between consumer and B2B packaging? For example, haircare products are sold to salons, but partially end up with consumers.

The rule of thumb is, that if a packaging ends up or may end up with consumers or in households, it is a consumer packaging. If the haircare products sold to salons are also sold to consumers, they are reported as consumer packaging. If the product is e.g. a bigger, bulk packaging only intended for professional use, then it is reported as a B2B packaging.

If we use part of the product packaging that is delivered to us from abroad to repack our online orders, do we register these packages such as cardboard boxes twice?

The recycling fee for a packaging should not be paid twice. If the packaging has been reported under imports, it is not reported again under packing in Finland. Note that reuse of reusable packaging is reported separately. For example, a reusable wooden pallet would be reported under imports, and if the pallet is reused in Finland, also reuse is reported. Only the reuse of packaging intended for reuse, such as wooden pallets, is reported. For example, conventional corrugated cardboard boxes can often be reused several times. They are not specifically intended for reuse and therefore their reuse is not reported.

Where can we find information about whether a pallet sent to us has been used before or whether it is the first use? The supplier will hardly tell us which category the pallet belongs to.

If the company buys pallets, it can usually tell from the price whether it is a new pallet or a used one. If the company uses rental pallets, the pallet supplier must assess the average proportion of completely new pallets and pallets in use for the first time. This proportion of pallets is reported in the first use column.

Which is the main material in an IBC, plastic or steel?

The plastic container and metal frame of an IBC are reported as separate packaging even if tools are required to separate them. The plastic container is reported on the plastic tab on the form in the B2B packaging section, and the metal frame on the metal tab in the B2B packaging section.

The reporting guidelines mention “materials that cannot be easily separated manually” in several places. What exactly does this mean?

There are cases in which the different materials are easy to separate manually, such as a plastic cup with a metal lid. If, however, the different materials cannot be separated from each other (e.g. a bag made of metallised plastic film) or a tool is needed to separate the materials (e.g. a wooden pallet with metal parts), they are not considered as easy to separate manually.

What would be the best way to implement the reporting between manufacturers and users (i.e. packers) of packaging so that no packaging is reported twice?

Packaging volumes are reported to Rinki by the company that packed or had its products packed by another party in Finland for the Finnish market. The packaging of imported products is reported by the importer. A packaging manufacturer in Finland or an importer of empty packaging only reports the materials used for packing this packaging. This way nothing gets reported twice.

When will the reporting system take into account the packaging materials that a company collects from its customers when it delivers products and then arranges their recycling?

If a company collects the packaging for its products from its customers and recycles the packaging itself, it is a good idea to contact Rinki’s corporate customer service team to discuss the matter in more detail. Recycling means using waste materials as raw materials in the manufacturing of new products, e.g. using cardboard packaging waste as a raw material in the manufacturing of cores. If the company arranges the collection and recycling itself, these volumes must also be included in Finland’s packaging waste statistics.

Why is there no column for recycled in-house on the declaration form?

Rinki and the producer organisations have come to an agreement on this. This is clearer when all companies recycling packaging report the quantities of the packaging material they have recovered directly to the producer organisations. The latter can then verify whether this truly constitutes recycling.

A company packs products in Finland that are not placed on the market but are exported through another company. In which column should one declare the packaging of the said products?

If a company sells products to another Finnish company, it should enter the packaging for these products in the Packed in-house or by subcontractor for the Finnish market column because they are not the company’s own exports. The only exception to such a case is when the exporting company belongs to the same group, namely that is there is an intragroup relationship between the companies. One should give an explanation of this in the additional information field on the declaration form.

The packaging imported by a company has already been used in the country of export. Should this packaging be declared in the import or reuse as packaging in Finland column?

Imported packaging is always new packaging placed on the Finnish market even though it has already been used once in the country of export. If packaging remains on the market in Finland, it should be entered in the import column. Packaging should only be declared under reuse as packaging in Finland after its first time of use or after the reuse of the packaging for imported products in Finland.

A company imports empty packaging. Should this be declared on the declaration form?

No, unless the importer later uses them to pack products in-house whereby the packaging should be entered in the column “Packed in-house or by subcontractor for the Finnish market”. Only the user of packaging, or the packer, is obliged to declare packaging. The importer of empty packaging should nevertheless remember to declare its share of the transport packaging.

Do the regulations apply to a foreign importer and does this company have to report?

Producer responsibility for packaging concerns:

  1. A Finnish packer* or a foreign company’s Finnish branch*, which packs products for the Finnish market
  2. A Finnish importer* or a foreign company’s Finnish branch*, which operates as an importer of packed products to the Finnish market
  3. A foreign operator, established in another country than Finland and sells packed products directly to users in Finland through distance sales


the company has a total turnover of at least 1 M€

*the company has a Finnish business ID and is domiciled in Finland

**the company has a permanent establishment in Finland and is registered as a branch in the Trade Register maintained by the National Board of Patents and Registration

A company manufactures private label products for another company. Which company is required to report the packaging on these products?

As regards reporting, the basic rule is that the company that owns the product at the moment of packing is required to report the packaging. The owner of packed products is most often the company that manufactures it. Private label products are retail chain brands that are sold under the name of the company that purchases the product and not under the manufacturer’s name. The owner of private label products packed by a manufacturer may also be the retail chain depending on the contract made between the companies. Companies are required to give an explanation to Rinki which one of companies is reporting the packaging.