FAQs about producer responsibility
Confused about producer responsibilty? Here you will find answers to frequently asked questions about extended producer responsibility and reporting packaging data.
Extended Producer Responsibility
What does producer responsibility mean?
Producer responsibility means the producer’s obligation to organise the reuse, recycling and other waste management of products, and to cover the costs thereof. Under the Waste Act, responsibility lies with companies that place tyres of motor vehicles, cars, electrical and electronic equipment, batteries and accumulators, paper and packaging on the Finnish market, regardless of how they are sold.
Producer responsibility for packaging applies to companies that pack in Finland, import packed products or sell their products to Finland through distance sales.
In Finland, producer responsibility for packaging is implemented through a common system where producer organisations are responsible for the practical implementation of producer responsibility requirements, such as collection and recycling. Packaging recycling fees are invoiced from companies with producer responsibility.
What kind of companies are concerned by producer responsibility for packaging?
Producer responsibility for packaging concerns:
A Finnish packer* or a foreign company’s Finnish branch**, which packs products for the Finnish market
A Finnish importer* or a foreign company’s Finnish branch**, which operates as an importer of packed products to the Finnish market
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
Are online shops responsible for their packaging under producer responsibility?
Yes, online shops are included in the scope of producer responsibility. Finnish online shops must join the producer responsibility scheme in Finland if they supply packed products to the Finnish market. Foreign online shops must register if they distance sell products directly to users in Finland
Reporting the packaging data
What is packaging?
Packaging is defined in Government Decree 1029/2021. A packaging preserves and protects the product, enables its handling and transport from the producer to the consumer or other user. A packaging provides information about the product and facilitates its presentation in the shop. All elements that reinforce or are attached to the packaging, such as labels, are packaging.
Examples of packaging include sales packaging, transport packaging and multi-pack.
Who reports the packaging?
Packaging volumes are reported to RINKI by the company that has packed in-house or sub-contracted packing of its products in Finland for the Finnish market. A distance seller reports the packaging that ends up in Finland to users. The responsibility for reporting lies with the company that owns the product at the time of packing.
An importer reports the packaging of imported products.
A packaging manufacturer in Finland as well as the importer of empty packaging only reports the materials used to pack these products. It is the user of the packaging ie. The packer of the product that is obliged to report the packaging they have packed to the Finnish market.
A company is responsible for its packaging, even if it outsources the packing to another company. This means that if a company hires pallets or buys a packing service from another company, the owner of the goods packed on the pallet must report the pallets used.
Exceptions to this are company internal transfers. This means that if a packaging moves within the same business ID in Finland between different locations, these transfers are not reported
What kind of packaging is covered by producer responsibility?
Producer responsibility applies both to packaging reaching the end user and to packaging used for transport (both B2B and B2C packaging). Producer responsibility applies to all packaging and packaging materials used for storing, protecting, handling, transporting and displaying the product. The packaging for dangerous goods is also covered by producer responsibility and the use is reported on the declaration form.
The packaging of products imported for the company’s own use must also be reported.
The volume of packaging does not affect the reporting obligation. Packaging data is reported even if the quantity is small.
Deposit packaging is not reported to Rinki.
What is Rinki Extranet?
Rinki Extranet is the place where company packaging data is reported and in addition, it contains useful material to support packaging data reporting.
The company contact person can update the contact persons as well as company information on the Extranet. The company is responsible for keeping contact and billing information up to date.
Are imports reported on the declaration form?
Yes, the importer is responsible for the imported packaging. It is the importer’s responsibility to determine the weights of the packaging, even if they do not see the packaging that is delivered directly to the customer.
The import column is used to record the packaging of all products imported to Finland and imported for the company’s own use. Packed products sold to users in Finland through distance sales are also reported as imports.
Are exports reported on the declaration form?
Export is not reported. Only packaging remaining on the Finnish market is reported.
How do I distinguish between B2B packaging and consumer packaging?
If the same packaging is sold to consumers and to businesses, it is reported as a consumer packaging. If the packaging is a larger packaging aimed primarily at for example catering establishments, it is a B2B packaging.
B2B packaging comprises the packaging that ends up to companies along with products. B2B packaging includes sales packaging as well as grouped and transport packaging for products intended for companies. B2B packaging also includes such grouped and transport packaging for consumer products that does not go to consumers with the product.
Consumer packaging includes sales packaging for consumer products and some grouped packaging, for example. Consumer packaging also includes packaging used at the point of sale for packing products, such as paper and plastic bags, boxes, single-use containers, etc., that consumers take with them.
How are IBC containers reported?
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.
Do the conventional shopping bags for consumers on the declaration form also cover reusable polypropylene tote bags?
Reusable polypropene tote bags are products, not packaging. They are not reported on the packaging declaration form.
Why is biodegradable plastic packaging included in plastics? What about compostable plastic packaging?
Biodegradable plastic packaging and packaging made from bio-based plastics are plastic packaging and are reported as plastic packaging.
Is packaging material reported only once in the supply chain?
Yes, packaging material is reported only once in the supply chain.
No packaging should be subject to a recycling fee twice.
However, the reuse of reusable packaging is reported separately for statistical purposes. For example, if a company imports a reusable wooden pallet, the pallet is reported at import and if the pallet is then reused in Finland, the reuse is be reported in the column for reuse.
The reuse of packaging intended for single use is not reported.
How should one report packaging that is imported from or exported to the Åland Islands?
The Åland Islands have their own producer responsibility system. Packaging imported from the Åland Islands is reported in the Import column. Exporting is not reported.
The packaging imported by a company has already been used in the country of origin. Should this packaging be declared in the import or reuse as packaging in Finland column?
Imported packaging is always considered as new when placed on the Finnish market even though it has already been used in the country of origin. If packaging remains on the Finnish market, it should be entered in the import column. Packaging should only be declared under reuse in Finland after its first time of use or when an imported packaging is reused in Finland.
How are private label products reported?
The general rule for reporting is that packaging is declared by the company that owns the product at the time of packing. The owner of packed products is most often the manufacturer. Private label products are retail chain brands that are sold under the brand 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 provide an explanation to Rinki which company reports the packaging.
Company’s packaging waste
Can a company return its packaging waste to Rinki eco take-back points?
No they cannot. Rinki eco take-back points only accept household packaging waste. Companies can arrange for packaging waste to be transported to the producers’ collection terminals, which accept packaging waste sorted in accordance with the producer organisations’ instructions, free of charge.