Producer responsibility of small companies

Packaging producer responsibility concerns all professionally operating companies that place packaging on the Finnish market (packed products or service or grower packaging).

Packaging producer responsibility concerns Finnish companies*, that

1. pack or subcontract packing of products to the Finnish market (excl. service- and grower packaging)
2.  import packed products
3.  manufacture or import service or grower packaging to the Finnish market

The party with producer responsibility for service- and grower packaging, i.e. the “producer” is the Finnish manufacturer or importer of the packaging.

Service packaging: packaging that is used to pack food and other products for consumers directly at the point of sale.

Grower packaging: packaging that is used to pack unprocessed agricultural and horticultural products to be sold directly from the holding.

Packaging producer responsibility concerns also foreign companies that,

•  sell packed products directly to users in Finland via distance sales.

*A Finnish company means a company with a Finnish business ID and is domiciled in Finland OR a Finnish branch of a foreign company, that is registered in the Trade Register maintained by the National Board of Patents and Registration and has a permanent establishment in Finland.

Producer responsibility concerns natural or legal persons that professionally place products on the market. The authority (Pirkanmaa ELY Centre) considers that a professionally operating company can be defined by its obligation to register for VAT. The limit for small-scale VAT exempt business activity is an annual turnover of 15 000 euros.

• If an operator is exempted from VAT due to a small turnover, the activity is not considered professional from the point of view of packaging producer responsibility.
• However, if a company registers for VAT (even with a turnover of less than 15 000 euros) it is considered a professional operator with producer responsibility.
• There are certain sectors that are entirely exempt form VAT, such as healthcare, social care, comprehensive and vocational education, higher education and basic arts education. These groups may include operators that pack or import packed products, which are not exempt from producer responsibility, unless their turnover is less than 15 000 euros. Being exempt from VAT does not alone determine whether an operator has producer responsibility, it is also important to know that the exemption is due to a small turnover.

Companies handle their producer responsibility obligations for packaging by signing a contract with a producer organisation. The contract is registered by Rinki.

There are two packaging sector producer organisations in Finland: Finnish Packaging Producers Ltd and Sumi Oy. Both are responsible for the collection and recycling of carton and paper, glass, metal, plastic and wooden packaging in Finland.

The company selects the producer organisation they wish to join and signs a contract on the transfer of producer responsibility obligations with the preferred producer organisation.

A Finnish company can easily sign a contract on the RINKI webpage.

Companies registered at Rinki contribute to shared costs of packaging recycling by being part of the producers’ shared system.

The contract with a PRO covers the producer responsibility obligations for the packaging put on the Finnish market. A company is required to organise the transport of waste from its property. This can be arranged with a waste transport company and these costs are not included in the recycling fees invoiced by Rinki.

In 2024 a company with a turnover of less than 1 million € only pays the registration fee according to the 2024 pricelist. In 2025 the company pays the business service fee according to the 2024 pricelist and the recycling fees according to the reported packaging volumes.

The recycling fees serve to cover the costs of packaging producer responsibility such as collection and recycling of packaging waste.

In addition, if the company places on the market so called SUP packaging (certain plastic containing single-use packaging) in 2024, the SUP fees for 2024 are invoiced in 2025. The SUP fees serve to cover for the littering costs incurred to the municipalities based on waste legislation.

Further information is available in the SUP databank.

The prices in the pricelist are indicated EUR/tonne and the recycling fees are invoiced based on the actual reported packaging volumes with the accuracy of kilograms.

A company with a turnover of less than 1M€, and with a contract that enters into force in 2024, reports packaging data for the first time in the beginning of 2025. The company will then report 2024 packaging data.

To collect packaging data the company needs data on the packaging weight and the packaging materials of the packaging.

Packaging data is collected with the accuracy of a kilogram.

If the packaging includes several parts that can be detached by hand, all the parts of the packaging are reported as if they were separate packaging.

Report all packaging that the company has placed on the market in Finland, i.e.:

• packaging used to pack products (excluding service and grower packaging)
• packaging of products imported to Finland
• service and grower packaging imported to Finland and manufactured in Finland

Please note that:

• Packaging used for packing products for export (incl. Åland islands) is not reported.
• Packaging used in a company’s internal transfers is not reported. An internal transfer means that a packed product moves within Finland under the same business ID.
• Beverage packaging that belongs to the deposit system are not reported to RINKI.

The volume of packaging does not affect the reporting obligation. Packaging data is reported even if the volume has been low.