Producer responsibility of small companies

Packaging producer responsibility applies to all businesses operating on a professional basis that place packaging on the Finnish market. The EU Packaging and Packaging Waste Regulation (PPWR) changes the definition of a producer in certain respects. Customers of Finnish Packaging Producers Ltd (Suomen Pakkaustuottajat Oy) can access a comprehensive Producer Definition Guide in the Rinki Extranet. The guide explains both the producer definition valid until 11 August 2026 and the definition under the PPWR, which will apply from 12 August 2026 onwards.

Producer definition until 11 August 2026

Packaging producer responsibility applies to companies established in Finland* that:

1. Pack or have products packed for the Finnish market (excluding service packaging and farm packaging)
2. Import packaged products into Finland
3. Manufacture or import service packaging or farm packaging for the Finnish market

Service packaging: Packaging used at the point of sale to pack food or other products directly for consumers.

Farm packaging: Packaging used for unprocessed agricultural and horticultural products sold from a farm.

Packaging producer responsibility also applies to companies established outside Finland that:
4. Sell packaged products by distance selling directly to users in Finland

*A Finnish company refers to a company that has a Finnish Business ID and is domiciled in Finland, or a Finnish branch of a foreign operator that is registered in the Trade Register maintained by the Finnish Patent and Registration Office and has a permanent establishment in Finland.

Producer definition from 12 August 2026 onwards

A packaging producer is:
1. A company established in Finland that:

• Manufactures or has manufactured, under its own name or trademark, packaged products or empty transport, service or primary production packaging; or
• Imports packaged products or empty service, transport or primary production packaging, provided that it is not the end user of those items.

2. A company established outside Finland that:

• Sells packaged products or empty transport, service or primary production packaging by distance selling to Finnish end users (consumers or businesses).

If no producer can be identified for a package under points 1 or 2 above, the producer is the company established in Finland that removes the packaging surrounding the packaged product without being the end user of the product.

Please note! More detailed guidance on the producer definition is available in the Rinki Extranet for customers of Finnish Packaging Producers Ltd. The guide explains, among other things:

• How transport packaging, service packaging, primary production packaging and end users are defined;
• What is meant by having products manufactured under one’s own name or trademark; and
• The exemption applicable to micro-enterprises.

The guide is updated regularly and contains the latest guidance, interpretations and positions issued by the authorities regarding the producer definition.

Producer responsibility concerns natural or legal persons that professionally place products on the market. The authority (Finnish Supervisory Agency) 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 20 000 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 20 000 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 20 000 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.

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.

When a company joins a producer organization, it pays a registration fee in accordance with the price list.

The company pays the business service fee according to the pricelist and the recycling fees according to the reported packaging volumes yearly.

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), the SUP fees are invoiced according to the pricelist. 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/kg and the recycling fees are invoiced based on the actual reported packaging volumes with the accuracy of kilograms.

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 falls under your company’s producer responsibility, including:

• packaging that you use to package products for the Finnish market (excluding grower/primary production packaging, service packaging, and, from 12 August 2026 onwards, transport packaging that you have not imported empty or manufactured yourself)
• packaging of products that you import (until 11 August 2026, the company is responsible for the packaging of raw materials and components used in its own production, but from 12 August 2026 onwards, responsibility for these transfers to the distance seller established outside Finland)
• empty grower packaging imported or manufactured by your company (from 12 August 2026 onwards referred to as “primary production packaging”)
• empty service packaging imported or manufactured by your company
• empty transport packaging imported or manufactured by your company (effective from 12 August 2026 onwards)
• Customers of Suomen Pakkaustuottajat can find useful additional instructions in Rinki’s Extranet.

Please note that:

• packaging used for products packed in Finland for export (including export to Åland) must not be reported.
• packaging used for internal transfers within the company must not be reported.
• An internal transfer means that a packaged product is transferred within Finland under the same Business ID.
• packaging included in a deposit-based beverage packaging system must not be reported to Rinki.

 
The quantity of packaging does not affect the reporting obligation. Packaging data must be reported even if the quantity has been small.