The rhythm of packaging data reporting and invoicing

The rhythm of packaging data reporting and invoicing changes beginning in 2025.

 

Download the timeline HERE.

 

What is at stake?

So far, the current year producer responsibility (EPR) fees have been paid according to the packaging volumes of the previous year. For example, the 2024 EPR fees are paid according to the 2023 packaging volumes reported by companies. To clarify reporting and invoicing, from now on the EPR fees for a certain year are paid according to the packaging volumes of the same year. For example, the 2025 EPR fees are paid according to the 2025 packaging volumes. Due to the transition period, only part of the 2024 packaging data will be invoiced, but at the same time big packers will be invoiced 2025 recycling fees in advance already during 2025.

Reporting and invoicing 2024 packaging data

All companies report the 2024 packaging data in full in January 2025. Due to the transition period the 2024 packaging data will be invoiced only partially. Below you will find more information on what packaging data is invoiced on each declaration form. Of the 2024 packaging data only such packaging will be invoiced for which a company has not yet paid 2024 EPR fees. The invoiced fees are therefore 2024 fees that are paid retroactively, which is why they are invoiced using the 2024 price lists and according to the producer organisation with which the company had a contract in 2024.

Basic declaration form (light or detailed)

Recycling fees for the 2024 packaging volumes reported on the basic declaration form will not be invoiced, except for companies with a turnover of less than 1 million euros and that join a producer organization for the first time in 2024. Other companies have already paid their 2024 fees during 2024 based on the reported 2023 packaging data.

Basic declaration form (light or detailed):

Recycling fees for the 2024 packaging volumes reported on the basic declaration form will not be invoiced, except for companies with a turnover of less than 1 million euros and that join a producer organization for the first time in 2024. Other companies have already paid their 2024 fees during 2024 based on the reported 2023 packaging data.

Service and grower packaging declaration form:

For all service and grower packaging reported on the separate form both recycling fees and business service fee is paid. These are retroactive 2024 payments for such service and grower packaging for which producer responsibility transferred to the manufacturer or importer of the empty packaging from 1.1.2024.

SUP packaging declaration form:

SUP fees are paid for all packaging reported on the SUP form. These are 2024 SUP fees that are paid retroactively. The 2024 SUP fees will be invoiced in the spring of 2025.

Reporting and invoicing 2025 packaging data

A new rhythm of reporting and invoicing is introduced beginning with the 2025 packaging data reporting. The packaging volume of your company determines the timetable of reporting packaging data and the timetable for invoicing. There are different practices for small and big packers. The 2025 packaging data is invoiced according to the 2025 price lists which can be found here. Prices for SUP invoicing are published later.

Small packers:

Small packers are companies that put on the market in 2024 less than 50 000 kg of packaging (and companies included in a joint contract, if the total volume of packaging put on the market by the companies included in the contract is less than 50 000 kg).

Small packers report the total of the 2025 packaging data in January 2026.

Packaging data is invoiced after reporting. For small packers reporting and invoicing remains similar to the current practice. The only difference is that all 2025 packaging data is invoiced with the 2025 price lists, although the invoicing takes place in 2026. Invoicing becomes therefore retroactive.

Big packers:

Big packers are companies that during 2024 put on the market 50 000 kg or more of packaging (and companies included in a joint contract, if the total volume of packaging put on the market by the companies included in the contract is 50 000 kg or more).

Big packers can select from two alternative reporting models:

1. Packaging data reporting once a year. The total of 2025 packaging data is reported in January 2026

2. Packaging data reporting quarterly. The 2025 packaging data is reported in four parts during 2025 (last quarter in the beginning of 2026). The quarterly packaging volumes must be reported within a month from the end of the year quarter. Also, the SUP packaging data and cups sold empty to end-users are reported quarterly.

Invoicing the packaging data depends on the choice of the reporting model.

If the company selects to report once a year:

• Although packaging data is reported once a year, recycling fees are invoiced four times a year with advance invoices. The company receives four advance invoices with which the 2025 recycling fees are paid. The advance invoice is sent midway through the year quarter.
• The advance invoices are based on the 2024 packaging data reported by the company. Each advance invoice consists of a quarter of the reported 2024 packaging volumes with a price calculated according to the 2025 recycling fee price lists.
• The invoicing will be settled when the company has reported the actual 2025 packaging data in the beginning of 2026. Part of the sum invoiced in advance will either be paid back, or further recycling fees will be invoiced.
• SUP fees are invoiced only once a year. The 2025 SUP fees will be invoiced in the spring of 2026. Also, the business service fee is invoiced once a year. The business service fee is invoiced once the actual 2025 packaging volumes have been reported.

If the company selects quarterly reporting:

• Recycling fees are invoiced quarterly, always after the company has reported the quarterly packaging volumes. Invoicing is based on actual packaging volumes reported by the company. If the company reports cups sold empty to end-users, also their recycling fees are invoiced quarterly.
• SUP fees are invoiced only once a year, although the SUP packaging data is reported quarterly. The 2025 SUP fees will be invoiced in the spring of 2026. Also, the business service fee is invoiced once a year. The business service fee is invoiced once all quarters have been reported.

How to select the frequency of reporting?

Big packers can choose the reporting frequency on the Rinki Extranet. The default choice is reporting once a year. If your company wants to report once a year you do not have to do anything. If you company decides to report quarterly, you must select this option on the Extranet by 31.1.2025. The selection cannot be changed during the year. Small packers cannot opt for quarterly reporting, they always report packaging data once a year.