The Finnish Chemical Industry Federation’s position on the Commission Implementing Regulation draft laying down rules for the application of Regulation (EU) 2025/40 as regards the format for registration in and reporting to the register of producers and the information to be provided in that context
The Finnish Chemical Industry Federation (Kemianteollisuus KT ry) represents chemical industry companies operating in Finland, from large multinational enterprises to micro-enterprises. Our member companies place on the market a wide range of packaging, e.g. consumer, industrial and transport packaging.
We support the objective of the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) to reduce the amount of packaging waste. The means to achieve the objectives must, however, be proportionate. The draft implementing regulation under consultation sets out provisions on the format for registration to the register of producers. Harmonising registration and reporting information is a welcome development, but the proposed requirements increase the administrative burden on operators unreasonably and weaken EU competitiveness.
Reporting obligations should be limited to information that is necessary for achieving the objectives of the PPWR and for carrying out monitoring and enforcement activities, and that producers can reasonably be expected to obtain, even from complex supply chains. Excessively detailed reporting requirements do not create added value but instead impose unnecessary costs on economic operators. For example, the reporting requirements should establish a clear threshold below which small packaging components do not need to be reported separately. Overall, the proportionality of the proposed reporting requirements in relation to their expected benefits should be carefully assessed before the adoption of implementing measures. The Commission should ensure that reporting provides a clear regulatory benefit and does not create disproportionate burdens for producers.
PPWR defines the allocation of packaging producer responsibility across Member States. According to the Regulation a producer is the economic operator who, as a manufacturer, importer or distributor established in a Member State, makes available packaged products from within the territory of that Member State. The producer must register and report on its packaging to all national authorities in the Member States where it makes packaging available on the market. Separate registration in each Member State creates a significant administrative burden and ties up considerable company resources and it is not aligned with the objective of ensuring the proper functioning of the EU internal market. For this reason, a centralised single point of contact should be established at EU level, through which an operator could register at once in all the Member States where it acts as a producer under the Regulation. There is no need to abolish the national registers, but they should form a unified European system that reduces duplicate administrative work and thereby facilitates regulatory compliance.
Although the proposal aims to harmonise the rules across Member States, the system leaves room for interpretation and, for example, the risk of duplicate reporting remains. Packaging supply chains are often long and complex, which means that an economic operator placing packaging on the market does not always know in which Member State the packaging ultimately ends up, and when its reporting obligation arises. The different scenarios should be supported by clear guidance to prevent duplicative reporting and unnecessary administrative burden, while ensuring that reporting obligations are kept to a minimum. One example of a situation in which the registration obligation lacks sufficient clarity is the reporting of reusable packaging, such as IBCs, that has already been placed on the market.
