Possible upcoming changes packaging law Slovenia
Earlier this month the government of Slovenia published a draft regulation on Packaging and Packaging Waste. This regulation, open for comments until July 8, could have major impact on the obligations of companies selling into Slovenia.
Abolition of thresholds of 15.000 kg
The first change is the abolition of the threshold of 15.000 kg. In the current system companies that place less than 15.000 kg of packaging on the Slovenian market are regarded as small producers. Small producers have limited producer responsibility in Slovenia. With the introduction of this new regulation, this threshold will no longer be used. Upon adoption of this regulation companies will be fully obligated for its packaging POM, irrespective of the amount of packaging placed on the market.
Introduction of obligations for cross-border sales to end-users
The second major change is the introduction of obligations for cross-border sales to end-users. Whenever a company, established in a different member state, would sell packed goods to a Slovenian end-user, this company is obligated to register and report. This obligation is accompanied by the obligation to assign an authorized representative in Slovenia.
Early implementation of the new EU packaging directive
This latter change is an early implementation of the new EU packaging directive (2018/852). This directive determines that all countries need to allow foreign producers to appoint an authorized representative in their country, in order to comply with their environmental obligations. It is expected that more countries will implement similar rules to Slovenia, thereby extending their producer responsibility rules to cover more producers.
Do you need to register for packaging?
Are you wondering if you should register for packaging in Slovenia, or a different country of the EU? Please do not hesitate to contact one of our Environmental Compliance Specialists! Send an email to email@example.com or call to +31(0)88-4321800 They will be happy to answer any questions that you might have.