In December 2024, the European Council formally adopted the PPWR (Packaging and Packaging Waste Regulation) – a decisive step towards reducing packaging waste and promoting sustainable packaging solutions.

What does this mean?
1. January 2025: publication in the Official Journal of the EU.
2. 20 days later: entry into force of the Regulation.
3. 18 months after: Mandatory application in all Member States.

The EU Packaging and Packaging Waste Regulation introduces several key requirements to minimize environmental impact and promote sustainability:

Material and Substance Restrictions (Article 5):

• Packaging must contain minimal harmful substances.
• This includes both the packaging material itself and all components like inks and coatings.
• The goal is to reduce environmental impact throughout the packaging’s lifecycle.
In online webshops, shipping packaging is subject to stricter requirements and guidelines. For traders of electronic goods, regarding filler materials (according to Article 21), the void space ratio must not exceed 50%. Void space refers to the space in packaging filled with filler materials such as paper, air cushions, bubble wrap, foam, or similar. The void space ratio is the ratio between the total volume and the volume of the contained products.

Recyclability (Article 6.1):

• All packaging must be recyclable.
• Packaging should be designed for easy separation and recycling of its components.
• It should be compatible with existing waste collection and recycling systems.

Packaging Minimization (Article 9.1 and 21):

• Packaging should be minimized in weight and volume.
• Unnecessary packaging, such as excessive void fill, is prohibited.

Reusable Packaging (Article 10):

• Reusable packaging must be designed for multiple use cycles.
• It should be easily cleaned and refilled without compromising product quality or safety.
• The packaging should be able to undergo as many cycles as possible under normal usage conditions – the benchmark for packaging is 5 for cardboard and 10 for all other materials.

Labeling (Article 11.1):

• Packaging must be labeled with information about its material composition which includes the ingredients processed in the packaging.
• This helps consumers and waste management facilities correctly sort and recycle packaging.
• According to Article 14, suppliers of packaging or packaging materials must provide information and documents that certify conformity and inform.

Producer Responsibility and mandatory representation in all EU countries (Article 40.2):

“A manufacturer shall appoint, by written mandate, a designated representative for extended producer responsibility in each Member State where he first makes packaging available, except in the Member State where he is established.”

• Manufacturers and importers are responsible for the entire lifecycle of their packaging, including proper disposal and recycling.
• They need to appoint an authorized representative in each EU country where they place packaging on the market.

Ensuring Compliance – suppliers, retailers and distributors obligations:

• Suppliers must provide information and documentation to certify that their packaging complies with the regulations.
• Retailers and distributors should verify that the packaging they sell or distribute meets these requirements.

By adhering to these regulations, businesses can contribute to a more sustainable future and avoid potential penalties.

Understanding and complying with PRO regulations is essential for foreign e-commerce businesses operating in Slovenia. By taking proactive steps to fulfill your PRO obligations, you can protect your business, contribute to a sustainable future, and build trust with Slovenian consumers.

Since 2021, there are a number of changes for businesses in the field of packaging management.

The Packaging and Packaging Waste Regulation was adopted in April 2021. It stipulates that all companies placing packaged goods on the Slovenian market without a previous Slovenian supplier will become obliged to report and pay a packaging fee in 2021.

The new Packaging and Packaging Waste Regulation imposes the payment of a packaging levy on all companies that place packaging products on the market, as the 15 tonne packaging threshold is abolished.

New obliged parties must conclude a contract with a packaging waste management company as from the adoption of the Regulation.

Packaging is an indispensable part of almost every product. When we hear the word packaging, many of us first think only of the primary packaging in which the product is packed on the shelf, but we forget about the packaging that was important in the product’s journey from the manufacturer to the customer.

Primary, secondary and tertiary packaging

To give you an idea of what the concept of packaging refers to, here are some practical examples of packaging. There are three types of packaging or packaging elements:

Primary or sales packaging protects or encloses the basic unit of the product. This includes, for example, jars, bags, cans, bottles, plastic bottles, boxes, bowls, tubes, containers or other similar packaging with component parts. It is intended for the consumer at the point of purchase and protects the product from external influences or has an important function at the time of purchase of the product.

Secondary or group packaging* means films, boxes and similar wrappings or other packaging with component parts which enclose or hold together a large number of primary sales units of the same or a variety of goods. It is irrelevant whether the packaging is sold together with the goods to the end user or consumer or is removed at the point of purchase and has only logistical value.

Tertiary or transport packaging** means barrels, boxes, crates, handles, bags, pallets, cartons or other packaging with components which enclose or hold together a larger quantity of the basic sales units of the goods in a sales or group pack, and which facilitates the handling and transport of the goods and protects the goods from damage in the distribution route of the product.

Note that packaging also includes carrier (shop) bags, sacks, boxes, paper bags, pizza boxes, wrapping paper, etc., which are usually filled at the point of sale.

Types of packaging materials

Packaging can be made from a variety of materials that are similar in composition but different in form and purpose. Thus, when packaging a single product, different materials are combined for either primary, secondary or tertiary packaging.

Materials are divided into the following groups:

• paper and cardboard (such as paper bags, cardboard wrappers, wrapping paper, boxes, cake liners, plates, jars, labels, stickers);
• plastics other than PVC (in the form of plastic bottles, bowls, tubes, canisters, dessert boxes, wrappers, plastic crates or containers, flower pots for transport, clothes hangers for resale, plastic capsules for beverages);
• PVC (wrapping film, bags, PVC wrappers);
• wood (transport pallets, wooden crates);
• iron and steel (in the form of nails, gas bottles, caps and other supporting materials such as staples, grinders, etc.);
• aluminium (mainly in the form of cans, aluminium foil, aluminium capsules for beverages);
• glass (bottles and glass jars);
• composites (separated by type of material, according to the weight predominating in the composite);
• other (ceramics, textiles in the form of straps and wearable bags, etc.).

For foreign companies delivering products in packaging or packaging on the Slovenian market without an business entity here, the Slovenian packaging Ordinance implifies the obligations to appoint an Authorised representative to take over your obligations in this market. Your authorised representative will :

1. Register your company with the Republic of Slovenia’s pertinent governmental authorities, including taking care of administrative expenses and fees
2. Represent the corporation within the jurisdiction of the Republic of Slovenia.
3. Assure of the timely and proper fulfillment of Extended Producer Responsibility (EPR) obligations.
4. Submit requisite reports to the relevant state authorities.

Interzero has more than 30 years of expirence in waste management and recycling, so we can act as your trustworthy partner, taking over your obligations in the Slovenian market.

Understanding Extended Producer’s Responsibility (PRO)

If you’re an online retailer selling products to Slovenian consumers, it’s crucial to understand the concept of Producer’s Extended Responsibility (PRO). In essence, PRO means that producers of certain products, including packaging, electronic devices and batteries, are responsible for the entire lifecycle of their products, from production to disposal. This includes the costs associated with recycling and waste management.

Why is PRO important for foreign e-commerce businesses?

• Legal Compliance: Non-compliance with PRO regulations can result in significant fines and legal issues. In the case of Slovenian packaging order the fines for not complying with packaging legislation is up to 4,000 € per company.
• Environmental Responsibility: PRO promotes sustainable practices and helps reduce the environmental impact of products. With a reliable partner like Interzero you can be calm, that we take care of proper waste disposal and recycling of resources whenever possible.
• Consumer Trust: Demonstrating commitment to PRO can enhance your brand reputation and customer trust. In the era of sustainable practices becoming more and more widespread and popular among businesses they are also higly valued among consumers. So if you care about the environment and take actions that reduce the impact of your products it can also result in positive brand awareness and recognition by your consumers.

Which products are covered by PRO in Slovenia?

In Slovenia, PRO applies to a wide range of products, including:

• Packaging
• Electrical and electronic equipment
• Batteries
• Graveyard candles

Until the new Regulation (EU) 2023/1542 on batteries and waste batteries is implemented in the Slovenian legislation there are no obligations for foreign companies without a legal entity in Slovenia to report the quantities and types of products of batteries they are delivering to the Slovenian market.

What are the obligations of a foreign e-commerce business under PRO?

As a foreign e-commerce business selling products to Slovenia, you have several obligations  such as:

• Appointing a representative in Slovenia:

You must appoint a representative in Slovenia who will be responsible for handling PRO-related documentation, reports and communication with the governmental institutions on your behalf.

• Joining a compliance scheme:

You need to join a compliance scheme that handles your products’ collection, recycling, and proper disposal. Interzero is a collective scheme with more than 20 years of experience in the Slovenian market.

• Providing information:

You must provide accurate and complete information about the quantity and type of materials in your products on the Slovenian market to the compliance scheme.

• Assuring your obligations are covered includes paying fees:

You will be required to pay fees to cover the costs of handling your products under PRO, preparing required documentation and submitting reports to the Slovenian governmental institutions.

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How can you comply with PRO?

To ensure compliance with PRO, consider the following steps:

1. Appoint a trustworthy representative: Find a reliable representative in Slovenia to handle your PRO obligations. Interzero has more than 32 years of experience in waste management, compliance and recycling across Europe and in Asia. We work with more than 50.000 clients only in Europe, so we would be happy to help with taking over your obligations in Slovenia.
2. Join a compliance scheme: Select a compliance scheme that aligns with your business needs. Interzero is compared to many other providers of authorized representative services in this case unique since we can cover authorization and licensing all under one roof. This enables our clients a simple and unified solution for their PRO obligations.
3. Provide information: Ensure that all the information you provide to the compliance scheme is accurate and up-to-date, especially regarding reported types of material and quantities that you put on the market.
4. Monitor changes: We will carefully monitor PRO regulations and inform you about any changes that request an action on your belhaf.