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    30 October, 2024

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    Understanding the rules that apply to the taxation of real estate transactions is essential for anyone operating in the market, whether investors,...

    28 February, 2025

    Omnibus package – incoming changes in ESG reporting

    The European Commission’s proposals to simplify ESG regulations as part of the so-called Omnibus Package published on February 26th 2025 have sparked...

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    • ‘Omnibus’ Proposal’s impact on EU’s sustainability ambitions

      Since the Omnibus proposal was announced on February 26th, consulting firms and non-profits have debated its impact—not just on reporting companies (as we discussed here) but also on the efficacy of the EU’s Green Deal and its broader sustainability ambitions.

      On ‘Omnibus’ Proposal’s impact

      Julia Otten, Senior Policy Officer at the consulting firm Frank Bold, criticized the proposed changes to the Corporate Sustainability Due Diligence Directive (CSDDD), arguing: 

      Julia Otten, Senior Policy Officer at the consulting firm Frank Bold, criticized the proposed changes to the Corporate Sustainability Due Diligence Directive (CSDDD), arguing: 

      The proposed changeswould effectively dismantle the law before it’s even started to apply, without presenting any proper evidence. Addressing crucial issues like child labour and forced labour requires targeted oversight beyond direct business partners in the value chain. It is absurd that the Commission is proposing to limit this. The sudden shift appears to prioritise short-term industry pressures over long-term sustainability goals and the protection of human rights.

      Others echo this concern. Richard Gardiner, Strategic Public Policy Lead of the World Benchmarking Alliance, warned that removing the requirement in Article 22 of the CSDDD to “put into effect” climate transition plans could undermine climate action: 

      This goes completely against that intention [of other EU policies to effect a decarbonised economy] and worst-case scenario could reduce these plans to kind of a paper exercise, a publicity exercise, but something that doesn’t have any real effect on how the company functions.

      Similarly, Mariana Ferreira of WWF described policy changes to the EU Taxonomy as a “significant butchering” of the framework. While the revised taxonomy still covers major corporations, the reduction in scope and materiality thresholds for reporting weakens its effectiveness, she argued. 

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      Such omissions reduce accountability and hinder firms, investors, and stakeholders from assessing whether climate policies achieve their intended impact due to diminished availability of comparable data. While the proposal’s focus on quantitative disclosures may improve some comparisons, many climate advocates, regulators, and investors stress that climate risks are financial risks—making robust reporting essential for economic stability. 

      The legislative process for this proposal is far from final. Experts predict that the most urgent element—the so-called “stop the clock” provision—may not be finalized until Q3 of this year, ensuring a lengthy and contentious debate. Positions vary across the EU: while countries like France, Germany, and Poland are expected to support the simplifications, others, including Spain and Italy, argue that the proposed changes are too extreme, according to Tony Christensen, Director of Position Green. 

      As negotiations continue, sustainability professionals across Europe will be closely watching how the Omnibus proposal evolves and what it means for the future of the EU’s sustainability strategy. 

      Sources:

      – “EU omnibus sustainability proposal: Why experts are concerned” by Moriah Costa for Green Central Banking (Feb 2025) EU omnibus sustainability proposal: Why experts are concerned – Green Central Banking 
      – “EU Omnibus Unveiled: Key implications for CSDDD, CSRD, and EU Taxonomy” Webinar by WWF, World Benchmarking Alliance, Frank Bold, ShareAction, and the European Coalition for Corporate Justice (Feb 2025) EU Omnibus Unveiled: Key implications for CSDDD, CSRD, and EU Taxonomy 
      – “EU sustainability report ‘Omnibus: what we know so far” Webinar by Position Green (Mar 2025) EU sustainability reporting “omnibus”: What we know so far 
      – “First EU Omnibus proposals on sustainable finance raise concerns for investors” by Leo Donnachie for the Institutional Investors Group on Climate Change (Mar 2025) First EU Omnibus proposals on sustainable finance raise concerns for investors 
      – “Frank Bold warns: reckless Omnibus proposals threaten to roll back a decade of EU sustainability progress” by Sarah Chenoun for Frank Bold (Feb 2025) Frank Bold warns: reckless Omnibus proposals threaten to roll back a decade of EU sustainability progress | Frank Bold 
      – “‘Omnibus’ package explained: Key proposed changes to the EU Taxonomy” by Tony Christensen for Position Green (Mar 2025) ‘Omnibus’ Package: Key EU Taxonomy changes explained 

      17 March, 2025
    • EPR overview internationally

      Although the European Union (EU) has established Extended Producer Responsibility (EPR) policies through legislation like the Directive on Waste Electrical and Electronic Equipment and the Directive on Packaging and Packaging Waste, the implementation of these policies can still vary significantly across member states and is continually evolving.  Since the Omnibus proposal was announced on February 26th, consulting firms and non-profits have debated its impact—not just on reporting companies (as we discussed here) but also on the efficacy of the EU’s Green Deal and its broader sustainability ambitions.

      On EPR overview internationally

      While EPR policies share a common goal—shifting the responsibility of waste management from consumers and governments to producers—their implementation varies widely across regions. Some countries enforce strict, centralized regulations with heavy penalties for non-compliance (e.g., South Korea), while others take a decentralized approach with state- or province-level policies (e.g., the US and Canada). Additionally, some frameworks emphasize financial contributions from producers, while others focus on physical take-back schemes or circular economy incentives. Understanding these variations is crucial for businesses operating in multiple markets, as compliance requirements, reporting obligations, and financial burdens differ significantly. 

      In this article, we will explore EPR frameworks beyond the EU, offering a broad overview of how some of the world’s largest economies are adopting and adapting similar principles in diverse ways. 

      Country Overviews 

      Key product categories Key compliance factors 
      United States (US) Packaging, electronics, pharmaceuticals…State-level EPR laws enacted in states like Maine, Oregon, Colorado, California, and Maine, with others in development, focussing on packaging. No national policy and none expected under the Trump administration. 
      Canada Packaging, electronics, batteries, tyres… Province-level EPR laws enacted in British Columbia, Yukon, Alberta, Saskatchewan, Manitoba, Ontario, Québec, New Brunswick, and Nova Scotia. A Federal Plastics Registry on its way. 
      Brazil Packaging, electronics, batteries, tyres, agrochemicals… Brazil’s pioneering 2010 credit policy has recently been updated in 2022 to enhance enforcement and circularity where it has been lacking. Reverse logistics certificates as well as engaging the informal waste picking sector play a key role in monitoring and compliance. 
      Mexico Packaging, electronics, plastics, batteries, lighting… Largely organised at a state and local level, but Mexico’s new government has proposed expansions to circularity and recycling targets (e.g., for electronics) but feasibility and enforceability of these plans is debated. 
      China Packaging, electronics, batteries… Electronics and battery producers are tasked with waste management, implementing more eco-design, and transparency. EPR implementation for packaging expected to be added to this legislation in 2025. 
      Japan Packaging, electronics, vehicles, appliances… Some form of EPR in place since the 1990s, making it the first in Asia, with most of the focus on bottles and other packaging. Specific laws, created in the 1990s and 2000s, dictate each product type, from vehicles to appliances. 
      South Korea Packaging, batteries, tyres, lubricants… The system is managed centrally, unlike some countries, where it is done by industry, but companies can choose to manage it themselves. High financial penalties for non-compliance, much greater than the cost of recycling. 
      India Plastic, batteries, electronics, tyres… Separate laws govern different product types, but all require registration with the Central Pollution Control Board (CPCB). Often implemented by the informal waste management sector. 
      Australia Packaging, electronics, batteries, tyres… Much of the waste is managed by voluntary and mandatory “product stewardship schemes” at the federal and regional levels, but some categories, such as tyres and mobile phones are led by the industries themselves. 
      South Africa Packaging 2020 legislation requires producers of paper and plastic packaging to integrate EPR principles. Registration with the Department of Forests, Fisheries, and the Environment or, later, the Waste Information Centre, is mandatory. 

      As illustrated in the table above, EPR strategies and their scope differ significantly across countries, even among those that have implemented these policies for many years. In some nations, EPR is managed at the federal level, while in others, it is handled regionally. The responsibility for these programs also varies—some are led by governments, others by industries, and in many cases, they involve coalitions of multiple stakeholders. The primary areas of focus are typically packaging and single-use plastics, with an increasing emphasis on electronic waste as its generation continues to rise. 

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      Looking ahead, EPR policies are expected to become more stringent, with increased reporting requirements, stricter eco-design mandates, and broader product coverage. Many jurisdictions are expanding EPR frameworks to include textiles, furniture, and other durable goods, in addition to traditional categories like packaging and electronics. Transparency will also be a growing focus, with digital tracking systems and producer responsibility databases (e.g., Canada’s Federal Plastics Registry) becoming more common. 

      Given the dynamic nature of Extended Producer Responsibility (EPR) frameworks worldwide, it is clear that these systems are continually evolving in response to shifting environmental, economic, and regulatory landscapes. As such, stakeholders must remain agile and attentive to emerging trends and policy developments in order to effectively navigate the changing global landscape of EPR. 

      To stay ahead of evolving EPR requirements, companies should: 

      • Monitor Regulatory Developments: EPR rules are constantly changing, and keeping track of new regulations at national, regional, and international levels is essential. 
      • Improve Product Design: Investing in eco-design, recyclability, and material reduction can help companies lower compliance costs and align with future regulations. 
      • Engage in Industry Partnerships: Many successful EPR programs are led by industry coalitions. Companies should explore partnerships with Producer Responsibility Organizations (PROs) and other stakeholders to share compliance burdens. 
      • Enhance Transparency and Reporting: With digital compliance tracking becoming a priority, businesses should establish robust data collection and reporting mechanisms to ensure they meet regulatory requirements. 

      As global EPR policies continue to evolve, businesses that take a proactive approach will be better positioned to navigate regulatory challenges, reduce environmental impact, and strengthen their brand reputation in a sustainability-driven market. Keeping a close eye on legislative changes and emerging best practices will be key to long-term success in the circular economy. 

      Sources:

      – “EPR in the Global Packaging Industry” by Misbah Syed (Oct 2024) Extended Producer Responsibility (EPR) in the Global Packaging Industry: A 2024 Analysis | LinkedIn 
      – “Extended Producer Responsibility Laws for Packaging Around the World” by Mitch Webster for PackagingSchool (Feb 2024) Extended Producer Responsibility Laws for Packaging Around The World 

      Country-specific:

      United States: 
      – “EPR by Product” by Product Stewardship Institute (Sep 2024) EPR by Product Archives – Product Stewardship Institute 
      – “EPR: Extended Producer Responsibility Laws in the US” by Katie Krasts for SpecRight (Feb 2025) Extended Producer Responsibility (EPR) Legislation | Specright 
      – “Outlook for Trump Administration Environment, Energy, and Natural Resource Regulation, Enforcement, & Ligitation” by Beveridge & Diamond (Jan 25) Outlook for Trump Administration Environment, Energy, and Natural Resource Regulation, Enforcement & Litigation 
      -“Pharmaceuticals” by Product Stewardship Institute (n.d.) Pharmaceuticals Archives – Product Stewardship Institute  

      Canada: 
      – “EPR Packaging Laws in Canada: Where are we now?” by RLG (Sep 2024) EPR Packaging Laws in Canada: Where are we now? – Reverse Logistics Group 
      – “Recent Changes to Extended Producer Responsibility in Canada” by Borden, Ladner, & Gervais (Nov 2024) Recent changes to extended producer responsibility in Canada | BLG 

      Brazil:  
      –  “Brazil’s Environment Ministry to enforce solutions for product waste” by BVRio (Jul 2024) Brazil’s Environment Ministry to enforce solutions for product waste | BVRIO 
      – “Brazil Solid Waste Legisation (PNRS)” by Circular Action Hub (n.d.) Brazilian Solid Waste Legislation – Circular Action Hub 
      – “Out with the old: Solid waste management changes in Brazil” by Fernanda Negrão Pereira (Nov 2022) for Enhesa Out with the old: Solid waste management changes in Brazil | Enhesa 

      Mexico: 
      -“Challenges in Mexico’s Electronic Waste Recycling Goals” by Eliza Galeana (Feb 2025) for Mexico Business News Challenges in Mexico’s Electronic Waste Recycling Goals 
      – “Extended Producer Responsibility in Mexico: A Human Rights Perspective” by Adalberto Méndez (Jun 2023) for the International Alliance of Waste Pickers and WIEGO mexico-epr_IAWP_english.pdf 

      China:
      “China: Existing Regulations Related to Extended Producer Responsibility (EPR)” by Regional Knowledge for Marine Plastic Debris (2024) Extended Producer Responsibility | RKC-MPD 

      Japan: 
      – “End-of-Life Vehicle Recycling: A Comparative Analysis of China and Japan” by Auto Recycling World (Sep 2024) End-of-Life Vehicle Recycling: A Comparative Analysis Of China And Japan – Auto Recycling World 
      – “Japan” by Regional Knowledge for Marine Plastic Debris (Mar 2024) Extended Producer Responsibility | RKC-MPD 
      – “Solid Waste Management and Recycling Technology in Japan” by the Ministry of Environment (2012) swmrt.pdf 

      South Korea: 
       – “EPR Policies” by KORA (n.d.) kora 
      – “South Korean Extended Producer Responsibility (EPR) System” by Lorraine Li for ChemLink (Oct 2024). South Korea Extended Producer Responsibility (EPR) System | ChemLinked 

      India: 
      – “A Guide to EPR Compliance in India” by Recykal (Aug 2023). A Guide to EPR Compliance in India – Recykal  
      – “Extended Producer Responsibility: Indian Perspective” by Global Product Compliance Group (2024) qKTwo3C0RjT4padtrmpa8Imjn.pdf 

      Australia: 
      – “Australia proposes to reform packaging regulations, involving EPR for packaging” by Sadie Shen for ChemLinked (Oct 2024) Australia Proposes to Reform Packaging Regulations, Involving EPR for Packaging | ChemLinked 
      – “Product Stewardship” by the Australian Government Department of Climate Change, Energy, the Environment and Water (2013) Product stewardship – DCCEEW 
      – “Reform of Packaging Regulation: Consultation Summary” by the Australian Government Department of Climate Change, Energy, the Environment and Water (Feb 2025) Reform of packaging regulation: Consultation summary – DCCEEW 

      South Africa: 
      –  “Everything you Need to Know about Section 18 Regulations to the National Environmental Management: Waste Act” by MPact Waste Management (Oct 2022) Section 18 Regulations | Extended Producer Responsibility 

      14 March, 2025
    • Omnibus package – incoming changes in ESG reporting

      The European Commission’s proposals to simplify ESG regulations as part of the so-called Omnibus Package published on February 26th 2025 have sparked a wide debate on their impact on the functioning of companies. The main objective of the changes is to reduce the administrative burden on enterprises and improve their competitiveness. However, there is a risk that reducing ESG reporting obligations could lead to a loss of availability of key ESG data for investors in the long term and difficulties in monitoring sustainability progress.

      ESG deregulation – intentions and consequences

      Both legislative packages – Omnibus I and Omnibus II – are aimed at simplifying the requirements for companies, especially in the field of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDD). The key assumption is to reduce administrative obligations by about 80%.

      The new regulations will apply only to the largest enterprises which:

      • employ over 1000 employees
      • and generate annual revenues exceeding EUR 50 million and/or having a balance sheet total of more than EUR 25 million.

      All other companies will be able to report voluntarily (using the VSME standard), which will ultimately be issued in the form of a delegated regulation.

      The reporting schedule has also been changed. Companies that were supposed to publish a sustainability report for the first time in 2026 or 2027 will be given additional two years to adapt to the new requirements.

      In addition, sector-specific reporting standards have been removed, meaning that companies will not have to adapt reports to industry-specific guidelines.

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      Regulatory perspective – what’s next?

      The Omnibus package also provides for the simplification of reporting in the field of:

      • EU Taxonomy – Disclosures regarding the Taxonomy will be mandatory only for companies that both have more than 1000 employees and annual revenues above EUR 450 million.
      • CBAM (Carbon Border Adjustment Mechanism) – 90% of importers (mainly SMEs and individuals) have been exempted from the CBAM obligation.
      • Audit of the report – The requirement for “limited assurance” will remain in force. ESG reports will be subject to limited verification by auditors (less rigorous control, based on the analysis of available information and the assessment of the probability of errors).
      • CSDDD requirements – Risk assessment in the activity chain will focus on direct business partners (Tier 1) with at least 500 employees hired.

      Conclusion

      The proposed changes to ESG reporting as part of the Omnibus Package are an important step towards simplifying regulations and reducing the administrative burden on enterprises. For many companies, this means reduced costs and greater flexibility in terms of sustainability activities.

      However, the limitation of ESG reporting also comes with serious risks. It may lead to a decrease in transparency on the markets, limit the access of smaller companies to financing and weaken the effectiveness of the EU’s climate policy. A key challenge for businesses will be to find a balance between the benefits of deregulation and the long-term sustainability goals.

      Regardless of future legislative decisions, companies should continue to pursue ESG strategies, even if they are not formally required to report. Sustainable development continues to be an increasingly important element of business strategy, which not only generates cost reduction by increasing the efficiency of processes, attracts investors, but also allows for building long-term value and resilience to market changes.

      28 February, 2025
    • 5 ways SMEs can manage the financial pressures of EPR compliance

      Managing compliance with Extended Producer Responsibility (EPR) regulations can be particularly challenging for smaller businesses, which often operate with limited budgets and resources. However, there are several strategies these businesses can adopt to minimize costs while fulfilling their obligations.

      Join collective compliance schemes

      Many small producers can benefit from joining compliance schemes or producer responsibility organizations (PROs). These schemes handle much of the administrative and logistical burden of EPR compliance, including waste collection, recycling coordination, and reporting. While there are membership fees involved, the shared infrastructure and expertise significantly reduce costs compared to setting up independent compliance systems.

      EFF can help your business simplify this process further! Instead of having to contact and coordinate with a unique PRO for each of your products and markets, partner with EFF with our EPR Attorneys will be your one-stop shop for organising all of these communications. We’ll work with you and the PROs to understand each of your requirements and make sure that you are meeting all your obligations in a timely manner.

      Start simplifying your processes now!

      Schedule a meeting with one of our experts and see how we can help your business. Contact us to discuss the details.
      Contact us

      Focus on sustainable product design

      Redesigning products and packaging to align with recyclability and sustainability standards can reduce modulated EPR fees. For instance, using mono-material packaging or incorporating higher levels of recycled content can lower financial obligations under many EPR frameworks. Proactive eco-design can also appeal to eco-conscious customers, creating long-term business value beyond compliance.

      Leverage government and industry support

      Many EU countries provide financial incentives, grants, or technical support to help small and medium-sized enterprises (SMEs) transition to sustainable practices. These programs can offset costs related to material changes or compliance adjustments. Additionally, working with industry bodies or trade associations can provide access to shared resources and advocacy for proportionate EPR policies.

      Streamline reporting and data management

      EPR regulations often require detailed reporting, which can be resource intensive. Investing in software or consulting services that automate data tracking and reporting can save time and reduce the likelihood of penalties for inaccuracies. Partnering with compliance specialists ensures that reporting is efficient and adheres to regulatory deadlines.

      Engage in supply chain collaboration

      Smaller businesses can work closely with suppliers to source compliant materials or optimize packaging for sustainability. By collaborating on eco-friendly solutions, they can achieve compliance while sharing costs and innovation efforts across the supply chain.

      By combining these approaches, small businesses can not only reduce the financial burden of EPR compliance but also turn it into an opportunity for innovation and competitive advantage. Strategic adaptation to EPR policies positions these businesses to thrive in a marketplace increasingly driven by sustainability.

      Sources:

      – ECommerce Europe (2020) “Extended producer responsibility policies that work for SMEs in Europe – Ecommerce Europe”
      ECommerce Europe (2023) “ECOM-Position-paper-PPWR-April-2023.pdf”
      Medium (2024) “Support of Micro, Small, And Medium Enterprises with EPR Registration Business. | by Ascgroup | Medium”
      PWC (2023) “How will Extended Producer Responsibility (EPR) affect you? | PwC”
      Reusable Packaging Europe (2024.) “The Extended Producer Responsibility in the EU: from fragmentation to harmonisation – Reusable Packaging Europe”

      10 February, 2025
    • All about the PPWR

      The EU’s Packaging and Packaging Waste Regulation 2025/40 (PPWR) officially enters into force on Tuesday, 11th February. Currently, roughly 40% of plastics used in the EU are for packaging, and in 2021, each EU resident generated approximately 36.1 kg of plastic packaging waste—an increase of 8.1 kg (29%) compared to the previous decade.

      Packaging and Packaging Waste Regulation

      First adopted in late 2022, this legislation amends and replaces the Packaging and Packaging Waste Directive 94/62/EC (PPWD) of 1994. The general date of application for the PPWR will be 12th August 2026, 18 months after its entry into force, at which point the PPWD will be officially repealed.

      Both the PPWD and PPWR regulate packaging placed on the EU market while introducing packaging waste management and prevention measures.

      Key elements

      According to the European Commission, key elements of the new legislation include:

      • “Restrictions on certain single-use plastics, such as pre-packed fruit and veg weighing less than 1.5 kg and individual portions of condiments, sauces, and sugar in hotels, bars and restaurants.
      • Minimising the weight and volume of packaging and avoiding unnecessary packaging.
      • 2030 and 2040 targets for a minimum percentage of recycled content in packaging.
      • A requirement for take-away businesses to offer customers the option to bring their own containers at no extra cost.
      • Minimising substances of concern, including restrictions on packaging containing per- and polyfluorinated alkyl substances (PFAS) if they exceed certain thresholds.”

      This legislation will affect a wide range of businesses, including packaging manufacturers, e-commerce platforms, and retailers and distributors, among others. It covers materials and packaging for commercial, household, and industrial use. It covers commercial, household, and industrial packaging materials, meaning its impact will be felt across multiple sectors. As a result, its implementation and long-term effects will be closely monitored across Europe.

      recyclable packaging

      Why does packaging waste matter?

      Properly managing and reducing packaging waste is essential for achieving many of the EU’s environmental goals, including five of the six objectives of the EU Taxonomy:

      • Climate Change Mitigation – Plastics accounted for approximately 3.4% of global emissions in 2019, including emissions from production and disposal.
      • Protection of Water and Marine Resources – Around half of marine litter comes from packaging waste.
      • Transition to a Circular Economy – The EU’s packaging waste recycling rate has stagnated at around 64–65% for over 15 years, with plastic packaging at only 40.7%.
      • Pollution Prevention and Control – Both plastic and paper-based packaging have been found to contain hazardous and carcinogenic chemicals, such as PFAS, according to the Environmental Defense Fund and Zero Waste Europe.
      • Biodiversity and Ecosystem Protection – Paper-based packaging remains the most widely used packaging material in the EU and is a major driver of deforestation in Europe and beyond, according to the European Environmental Bureau.

      Beyond material substitution: The need for systemic change

      The sustainability of single-use packaging is not determined solely by material choice. As Marco Musso, Senior Policy Officer for Circular Economy at the European Environmental Bureau, explains:

      This study sounds the alarm on the false solutions of substituting one single-use material for another… To credibly prevent waste EU decision-makers must focus on restricting avoidable packaging while promoting efficient and convenient reuse systems.

      The PPWR—with its obligations to minimise excessive packaging and reduce hazardous substances—is a significant step forward in achieving the EU’s environmental objectives. However, it is just one piece of the puzzle.

      For example, packaging is a key component of Extended Producer Responsibility (EPR) schemes, which go further by placing the onus on producers to manage the waste they generate and introduce into the market.

      Next steps

      To learn more about how EFF can help you register your packaging and packaging waste with your local EPR system, contact us!

      For further details on the legislation, you can read the full Regulation 2025/40 here.

       

      Sources:

      “Beyond paper: PFAS linked to common plastic packaging used for food, cosmetics, and much more”). Tom Neltner for the Environmental Defense Fund. (2021
      “How much of global greenhouse gas emissions come from plastics?” Hannah Ritchie for Our World in Data. (2023).
      “Packaging Waste”. European Commission (n.d.)
      “Packaging waste statistics”. Eurostat. (2024).
      “Paper-based food packaging at the centre of Europe’s waste crisis, new report reveals”. Abou-Chleih for the European Environmental Bureau. (2023).
      “Plastic Waste and Recycling in the EU: Facts and Figures”. European Parliament. (2018/2024).
      “41% of plastic packaging waste recycled in 2022”. Eurostat. (2024).

      7 February, 2025
    • January updates to EU taxonomy

      This month, the EU’s Platform on Sustainable Finance (PSF) initiated a public consultation to collect feedback on the updates made to the EU Taxonomy, as system for classifying and reporting on sustainable activities. The intention was to improve usability and simplicity while expanding the scope of the activities included.

      Updates to EU taxonomy

      The organisation published a report with initial findings from extensive stakeholder engagement, particularly with companies, and is now seeking further consultation from the public. In introducing the note to the report, Helena Viñes Fiestas, Chair of the PSF, stated:

      During this period, our priority has been to improve the usability and effectiveness of the Taxonomy and the broader sustainable finance framework. Once the necessary changes have been implemented, the Platform hopes that a future mandate will allow us to focus on incorporating many more activities into the Taxonomy.

      Currently, the EU Taxonomy includes the following sectors and their activities:

      Accommodation activitiesArts, entertainment, and recreationConstruction and real estate activitiesDisaster risk management
      EducationEnergyEnvironmental protection and restoration activitiesFinancial and insurance activities
      ForestryHuman health and social work activitiesInformation and communicationManufacturing
      Professional, scientific, and technical activitiesServicesTransportWater supply, sewerage, waste management and remediation

      Proposed changes include expanding the scope to include areas such as digital services or mining and smelting of key metals such as lithium, copper, and nickel. Other metal manufacturing, such as that of iron and steel, is included in the Taxonomy list of activities.

      To be considered sustainable, an activity must contribute significantly to at least one of the following six objectives and Do No Significant Harm (DNSH) to any of the others, as well as complying with the minimum safeguards.

      Pollution prevention and controlMarine and water resource protectionBiodiversity and ecosystem protection
      Climate change adaptationClimate change mitigationCircular Economy transition

      One aspect of the feedback was the call for the criteria and instructions to be made clearer and more practicable. This is essential for implementation and interpretation of results because, as in the technical screening criteria, the report states:

      A clear description of the technical screening criteria reduces implementation costs and ensures that criteria be interpreted in the same way by different preparers and auditors, providing comparability of the reporting results.

      Another area of improvement is in the DNSH criteria, particularly in regard to new activities proposed.

      You can read the official report here.

      The consultation is open to the public from January 8 to February 5, 2025. Stakeholders are invited to share their evidence-based feedback via the official consultation link.

       

      Sources:

      – “Call for feedback by the PSF on preliminary recommendations for the review of the Climate Delegated Act and the addition of activities to the EU taxonomy” by the European Commission (Jan 2025). Available at Call for feedback – Platform on Sustainable Finance
      “EU Platform on Sustainable Finance Proposes Key Updates to EU Taxonomy” by ESG News (Jan 2025). Available at EU Platform on Sustainable Finance Proposes Key Updates to EU Taxonomy – ESG News
      “EU Platform on Sustainable Finance Unveils Proposals to Simplify, Expand EU Taxonomy” by Mark Segal at ESG Today (Jan 2025). Available at EU Platform on Sustainable Finance Unveils Proposals to Simplify, Expand EU Taxonomy – ESG Today
      “EU Taxonomy Navigator” by the European Commission (n.d.). Available at EU Taxonomy Navigator
      “Platform on Sustainable Finance Draft Report on Activities and Technical Screening Criteria to be Updated or Included in the EU Taxonomy” by the Platform on Sustainable Finance (Jan 2025). Available at Platform on Sustainable Finance draft report on activities and technical screening criteria to be updated or included in the EU taxonomy

      7 February, 2025
    • Switzerland to introduce annual VAT reporting in 2025

      Starting from January 2025, Switzerland will introduce an option for businesses with a turnover of up to CHF 5,005,000 to switch to annual VAT reporting. This new system will provide an alternative to the current quarterly, semi-annual, or monthly reporting requirements. The change aims to simplify VAT compliance for smaller businesses while maintaining efficient tax collection.

      Eligibility criteria

      To qualify for the annual VAT reporting option, businesses must meet two key criteria. First, their annual turnover must not exceed CHF 5,005,000. Secondly, the business must have a clean VAT compliance history, meaning timely VAT filings and full payments for the last three periods. The Swiss Federal Tax Administration (SFTA) will verify compliance before granting approval. Businesses that wish to opt for the annual VAT reporting system must submit an application through the ePortal by February 28, 2025. New businesses, however, have 60 days from receiving their VAT number to apply.

      Advance VAT payments

      Under the new system, businesses will be required to make advance VAT payments. These payments, calculated by the SFTA, will be due in instalments on May 30, August 30, and November 30. For those using the net tax rate method, only the August 30 payment is required. These advance payments are based on an estimated tax liability and can be adjusted up to 10 days before the due date. However, if the advance payments are deemed insufficient—specifically if they are below 50% or 35% of the total tax claim—they may be considered inadequate, potentially leading to penalties.

      Filing and payment

      The annual VAT statement, which will include final VAT calculations, must be submitted and paid by the end of February in the following year. Businesses will have the option to request extensions or make corrections to the submitted VAT return. If a business overpays its VAT in advance, the excess amount will be refunded after the annual reconciliation.

      Revocation of the option

      If a business exceeds the CHF 5,005,000 turnover threshold or fails to meet VAT obligations on time, it will lose the right to opt for annual VAT reporting. In such cases, the business will be required to revert to the more frequent reporting periods, such as quarterly or semi-annual returns.

      This shift to annual VAT reporting in Switzerland offers businesses an opportunity to streamline their VAT reporting obligations. However, careful attention to compliance and timely payments will be essential to avoid penalties and ensure smooth operation under the new system.

      How can EFF help?

      As the new VAT reporting system in Switzerland takes effect, businesses may find the transition challenging. EFF offers comprehensive VAT services, including VAT registration, compliance, and reporting. By choosing EFF, businesses can ensure that they meet all regulatory requirements while saving time and avoiding potential penalties. Contact us today to see ho we can help your business!

       

      Sources:

      – Federal Tax Administration VAT changes

      7 February, 2025
    • The Estonian Ministry of Finance has proposed changes to VAT reporting and mandatory e-invoicing to enhance VAT receipts

      The Estonian Ministry of Finance has proposed significant changes to VAT reporting and the implementation of mandatory e-invoicing to improve VAT collection.

      Changes to VAT reporting

      A key aspect of the reform is the removal of the €1,000 threshold for declaring transactions, requiring VAT payers to report all transactions. This change aims to close loopholes, as many small transactions under the threshold are often undeclared, contributing to tax evasion. In 2023, approximately €327 million in input VAT went unreported.

      A 2014 reform, which required more detailed invoice declarations, resulted in an increase of over €100 million in VAT receipts. Building on this success, the Ministry believes that the introduction of e-invoices will further enhance VAT receipts by reducing administrative burdens, improving data quality, and preventing fraud. Already, 47% of entrepreneurs are prepared to adopt e-invoicing, which will also be mandatory for cross-border transactions within the EU from July 1st, 2030.

      The proposed changes are expected to increase VAT receipts by €16.6 million annually and could take effect by 2027. These measures align with broader EU trends, as several countries are also moving towards mandatory e-invoicing.

       

      Sources:

      https://www.fin.ee/uudised/rahandusministeerium-esitas-ettepanekud-kaibemaksulaekumise-parandamiseks

      6 February, 2025
    • Extended Producer Responsibility (EPR)

      Failure to comply with the rules of Extended Producer Responsibility (EPR) carries a number of sanctions, ranging from a restriction or complete ban on the sale of a product, to loss of brand reputation, to monetary fines or confiscation of goods. More and more countries are adopting EPR as a mandatory environmental policy, so its tenets are strictly enforced. Manufacturers that fail to comply with its provisions or use inappropriate waste management practices face numerous consequences. The severity of possible restrictions depends on both the scale of the violation and the size of the company, while their effects have a…

      What exactly is EPR?

      Extended Producer Responsibility (EPR) is a type of environmental policy that was first implemented in Sweden and has subsequently gained popularity in many countries around the world. The policy is based on the “polluter pays” principle, thus regulating the producer’s responsibility for the products they put on the market. Its application directly contributes to the development of a circular economy.

      The main goal of EPR is proper waste management and sustainable consumption of raw materials.

      According to the policy, manufacturers are responsible for the entire life cycle of products, from the moment they are manufactured to the end of their useful life. Accordingly, regulations govern the management of generated waste through payment of fees for collection, recycling, reuse and disposal.

      Who is affected by the EPR regulations?

      In short, the provisions of Extended Producer Responsibility apply to any person who takes part in a product’s introduction to the market. In other words, any legal or natural person whose business activity consists of developing, manufacturing, processing, selling or importing products, regardless of how they are placed on the domestic market.

      Companies that sell their products directly to end consumers (B2C) are subject to different regulations than those that trade with retailers or distributors (B2B). Moreover, the requirements applied to domestic sellers differ from those applied to international sellers. Therefore, it is important to consider the type of business you are doing in order to correctly determine your obligations.

      Who should apply for an EPR registration number?

      • Individuals and companies that manufacture products subject to EPR
      • Vendors of products subject to EPR

      What products are subject to EPR?

      In order to reduce waste and contribute to the development of a circular economy, the particulars of EPR are regularly updated. According to experts’ predictions, more and more products will be strictly regulated in the coming years.

      Products covered by EPR:

      • Packaging
      • Batteries
      • Electrical and electronic equipment
      • Used industrial oils
      • Tires
      • Vehicles
      • Furniture

      What is a Producer Responsibility Organization (PRO)?

      A Producer Responsibility Organization (PRO) (PRO) is an entity established under the Extended Producer Responsibility (EPR) system. Its task is to relieve producers of their responsibilities for managing waste resulting from their operations, in particular collection, recovery and recycling.

      Key features and role of PRO:

      • Assumption of producer obligations: PRO acts on behalf of producers, assuming their waste management obligations. Producers pay fees to the PRO, which funds recycling and recovery activities.
      • Waste management: PRO is responsible for organizing the collection, transport, recycling, and reuse of waste generated from products placed on the market.
      • Supporting a circular economy: Through waste reuse and recycling activities, PRO contributes to waste minimization and supports sustainable development.
      • Regulations: PRO’s operations are strictly regulated in each country, often stemming from EU directives such as Directive 2008/98/EC on waste. These organizations are often subject to supervision to ensure compliance with regulations and the achievement of specific recycling targets.
      • Application in various industries: PROs operate in many sectors, such as packaging, electronics, vehicles, batteries, and textiles. Each industry may have specific waste management requirements.

      How to contact us?

      Customers can contact our sustainability experts directly. At an arranged meeting, we determine how we can best meet your EPR needs. Although we operate mainly in Poland, we have many years of experience working with clients from all over Europe. Don’t hesitate to contact us if you think you could benefit from our expertise!

      Do you have any questions?

      Don’t hesitate to reach out if you think our expertise could help you!
      Contact us

      Responsibilities

      Extended Producer Responsibility (EPR) regulations can vary from country to country, so it is important to verify exactly what obligations apply to the specific category of products a company markets. Despite the many differences, a common feature of the vast majority of cases is the presence of declaratory and financial obligations.

      The main obligations of producers in Poland under the EPR:

      1. Financing of waste management – manufacturers are required to cover the costs of collecting, transporting, recovering and recycling waste generated from their products. These costs include, among others:
        • Selective waste collection,
        • Environmental education,
        • Reporting on waste management activities.
      2. Achieving recycling levels – manufacturers must meet certain recycling and recovery quotas, which are set by national and EU regulations. For example, in the case of packaging, a certain percentage of materials such as plastic, glass and paper are required to be recycled.
      3. Cooperation with producer responsibility organizations (PROs) – producers can delegate their waste management responsibilities to PRO organizations, which manage collection and recycling processes on their behalf. The producer pays an appropriate fee for this.
      4. Reporting – manufacturers are required to submit detailed reports on:
        • The amount and type of products marketed,
        • recycling and recovery activities undertaken,
        • Implementation of obligations related to environmental education.
      5. Eco-design of products – EPR encourages manufacturers to design products in ways that minimize their environmental impact, such as by:
        • Limiting the amount of materials used,
        • Use of recyclable raw materials,
        • Facilitating product disassembly and repair.
      6. Funding environmental education – manufacturers are required to conduct or finance educational activities that raise public awareness about separate collection, recycling and waste reduction.
      7. Product labeling obligation – products placed on the market must be labeled in a way that facilitates their subsequent segregation and recycling. This applies especially to packaging.

      Example: Obligations for the packaging industry in Poland

      Manufacturers marketing packaged products must:

      • report the amount of packaging put on the market,
      • achieve certain recycling levels (e.g., for plastic or glass),
      • pay fees to the waste management system, including to PRO organizations,
      • ensure that their products are labeled in accordance with regulations to facilitate selective collection by consumers.

      Learn more about extended producer responsibility.

      Explore our offer.
      Read more

      What do we offer?

      We work with companies, manufacturers and individuals marketing electronic and electrical equipment, batteries and packaging, offering comprehensive support, including:

      • Initial consultation to determine customer needs
      • Individual case analysis
      • Regulatory compliance analysis
      • Calculation of estimated EPR charges
      • Registration in the register of producers
      • Support for appointment of attorneys
      • Establish contact with Producer Responsibility Organizations
      • Benchmarking and advising on EPR best practices
      • Regular mapping and monitoring of legislative changes
      • Advice on labeling responsibilities
      4 February, 2025

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