Lithuania EPR Guide | Lovat Compliance

Lithuania: Extended Producer Responsibility (EPR) for packaging

The Law on Packaging and Packaging Waste Management in the Republic of Lithuania entered into force in 2003, but the law was amended and supplemented until 2023. The regulations governing packaging and the proper handling of packaging waste must be followed by all those involved in packaging and business operations.

Who is considered responsible

All manufacturers and retailers are required to comply with the regulations outlined in the Lithuanian Packaging Act, and these provisions apply to anyone distributing packaging materials to Lithuania:

Manufacturers
Packaging manufacturers
Importers
Intermediaries
Sellers
Waste handlers

What the packaging includes

The packaging supplied to the Lithuanian market is considered to be the packaging used in the products for sale.

Packaging within the meaning of the Packaging Act may consist of the following materials:

plastics
paper and cardboard
metal
wood
textiles
glass
combination bags

Thresholds

Producers are required to keep records of all packages of finished products, regardless of the volume of the package. The registration limit for the EPR rules is 0.5 tons of packaging. Producers and importers supplying more than 0.5 tons of packaging to the territory of the Republic of Lithuania are required to pay an environmental tax on packaging waste.

Producers’ Commitments for Extended Producer Responsibility (EPR) in Lithuania

1 Extended producer responsibility (EPR) Registration in Lithuania

Mandatory enrollment in the Unified Product, Packaging and Waste Information System (GPAIS) required for all packaging manufacturers and importers. Licenses are issued by the Ministry of Environment or its authorized licensing authority through the GPAIS system. Waste records must be kept in GPAIS by waste management companies. Product distributors incorporate accepted product waste into their product waste logbooks, eliminating the necessity to record this waste in GPAIS.

2 EPR certification with Producer Responsibility Organization (PRO)

There are presently three operational Packaging Recovery Organizations (PROs) in Lithuania, established as public entities. In cases where the nature of enterprises’ activities suggests Extended Producer Responsibility (EPR) requirements under the law, government inspectors and PROs will provide information to the enterprises.

3 Declaration

The manufacturer or importer must prepare and submit an FR0524 tax return for the previous calendar year, detailing environmental pollution resulting from packaging waste in alignment with packaging records.

Data concerning the generation of packaging waste is derived from industry declarations related to products introduced to the market. The Packaging Recovery Organization (PRO) enforces monitoring measures to deter the evasion of Extended Producer Responsibility (EPR) obligations and to ensure compliance.

4 Settlement of charges

The fee paid to the Extended Producer Responsibility (ERP) organization by its members for the management of packaging waste varies according to the types of materials and the adaptability of the packaging for reuse and recycling. Lithuania employs a payment system that adjusts based on the recycling level.

Authorized representative

In Lithuania, a foreign packaging supplier is not obligated to appoint a local representative and can independently fulfill its responsibilities.

Reporting Deadline

Product or packaging records can be kept daily, monthly, or quarterly, with a requirement to log waste quantity within 5 working days after each calendar month.

The Administrator of the Reusable Packaging Deposit Scheme must electronically share details on reusable packaging accountability with the Environment Agency by February 20th annually.

Penalties or Sanctions

Neglecting to carry out separate waste collection from non-household sources may lead to the issuance of a warning or a fine ranging from 20 to 80 euros.

If taxpayer hides the amount of products or packaging they provide to the market in Lithuania and don’t report it to the tax authorities, the taxpayer could be fined 2% of their income. There’s a minimum tax of €10,000 for pollution caused by production or packaging waste if the calculated tax is less than €10,000.

Extended Producer Responsibility for EEE in Lithuania

According to Article 8 of the Resolution on approval of rules for handling electrical and electronic equipment and its wastes of 15.08.2018, the producers or importers of electrical and electronic equipment have to consider and organize the collection, transportation, recycling of waste electrical and electronic equipment.

Examples of products subject to EEE in Lithuania

Temperature change equipment;
Screens, monitors and equipment with a screen area greater than 100 cm2;
Light bulbs;
Large-sized electrical appliances;
Small-sized electrical appliances;
Small information technology and telecommunications equipment.

Who must register

Domestic producers require mandatory registration with the Regional Department of Environmental Protection of the Ministry of Environment of the Republic of Lithuania, while foreign producers must also register with the Environmental Protection Agency before supplying electrical and electronic equipment to Lithuania.

Threshold

There are no thresholds. Each manufacturer is required to register before trading in electronic and electrical equipment in Lithuania.

Registration procedure

The producer submits online or in writing to the Regional Department of Environmental Protection of the Ministry of Environment of the Republic of Lithuania an application for registration in the Cadaster of producers and/or importers.

The producer of electrical and electronic equipment, who indicated in Section III of the Application that company independently organizes waste management of electrical and electronic equipment, submits together with the Application a document confirming the financing of waste management of electrical and electronic equipment.

Foreign entities supplying electrical and electronic equipment are obligated to provide, upon registration, the amount of electrical and electronic equipment to be supplied to the Lithuanian market in the current year.

Authorized representative

Companies producing Electrical and Electronic Equipment (EEE) and situated outside Lithuania can avail themselves of the option to grant written authorization to an entrepreneur in Lithuania. This authorization allows the Lithuanian entrepreneur to assume responsibilities for adhering to waste electrical and electronic equipment management requirements on behalf of the overseas company.

Reporting Deadline

The declarations should be submitted no later than 50 days after the end of the previous year via the Unified Product, Packaging, and Waste Information System (GPAIS) to the Environmental Protection Agency (EPA).