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Extended producer responsibility (EPR) for packaging in Luxembourg
Complying with the latest legal amendments enacted on March 21, 2017, addressing packaging and packaging waste and the subsequent revisions introduced on June 9, 2022, pertaining to waste management, packaging materials are now held under the scope of extended producer responsibility.Who must register for packaging EPR in Luxembourg
Obligated parties under EPR packaging Luxembourg include:- Manufacturers and importers of packaged goods
- Retailers and distributors, including online stores
- E-commerce companies, even based abroad, if selling directly to Luxembourg consumers
- Private-label brands
What the program includes
EPR Luxembourg covers all packaging materials and usage types:- Household packaging (e.g., plastic bottles, glass jars, paperboard)
- Commercial/industrial packaging
- Primary, secondary, and tertiary packaging
- All material types: plastic, glass, metal, paper/cardboard, composite, and wood
Thresholds
No minimum quantities exempt individuals from these obligations—even a single product item demands compliance.EPR registration procedure in Luxembourg
Steps for EPR registration Luxembourg:- Producers must enter into an agreement with an eco-operator (Responsible Extended Organization) to secure a participation certificate within the system
- Submit an annual report to the Ministry of Environment, Climate, and Development
- The fee amount varies based on the type and volume of packaging introduced to the market. The minimum annual contribution stands at EUR 50
- Producers are obligated to furnish annual packaging reports
Authorized representative
Luxembourg currently does not require the appointment of an Authorized Representative (AR) for foreign companies. However, non-resident producers should consider designating a local intermediary (e.g., fiscal representative or logistics partner) to ensure compliance and facilitate EPR registration Luxembourg.Reporting deadline
The deadline for submitting the annual declaration is February 28th, specifically for packaging.Who assumes responsibility?
The Packaging Act and its accompanying regulations apply to a broad spectrum of stakeholders:- Producers
- Distributors
- Importers
- Manufacturers
- Producers of Industrial and Commercial Packaging (B2B)
Duties of each group
- Producers: Declare and finance recycling for packaging introduced
- Valorlux: Collect, sort, recycle, and report on packaging waste
- Retailers/distributors: Monitor EPR status of suppliers
- Regulators: Conduct inspections and ensure enforcement
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