Luxemburg: Extended Producer Responsibility (EPR) for Packaging
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 Assumes Responsibility?
The Packaging Act and its accompanying regulations apply to a broad spectrum of stakeholders:
- Producers
- Distributors
- Importers
- Manufacturers
What Constitutes Packaging?
- Paper and cardboard
- Metals
- Plastics
- Glass
- Wood
- Aluminium
Thresholds
No minimum quantities exempt individuals from these obligations—even a single product item demands compliance.
Producers’ Duties under Extended Producer Responsibility (EPR) in Luxembourg
Producers are required to engage in the following steps to adhere to EPR regulations:
1- Registration
- 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.
2- Fee Payments
- The fee amount varies based on the type and volume of packaging introduced to the market.
- The minimum annual contribution stands at EUR 50.
3- Reporting
- Producers are obligated to furnish annual packaging reports.
Authorized Proxy
Producers are obliged to designate a local authorized proxy in Luxembourg who will fulfill the packaging law requirements on the producer’s behalf.
Reporting Deadline
The deadline for submitting the annual declaration is February 28th, specifically for packaging.
Penalties
A fine equivalent to 1% of the contribution from the previous declaration is applicable for each month of delay.”