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Packaging recycling is a costly but crucial process for the environment. If you are a manufacturer introducing goods with packaging into the market, be sure to check if the product fee applies to you.
What is a product fee?
Legal regulations impose various obligations on entrepreneurs, including the responsibility for recycling packaging and products they introduce into circulation. The product fee is a form of settlement for fulfilling this obligation. It is imposed on manufacturers and importers of certain goods categories who have not ensured the required level of packaging recycling.
The product fee was introduced to draw attention to the negative impact of packaging waste on the environment and to highlight the high costs of its disposal. Therefore, the fee should serve as an incentive for maximizing the recycling of packaging waste.
Who Should Pay the Product Fee?
Certain categories of entities engaged in business activities should pay the product fee. These include entrepreneurs who:
- Introduce products in packaging into the domestic market for the first time.
- Import products in packaging.
- Import vehicles, agricultural machinery, etc.
- Introduce products in branded packaging or under their own brand.
- Introduce electrical and electronic equipment.
- Introduce batteries and portable accumulators.
- Introduce products such as oils, lubricants, pneumatic tires, and vehicles.
If you belong to one of the mentioned groups, it means that you should pay the product fee. However, what is the exact amount of the fee?
How much is the product fee and when is it due?
The amount of the product fee is calculated based on the weight of the manufactured products, expressed in kilograms. Detailed rates for various types of packaging are specified by regulations from the Minister of Climate and Environment, so it is in these regulations that one should look for the current fee amounts. However, the regulations also set a maximum rate, meaning that you will not pay more than 4.50 PLN per 1 kg for product packaging.
Entrepreneurs producing goods in packaging are required to pay the product fee by March 15, while for the introduction of products such as oils, lubricants, or pneumatic tires to the market, the deadline is March 31. The product fee is paid after the end of the calendar year, allowing for the inclusion of the entire accounting period.
What obligations are associated with the product fee?
In addition to paying a product fee, entrepreneurs are also obliged to conduct public educational campaigns that increase consumers’ ecological awareness. Entities subject to the obligation to pay a product fee should allocate at least 2% of the net value of packaging placed on the market for this purpose annually.
An alternative option is to transfer the same amount to a separate bank account of the voivodeship marshal.
However, public education campaigns are not everything. Entrepreneurs are also obliged to prepare annual reports on products, packaging and waste management. These reports take into account:
- import and export of packaging waste,
- weight of packaging introduced to the domestic market,
- intra-Community supply of products,
- organization of packaging recovery,
- information about public educational campaigns
The reporting obligation is very important because failure to fulfill it or incorrect performance may result in administrative fines. The report must be submitted to the appropriate authority by March 15 each year.
Does the entrepreneur fulfill the obligations related to the product fee independently?
An entrepreneur can fulfill the obligation of achieving the required levels of recovery and recycling either independently or through a packaging recovery organization. The organization enters into an agreement with the entrepreneur, committing to ensuring the recycling of the amount of packaging waste the company introduced into circulation in a given calendar year. The packaging recovery organization also takes on the responsibility for conducting public educational campaigns.
However, specific regulations apply to entrepreneurs introducing multi-material packaging to the market. They are not allowed to settle the packaging recovery independently or solely through an appropriate organization. In this regard, the legislator mandates collaboration with any Chamber of Commerce, which, on behalf of the entrepreneur, will fulfill the obligations of achieving the required levels of recycling for packaging waste.
Who is exempt from the product fee?
Entrepreneurs introducing small-sized equipment to the market are exempt from the product fee, provided that none of its external dimensions exceeds 50 cm, and the total mass of the equipment produced on average per year is less than 100 kg. The exemption also applies to large-sized equipment with the same maximum dimensions, but their total mass must not exceed 1000 kg.
To be exempt from the product fee, it is necessary to submit an application for de minimis aid by March 15 each year. It is also mandatory to provide all necessary information about the entrepreneur applying for the exemption and the business activities conducted by them. By completing all the formalities, producers meeting the specified criteria can be exempted from the product fee.
Benefits of Consulting with r2eko
In r2eko, we will assist you in calculating the amount of product fees and filing the appropriate reports. Incorrectly submitted reports may result in the obligation to pay administrative fines, but with our team of professionals, you won’t have to worry about that.
With years of experience, we can submit accurate reports not only for product fees but also for the amounts allocated to educational campaigns. Want to avoid fines? Trust our specialists and opt for consultancy at r2eko.
