Packaging and the upcoming legislative changes in Slovenia!

Packaging and the upcoming legislative changes!

Under the packaging, we consider all products of any material used to contain, surround, or hold goods together. In particular, its purpose is to protect the goods in the event of delivery of a mild delivery from their manufacturer to the user or the consumer. The packaging on the market of the Republic of Slovenia must be in line with the Regulation on the management of packaging and packaging waste (‘the Regulation’). Furthermore, it needs to report to the Slovenian Environment Agency (ARSO). If not, reporting debtors can pay a fine up to EUR 4 000.

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What counts as packaging?

  • foil wrapped around the CD box,
  • covers for sending catalogs and magazines (with magazines),
  • cake linings sold together with pastries,
  • rolls, tubes, and cylinders with flexible material (e.g. plastic film, aluminum, paper),
  • matches,
  • capsules for beverage vending machines (e.g. coffee, cocoa, milk) that are emptied when used.

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What’s not packaging?

  • flower pots in which plants remain for a lifetime, toolboxes,
  • tea filter bags,
  • capsules for a coffee maker, coffee bags of foil and paper filter coffee cartridges tossed together with the coffee product used,
  • printer cartridges,
  • boxes for CDs, DVDs, and video cases (sold together with a CD, DVD).


The manufacturer’s extended liability

Slovenian companies face changes in the field of packaging since a draft novel of the Regulation was submitted for public consideration in August. Below we summarise some of the amendments.

The proposed novel is otherwise governed by the manufacturer’s extended liability for persons who place packaging on the Slovenian market. What does that mean? This means that they will pay the costs of handling packaging waste, as well as have a financial and organizational obligation for all producers to ensure that all packaging waste is treated in the area of the Republic of Slovenia.


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Who counts as a manufacturer?

The Regulation defines who is the manufacturer who has this obligation and what counts as placing on the Slovenian market. Because of the change, any legal person and sole proprietor that is placing packaging on the Slovenian market is a manufacturer. In addition, it corresponds to the definition of the acquirer of the wrapped goods, the manufacturer of the supply of packaging used for wrapping or packaging the goods at the point of sale (so-called service packaging). Likewise, a foreign undertaking selling wrapped or service packaging directly to the end-user via means of distance communication counts as a producer.

Abolition of the quantitative threshold

Under the current Regulation, companies do not have to pay the costs of placing packaging on the market to those who place the market up to 15 000 kg or 15 tonnes of packaging per year. However, the novel is now proposing to abolish the quantitative threshold for the incurrence of the obligation to pay the costs of handling packaging waste. In this respect, it also proposes to pay a lump sum for those producers who place less than 1000 kg of packaging on the market in Slovenia per year. However, the latter will still not apply to PVC packaging and packaging that wraps dangerous goods and plastic carrier bags.

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Changes in reporting

The change also brings the novel to the producer records. This is because only data on producers and their activities will be managed, not on the type and weight of packaging they place on the Slovenian market. However, certain provisions of the regulation in force will still be complimented.

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