Ministry of Environmental Protection and Natural Resources of Ukraine has published draft law “On Packaging and Packaging Waste” for consultation with the stakeholders.
Summary of the proposal:
• Packaging must meet the design requirements, a producer/importer must register in the Packaging Registry and provide information on packaging materials/types/brands. Packaging volumes must be reported.
• Producers/importers meet the recycling targets by introducing its own PRO or become a member of collective PRO. Collective PRO must represent at least 10% of the producers/importer packaging volume. PRO (own or collective) must implement separate waste collection in all areas where the products are sold.
• Recycling targets are ambitious, and the law requires fast results in the collection and recycling of the sales packaging (post-consumer packaging). Although target achievement by recycling of the sales packaging is legally required after three years from the enforcement of the law; it must be implemented from day one to gradually start the process. One year four, 50% of the packaging waste required to meet the recycling target must come from the households/consumer packaging stream. This requires effective co-operation with the municipalities.
• The PRO system is a full cost system, not limited to the targets achievement only, PRO must collect and recycle packaging waste, even if it overachieves the targets. On top of the waste management costs, collection sites maintenance and cleaning must be covered as well.
• Currently, fines are high for non-compliant packaging – for non-conforming packaging it can be 100% of the product in packaging value (not packaging value).
• If the PRO does not meet the targets, it will pay the state double fee for the missing part as a fine.
• Jan 1, 2024 is the planned enforcement date.