My observation is that companies are currently experiencing the following difficulties with reporting packaging data under the new packaging law:
- The packaging materials and their weights per item are often not recorded at all. In most cases, each dealer / producer has his software in which all his article data are recorded. This software (individual developments or standard software) is usually not even designed to record packaging data, especially with all the nuances that the packaging law provides.
- If the customer's software can't capture that, it can be entered into Excel after the fact (that's how my calculator came up with the idea). But even that still few companies have, mostly they do not have the data at all.
- Therefore, for each article must first be measured and weighedThe packaging is made up of a number of different components. If you have several thousand items in your range, this can take a while. Alternatively, you have to ask the supplier for a Packaging specification ask
- In addition, for measuring and weighing, it must first be determined in the company hierarchy who is to deal with this. In the case of distribution across several locations, entire Packaging teams with different packaging officers be formed.
- The Central Office Packaging Register presents the 1,813-page "Catalog of packaging subject to system participation" is available, in which it is broken down per product category which types of packaging have to be reported and which do not. Companies must check this catalog for each of their items to see exactly what should be reported. For example, it states that Iced tea sales packagingwhich is greater than 18 liters do not have to be reported, but smaller ones do. At Milk however, the limit is 28 liters. This catalog also distinguishes between outer packaging, sales packaging, transport packaging and shipping packaging, which does not make interpretation any easier.
- Those who ship internationally must also check their data for notifications in all EU countries prepare. The Definitions of the materials however, differs per country. While, for example, aluminum in Germany only counts as aluminum from 90% aluminum content, the limit at ARA in Austria is 80%. Other EU countries where packaging has to be reported (e.g. Slovenia) have different definitions. So the data must be recorded separately for each country.
- In order to save royalties, a company can obtain from its upstream suppliers a De-commitment statement confirming that the royalties for a particular product have already been paid. For this purpose, a document must be drafted together with a lawyer, which must then be signed by the suppliers. However, some suppliers only release part of the packaging (e.g., only transport packaging, but no sales packaging), and furthermore, they may release the Restricting disengagement to a specific period of time or specific products. All these restrictions must be taken into account in the packaging declaration, and accordingly included in a software. The purchasing departments have their hands full at the moment with the administration and recording of all the declarations of discharge.
- If a retailer/producer has outsourced its logistics, from now on also the external logistician start recording the packaging they have shipped. And they need to know per period and country how many grams of labels, film, hot glue and cardboard they have shipped there. Neither the logistics companies' processes nor their software are designed for this.
- Sales-related items that are not normally considered sales items at all by distributors/producers must also be included in the reports. For example Wrapping paper, shopping bags, aluminum foil or pizza boxes. A store can no longer simply buy wrapping paper from the store next door and use that as gift wrap, but must either use the consumption of wrapping paper per month in gram correctly in the system or have a written declaration of release from the gift wrap supplier. For this purpose, processes must also be defined in the companies that did not previously exist in this way.
In short, making the correct packaging reports is about as simple as a sales tax advance return, or like data protection. It requires a permanent intervention in the processes of the companies, clear responsibilities and a complicated calculation formula. The Packaging Act finally encourages companies to do their homework and makes it clear to companies how much of what packaging they put into circulation. Since the reporting of target figures is done on a quarterly basis, this work must of course be done every three months. Recording, on the other hand, is a permanent process, where all items must be set up once, and maintained permanently. If all the data is always entered correctly (which is rarely the case), a calculation of the reports can then be automated so that all that is needed is to press a single button. However, until the underlying data is entered, it is a long way.
