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CERT does not get actively involved in registration requirements as this is based on volumes of sales and is considered a commercial activity. However, we have a legal obligation to demonstrate due diligence that we have checked and confirmed that this registration to offset your carbon footprint is in place.

Your co-operation is required in order for us to approve and allow the release of your products to market – thank you.

NOTE: There are financial repurcussions and potential market sanctions if you do not comply with these environmental requirements.

Remember to complete the Product Schedule by adding each product’s unique reference and name. This should align with the product file name in the Product Schedule. You can find guidance for this step in your Product Schedule.

Once your product has been fully approved and signed off, you may proceed with shipping to your intended markets. Do not ship the product before receiving written approval; doing so renders your product non-compliant and illegal.

Supporting Information.

Extended Producer Responsibility (EPR) is a policy approach that holds manufacturers accountable for the entire lifecycle of their products, including post-consumer waste management.
While CERT does not specifically handle EPR compliance as it is classified as a commercial activity, there is a minor overlap with legislative requirements. EPR compliance can be managed by a fiscal representative, or by engaging specialised EPR service providers available online. Alternatively, businesses may choose to meet these obligations independently, which requires a thorough understanding of EPR guidelines and the capacity to manage the necessary administrative processes.
It is mandatory for us to demonstrate due diligence by ensuring that clients have fulfilled EPR requirements in the markets where they operate.

Packaging Waste registration:

The EU Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40) came into force on 11 February 2025 replacing the previous Packaging and Packaging Waste Directive 94/62/EC, introducing significant changes to packaging waste management across the European Union.

• • • • EPR is a policy tool that extends producers’ financial and/or operational responsibility for a product to include post-consumer management
      • All EU Member States now have EPR schemes for packaging in place.
      • The PPWR introduces an EPR registry and eco-modulation of EPR fees based on packaging recyclability and recycled content.

     

  • Registration and Reporting
    • • Producers must register with national producer responsibility organizations (PROs) or equivalent authorities in each EU Member State where they operate.
      • This is considered a commercial activity and so either the client themselves or their nominated Fiscal Representative/dedicated Packaging Waste Service need to monitor and honour the registration requirements.
      • Annual reporting is required on quantities of packaging placed on the market, with corresponding eco-fees to support recycling efforts.
      • For reusable packaging, producers must register in the producer register.
      • CERT only require confirmation that this legal obligation has been addressed for all markets you are intending to actively sell in.

     

  • WEEE (Waste Electrical and Electronic Equipment) Directive:

    The WEEE (Waste Electrical and Electronic Equipment) Directive requires producers, distributors, and sellers of electrical and electronic equipment (EEE) to comply with Extended Producer Responsibility (EPR) obligations.

  • Who must register
    • • Companies manufacturing or importing EEE into the EU market.
      • Registratin is with national WEEE authorities in each EU country where they sell products. This ensures compliance with local regulations.
      • Registration includes providing details about the types and quantities of EEE placed on the market.

     

  • EPR Registration Number
    • • Marekt introducers must obtain an EPR registration number, which is required for selling on platforms and for cross-border sales.
      • Each country may have specific formats for registration and reporting, which can vary significantly.

     

  • Reporting and Take-back Obligations
  • Market introducers must submit regular reports detailing the amount and type of EEE sold, collected, treated, and recycled.
  • Reporting frequency varies by country but is typically annual or biannual.
  • Distributors must offer free take-back services for customers returning e-waste.
  • Market introducers must organise or finance systems to collect and recycle discarded equipment.

EU Battery Waste Registration:

The EU Battery Waste Registration is governed by the new EU Batteries Regulation 2023/1542, which replaces the previous EU Batteries Directive (2006/66/EC). This regulation standardises rules across all EU Member States and introduces stricter requirements for producers, importers, and distributors of batteries.

Registration

• • Market introducers must register with the national producer responsibility organization (PRO) or equivalent authority in each EU Member State where they operate.
  • Registration includes providing details such as battery type, weight, and compliance with labeling requirements (e.g., crossed-out wheelie bin symbol).

Reporting and Take-back

• • Market introducers must report annually on the quantities of batteries placed on the market and pay corresponding eco-fees to support recycling efforts.
  • you need to establish or participate in take-back programs for waste batteries to ensure proper collection and recycling.

Battery Passports
From August 2025, battery passports will be introduced to provide traceability and environmental data for batteries. Requirements will vary depending on the type/size of battery and the use of the battery.

Formulated Products

If you introduce a substance to the market (EU/UK) in excess of 1 tonne, it is likely to be subject to registration and fee incurred, to offset the environmental impact of the substance you are potentially introducing to the environment. CERT can assist with this registration requirement if needed, as the process needs to be handled by your Only Representative (chemical reference for an Authorised Representative).

These EPR regulations all aim to minimise the environmental impact by ensuring proper recycling and promoting a circular economy across the EU.