EPR fundamentals

    Placed on the market

    The legal moment when packaging first becomes available in a jurisdiction, determining which entity and which year the obligation falls in.

    Placing on the market means making a product available for the first time in a defined territory in the course of commercial activity. It anchors both who is obligated and which reporting year the tonnage belongs to.

    It is not the same as manufacture, shipment or sale to a consumer. Goods sitting in a bonded warehouse are usually not yet placed on the market; goods transferred to a local distributor generally are. Exports are excluded from the exporting market's tonnage, which is why export volumes must be netted out.

    Because reporting years and definitions differ, the same shipment can fall in different years in different markets. Reconciling that is a normal part of multi-market reporting rather than an error.

    Related terms

    • Producer (obligated party)

      The legal entity responsible for registering and paying EPR fees on packaging, usually the brand owner and otherwise the importer or first seller.

    • Tonnage reporting

      The annual declaration of packaging weight by material category placed on a market, and the basis for nearly every EPR invoice.

    • De minimis threshold

      A revenue, tonnage or unit level below which a producer is exempt from some or all EPR obligations in a jurisdiction.

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