Obligated Organisations

1. Companies which import packaged goods with the purpose of using them for their own purposes (raw materials, machinery spare parts and equipment, etc.),
2. Companies which as movers, (supermarkets, commercial stores) package or see to the packaging on their behalf of goods under their own private label with the purpose of trading them in Cyprus,
3. Companies which use facilitating packages, either without a brand name or under their own label. This kind of packaging is used at the point where the service is offered to consumers or users in combination with the provision of goods or services. In this category are for example, wrapping paper, paper or bread bags, pizza boxes, supermarket and other commercial stores bags, bags handed out at exhibitions and other shows, etc.,
4. Companies which offer free packaged goods as a means of promotion or as samples. It is clarified that the obligation in Cyprus concerns only products placed into the Cyprus market (not exports or re-exports).

In every case, obligation is with the Organisation that places first the products into the market (the first which produces them or the first which has imported and released them into the Cyprus market).

(a) How can you meet the obligation of recovery of Packaging you place in the market?

(i) With a Collective Compliance System:

A company which opts to contractually join a Collective Compliance System for Packaging Waste Management should be aware that the Collective System:

• Represents many obligated Organisations
• Is a non-profit Organisation
• Submits detailed business planning to the competent authorities and is licensed for a six-year period.
• Undertakes the collective obligation on the total of packaging which its members place in the market (however, the packaging can no longer be identified)
• Develops collective and large-scale activities capable of achieving the targets of recovery and recycling which it undertakes on behalf of its members.

Also, the interested company should be aware that:

• Its participation in the Collective Management System requires the payment of contribution to the system by all its member companies.
• When the member pays its contribution to the Collective System then it is RELIEVED of any responsibility for packaging management and the responsibility is TRANSFERRED to the Collective System.

 (ii) With an individual Recovery System:

A company which chooses to develop an Individual Packaging Recovery System should:

• Prove to the State that it is implementing a guaranteed system.
• Submit to the competent authority data that concern the description of the system it implements regarding targets and methods, the technical and financial infrastructure it has for the implementation of the system and details of the manner of operation to establish the capability of its compliance with the Law.
• Pay the approved fee which amount corresponds with the cost of examining its application by the competent authorities.
• Demonstrate that the recyclable material recovered ends up in recycling in accordance with the requirements of the law.
• Specifically, you must draft a detailed list with the packaging for which you are obligated for. You must then contact all your clients to find out what they do with the packaging as soon as your products are put into use. You must also collect and recover the packaging waste either by yourselves or through other associates you may have.
• Then you must compare these two flows of information as described above, to ensure that you are achieving the quantities of recovery and recycling set by the Law.
• You must repeat this exercise every year.

(b) How can you meet the obligation of informing the Authorities?

1. Obligated Organisations for packaging must provide exact data to the government concerning the mass of packaging they place in the Cyprus market and demonstrate the way they have received proof that their packaging has been recovered and recycled.
2. They should submit this information annually to the Environment Service of the Ministry of Agriculture, Rural Development and Environment.

To consider that a company has placed packaging into the market it should:

1. Either itself directly import products to Cyprus (or via a third-party importer on its behalf by under its own special order) (raw material, spare parts etc.), which the company itself has used in its production process
2. Either it has placed into the Cyprus market directly or through third parties packaged products which it has either produced or imported directly by itself.

1. It is also clarified that products which have been produced, imported or held in warehouses and have not been made available to consumers yet would not be considered as having been placed into the market.
2. Also, in the case where products which have been produced or imported are not finally made available to consumers and therefore should be thrown away as waste, as packaged products, then these products are not considered as having been placed in the market and no obligation on their packaging emerges under the Packaging and Packaging Waste Law. Such waste is considered industrial waste of the company concerned.