Green Environment Support: Businesses Must Register with AFM-APR for Certain Packaging or Recycled Plastic

Economic operators in Romania must prepare the registration process in AFM-APR, after the recent approval of the registration procedure. This measure applies to those bringing sustainable or plastic-free reusable alternatives to single-use plastic products to market. Here are the most important aspects of the legislation that the companies concerned must know, according to Green Environment Support, one of the largest environmental consulting companies in Romania.

On September 25, the Order was published – no. 2.002/353/2023 for the approval of the Procedure for the registration of economic operators who introduce sustainable reusable or plastic-free alternatives to single-use plastic products, PET bottles containing recycled plastic and recycled plastic to be incorporated into PET bottles on the national market which brings a new registration obligation for certain economic agents.

The companies that must register in the AFM-APR register are those that will introduce on the national market:

a) single-use retail packaging: cups and lids/cups and their lids made of sustainable or plastic-free reusable materials. This category can include both manufacturers and importers of such packaging, as well as HoReCa.

b) PET bottles containing recycled plastic regardless of whether these bottles are used for food or other types of non-food products, and the business categories that may be eligible are manufacturers and importers of such packaging and HoReCa

c) recycled plastic to be incorporated into PET bottles (recyclers or importers of recycled plastic to be incorporated into PET bottles)

Registration in the register must be done within 60 days from the entry into force of this order.

“It is very important that economic operators know that they must register in the AFM-APR register by November 24. In the process of preparing for registration, we offer companies the necessary support to avoid possible errors and to meet the deadline. Over the past few years, the harmful impact of single-use plastic products on the environment has become increasingly evident, generating a growing concern globally. Romania, along with other countries, has decided to act firmly to reduce the amount of plastic waste and to promote the use of sustainable and environmentally friendly alternatives,” says Daniela Dobre, CEO of Green Environment Support.

Validation or rejection of the registration will be done by the authorities in no more than 15 working days from the receipt of the request. In the case of new activities, they will be registered within the same period of 60 days from the start date of the activity. If the activity for which registration was requested ceases, a cancellation request will be submitted within a maximum of 20 working days.

By February 25, 2027, the central public authority in the field of environment and the central public authority in the field of economy shall carry out an evaluation of the registration procedure.

Registration is done through the e-tax application made available by the Environment Fund Administration based on an application that must be completed.

The instructions for filling out the application are detailed in the “Registration procedure for economic operators who introduce on the national market sustainable reusable alternatives or that do not contain plastic to single-use plastic products, PET bottles that contain recycled plastic and recycled plastic to be incorporated into PET bottles, from 25.07.2023” as follows:

For the heading “durable reusable alternatives or that do not contain plastic to single-use plastic products”, the name and the material/materials from which it is made must be filled in for each package introduced on the market in this category.

Under the heading “PET bottles containing recycled plastic” data will be entered regarding the volume of the bottle, the category (intended to come into contact with food products/which do not come into contact with food products). Each category will also need to contain data on the industries they are intended for (eg: food industry, beverage industry, cosmetic industry, detergent industry, etc.).

Under the heading “recycled plastic to be incorporated into PET bottles”, the country of origin of the recycled plastic will be selected from the predefined list, if this is an EU member, or it will be filled in by the operator, if it is a third country.

The column relating to “the registration number/numbers in the Union Register of technologies, recyclers, recycling processes, recycling systems and decontamination facilities, provided for in art. 24 of Regulation (EU) No. 1,616/2022 of the Commission of 15 September 2022 regarding recycled plastic materials and objects intended to come into contact with food products and repealing Regulation (EC) no. 282/2008” will be completed only by economic operators whose activity falls under the provisions of Regulation no. 1.616/2022.

Economic operators who have not been allocated a registration number in the Union Register of technologies, recyclers, recycling processes, recycling systems and decontamination facilities by the date of completing the application for registration in the AFM-APR Register will complete the registration number from the Ministry Health of the notification/request, according to the provisions of art. 9 para. (1), art. 10 para. (2), art. 17 para. (2), respectively art. 25 para. (1) from Regulation (EU) no. 1.616/2022.

Through this new obligation, it aims to promote a sustainable approach to the use of packaging from renewable sources and the circular economy.

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