M.
Message from the Chair and the Director
2025 promises to be a challenging and uncertain year for the Interregional Packaging Commission (IRPC), with new legislation set to have a significant impact on the way our organisation operates.
A series of new obligations and adjustments await us in the wake of the publication on 22 January 2025 of the Packaging Regulation (PPWR), which officially came into force twenty days later and will apply from 12 August 2026. Meanwhile, the forthcoming introduction of the new EPR and Litter Cooperation Agreement will also have an impact on the operation and responsibilities of the IRPC.
The priority now is to put
in place Belgian legislation
that will ensure effective implementation
of the PPWR.
On 16 December 2024 the European Parliament officially approved the PPWR (Packaging and Packaging Waste Regulation). The PPWR (in full: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC) sets out new provisions for preventing and reusing packaging and largely replaces existing Belgian legislation, specifically the Cooperation Agreement of 4 November 2008 on the prevention and management of packaging waste.
In addition to stricter measures, the PPWR introduces a number of substantial changes. For example, the term “producer” will now be used instead of “responsible company” (i.e. “party responsible for packaging”), and “producer responsibility organisations” will replace “accredited compliance organisations”.
Furthermore, all producers and producer responsibility organisations will be required to register and obtain authorisation. The specific rules and procedures for this have yet to be finalised.
The priority now is to put in place Belgian legislation that will ensure effective implementation of the PPWR. To avoid legal uncertainty, this legislation must be drafted without delay and come into force by 12 August 2026 at the latest.
The Extended Producer Responsibility Interregional Platform (EPRIP), for
which the IRPC acts as secretariat, was set up in 2009. The aim of the EPRIP was to develop a common understanding on extended producer responsibility (EPR). Each of our activity reports in recent years has devoted attention to the new EPR and Litter Cooperation Agreement currently being developed within the EPRIP. The Belgian Regions now intend to finalise this agreement as early as possible in 2025.
The Cooperation Agreement will rename the IRPC and reorganise it into a dual structure. The name IRPC (Interregional Packaging Commission) is expected to disappear this year, to be replaced by the official name “Interregional EPR Commission”. This will comprise the “Packaging decision-making body” and the “EPR decision-making body”. The latter will continue the work of the EPRIP.
The EPR part of the Cooperation Agreement provides an opportunity to supplement waste streams, previously managed by each individual Belgian Region, with an interregional section. This will also involve charges to support regional policy.
A second section of the Cooperation Agreement stipulates that the costs associated with litter must be passed on to the producers, either in the form of a direct charge or by working with a collective body.
As soon as the EPR and Litter Cooperation Agreement enters into force, the charges for both EPR and litter will take effect almost immediately. The Interregional commission will be responsible for organising this.
Furthermore, with regard to the EPR section, the implementing cooperation agreements must now be finalised without delay. This will be done separately for each stream, since the interregional Cooperation Agreement requires an implementing cooperation agreement to be drawn up for each stream individually. The Interregional commission will therefore face a significant increase in its workload.
The name IRPC (Interregional Packaging Commission) is expected to disappear this year, to be replaced by the official name “Interregional EPR Commission”.
Unfortunately, staffing levels of the Interregional commission’s Permanent Secretariat are at an all-time low, seriously hampering its ability to meet the aforementioned challenges. We cannot stress strongly enough the absolute necessity of finding a quick and decisive solution to this situation.
We hope you enjoy reading this report and invite you to join us in looking back on an eventful year marked by challenges, perseverance and progress.
Martine Gillet, Chair
Marc Adams, Director