How will the mandatory packaging reporting requirements improve Singapore’s waste management system?
In the process of gathering information on their packaging, companies will be more aware of the potential and opportunities for packaging waste reduction within their business operations. Companies will also be motivated to take action to reduce the amount of packaging used, which will help to reduce cost and minimise waste generation at source. In developing 3R plans, companies can consider initiatives that facilitate the recycling of packaging waste, such as through using packaging material that is easier to recycle or implementing voluntary packaging take-back and recycling schemes.
What are the differences between this mandatory packaging reporting and the mandatory waste reporting which will extend to large industrial developments? Will there be double reporting?
The mandatory packaging reporting focuses on the reporting of packaging that a producer imports (s19(2a) RSA) or uses (s19(2b) RSA) in Singapore as part of their businesses, while the mandatory waste reporting focuses on all types of waste generated at the premises. Therefore, there is no double reporting in this context.
How will NEA inform companies on their compliance obligations?
Information on the mandatory packaging reporting has been provided through various channels including the NEA’s website and press releases. We have also reached out to the companies which could be affected by the requirements through several briefing and engagement sessions. To find out more on upcoming briefing sessions, please contact email@example.com.
NEA will also be sending out letters to inform companies of the new mandatory packaging reporting requirements. Companies are required to comply with the mandatory packaging reporting requirements as long as they fulfil the “producer” definition as specified under Section 19(2) of the Resource Sustainability Act (RSA). All companies are advised to download a copy of the RSA to better understand their obligations as a Producer or contact the NEA.
Will there be double-reporting of packaging across the supply chain?
There will not be any double reporting as producers and retailers will only be required to report the additional packaging that they place into the Singapore market through import or use. For example, the manufacturers of packaged goods will report the amount of packaging they use to pack their goods, while the manufacturers of the packaging are not required to report the same packaging that the manufacturers of packaged goods are reporting. However, packaging manufacturers are required to report the packaging used to package their packaging products. Similarly, retailers will report the amount of service packaging they issue at the point-of-sales, such as plastic bags, while manufacturers of the plastic bags are not required to report the plastic bags that the retailers are reporting. Instead, the manufacturers of plastic bags are required to report the packaging used to package the plastic bags.
Prescribed threshold criteria
Is the annual turnover threshold based on local sales or overall sales turnover (including import)? Does a company only consider sales turnover of products sold in Singapore?
The annual turnover refers to the company’s overall turnover, or company gross revenue and is independent of the source of revenue (i.e., sales turnover of products sold overseas is considered in determining the annual turnover threshold).
Is the annual turnover based on calendar year? What happens if my company’s annual turnover is based on financial year, which is different from calendar year?
Yes, the annual turnover is based on calendar year. For example, to determine whether your company meets the annual turnover for the report (containing packaging data for 2021 (T+1)) to be submitted in 2022 (T + 2), this will be based on your company’s annual turnover in 2020 (T). Companies, which have financial reporting not based on calendar year, are advised to obtain information from their relevant departments or Finance Department to ascertain the annual turnover based on calendar year.
Will a company need to comply if its annual turnover is less than $10 million?
In the initial phase of mandatory packaging reporting, companies with an annual turnover that does not exceed $10 million will not be affected. Nonetheless, the reporting criteria may be reviewed in subsequent years, and it may be adjusted over time. Hence, there is a possibility that your company may be required to comply in the future. In addition, the annual turnover of your company could vary from time to time.
What happens if the annual turnover of my company falls below the threshold (i.e., is equal or below $10 million) after registration?
Assuming a company completes registration in Year T+1 based on annual turnover for Year T, the company will still be required to submit report for packaging used in Year T+1 in Year T+2, even if their turnover for Year T+1 later falls below the threshold. However, the company does not need to report for packaging used in Year T+2 in the following year, since their annual turnover for Year T+1 is below the threshold. Nonetheless, companies are advised to continue submitting the packaging report as the annual turnover could increase to more than $10 million in the future.
For example, Company A’s annual turnover for 1 Jan 2020 – 31 Dec 2020 (T1) was above $10 million at the point of registration on 1 Jan 2021 (T1 + 1). However, the latest annual turnover (i.e., 1 Jan 2021 – 31 Dec 2021) (T2) available on 1 Feb 2022 falls below the threshold. Company A is still required to submit the packaging report for 2021 (T1 + 1) in 2022 (T1 + 2) based on annual turnover in 2020 (T1) but need not submit the packaging report in 2023 (T2 + 2) based on annual turnover in 2021 (T2).
Mandatory Packaging Reporting
How does a company register for mandatory packaging reporting?
Registration with NEA for mandatory packaging reporting and the submission of reports and 3R plans will be done through the Waste and Resource Management System (WRMS) which can be accessed at https://wrms.nea.gov.sg.
Do companies only start collecting packaging data after registration with NEA?
The registration is an administrative process, and does not represent the date which the company is required to start collecting data on the specified packaging that is imported or used. Companies are required to start collecting packaging data based on the date stated in the Subsidiary Legislation.
What are the types of data that a company needs to include in their annual reports?
Companies will have to provide data on the amounts (in terms of weight) of packaging imported or used in Singapore annually broken down according to type of packaging material (e.g. plastic, paper, metal, glass) and packaging form (e.g. carrier bags, bottles).
Companies will also be required to submit their 3R plans for packaging. This will include details on the key initiatives, key performance indicators (KPIs) and targets. Companies will be required to report on the progress of these plans in subsequent years of reporting.
The types of 3R plans for packaging that companies could consider, include: (i) packaging reduction, (ii) packaging collection for reuse and/or recycling, (iii) consumer and/or industry outreach related to packaging 3Rs, (iv) use of recycled content in packaging material and (v) improving recyclability of packaging.
What is the 3R plan? Is the 3R Plan a “future” plan, or the past year’s plan?
The 3R plan represents a progress update or report card on the company’s plans to reduce, reuse or recycle packaging within the next 3 years. For longer-term plans, a milestone KPI within a 3-year period will need to be indicated. For example, if the plan is submitted in 2022, company shall provide an update on the progress of the plan in 2023.
With reference to the template, does a company report the actual annual weight or round the weight to the nearest whole number?
Companies should report the annual weight to the nearest whole number. For example, if the annual weight of a certain packaging material and form is 78.7kg, the weight should be reflected as 79kg in the reporting template.
What companies are required to comply with the mandatory packaging reporting requirements?
Companies that supply regulated goods in Singapore and has an annual turnover of more than $10 million, will be required to comply with the mandatory packaging reporting requirements.
This includes brand owners, manufacturers, importers and retailers such as supermarkets.
My company imports/purchases packaging. However, we engage a subcontractor to dispose of and/or recycle these packaging. Am I still required to report these packaging?
Packaging that is imported or used in Singapore should be reported and this is independent of whether the packaging is disposed of or recycled. Information on packaging recycled can be provided as additional information in the reporting template (e.g. under “Remarks” column).
Are retailers required to report packaging used such as carrier bags?
Yes, carrier bags provided by retailers are required to be reported.
Is there any difference in reporting for packaging incurred from regulated goods that are imported, and regulated goods that are purchased locally?
If your company supplies regulated goods into Singapore through import, your company is obligated to report the amount of specified packaging associated with the regulated goods. On the other hand, if the regulated goods were purchased locally through a supplier, the reporting obligation is on the local supplier (i.e. the first point of contact for the regulated goods in Singapore) unless you have engaged the supplier (e.g. manufacturer) to manufacture or import the products.
Does reusable packaging (e.g. glass bottles) need to be reported?
We understand that some companies collect used packaging back for refilling and resell the packaging back again as products, such as beer glass bottles. Such packaging should still be reported unless the material remains in the possession of a producer to be re-used for the containment, protection, handling, delivery or presentation of any goods.
In cases, where the packaging is clearly meant for long-term storage and reuse, (e.g. plastic cases for storage of tools), the packaging need not be reported.
In cases where a company delivers their products in reusable packaging (e.g. plastic crates), and the crates remain in the company’s possession for reuse, such packaging do not come under the definition of “packaging” under the RSA and need not be reported.
How do we report packaging that are reused?
Packaging that is imported or used in Singapore should be reported and this is independent of whether the packaging is reused or not. Information on packaging reused can be provided as additional information in the reporting template (e.g. under “Remarks” column).
Only packaging that has been included under the exclusion list for “specified packaging” need not be reported.
In addition, any material that remains in the possession of a producer of specified packaging to be re-used for the containment, protection, handling, delivery or presentation of any goods is not considered as packaging and need not be reported.
For queries relating to the mandatory packaging reporting, you may email firstname.lastname@example.org.