Reducing the environmental product fee and extended producer responsibility fee- planning and optimisation

The EPR rates are much higher than the environmental product fee rates, so the new system may carry more risks. In addition, even if the environmental product fee obligations have been reduced to zero in many cases, the environmental product fee obligations have not been eliminated. It is also possible that some companies will only be affected by one of the two obligations.

To this day, we encounter companies in our practice that paid huge amounts as product fee merely because the reporting that is supposed to support their filings is unsuitable or confusing. They have useless records for this data supply obligation and it is unclear what they pay or do not pay product fees for, and especially for what reasons.

In the lives of most companies, the environmental product fee and the EPR scheme is a necessary evil which most departments strive to rid themselves of. Filing the returns and the data reporting obligation is the responsibility of finance and/ or accounting but reporting belongs to a different department which generally receives the data from logistics or, in some cases, from an affiliated company abroad. This, however, is a typical case of too many cooks spoiling the proverbial broth. Indeed, it would be important to think over and check the systems thoroughly since, with careful planning, the related administrative and payment obligations could be reduced or even avoided altogether in some cases.

The experts at Mazars can help you cut the Gordian knot by developing the processes, establishing the correct content of the reports, and minimising related liabilities.

To whom do we recommend our services?

• To any company that has an environmental product fee or EPR obligation, especially if they are involved in products subject to product fee/ circular products, domestic manufacturers, importers or even if they supply the products domestically and sell abroad in large volumes

• To companies who do not know whether they are affected by the environmental product fee and EPR obligations and would need an expert to support their implementation

• To companies that has already filed product fee returns and EPR data reporting obligations and ensure that they pay their liabilities but are uncertain what data they use as a basis for the returns, and find the contents of the reports to be unclear
• To those who feel that in the case of an audit by the authorities they could not provide satisfactory answers to even the simplest questions of the auditors (What are the products after which you pay a fee? In which cases? At what times?)

How can we help?

• We identify the products that are subject to the environmental product fee and the circular products subject to EPR fee.
• We help with the development of the optimized processes, help with the proper setting up of invoicing, or review the existing systems.
• On the basis of the product flows and processes drawn up, we prepare a customised policy which will help the company in the case of an audit by the respective authority in supporting its returns and records.
• We review the available records and reports related to the environmental product fee and EPR and help with making them more efficient.
• We take over tasks related to the filing of the environmental product fee returns and EPR related data reporting obligation or help with administration (the determination of the CSK/KT and KF codes, which form to complete when, etc.).
• If necessary, we carry out a complete review for identifying and properly handling environmental product fee and EPR payment obligations.

If you have any questions related to the environmental product fee and EPR, please contact our colleagues directly or through your Mazars contact person.