Recycling Compliance

Who must comply with EPR regulations in Georgia?

Importers and manufacturers of specific products such as tires, oils, batteries, and electronics are legally required to adhere to Extended Producer Responsibility (EPR) rules. This includes managing the waste generated by these products at the end of their life cycle.

What is a Producer Responsibility Organization (PRO)?

A PRO is a collective organization that manages waste collection and recycling obligations on behalf of its member companies. By paying a fee to a PRO, companies transfer their physical recycling duties to the organization, ensuring legal compliance.

Can I manage my waste individually?

Yes, companies can opt for an individual compliance scheme instead of joining a PRO. However, this requires establishing your own waste collection and recycling infrastructure and getting it approved by the Ministry, which is often operationally complex and costly.

What are the penalties for non-compliance?

Placing subject products on the market without proper EPR registration is illegal. Violators face significant fines, and authorities may block the import or sale of non-compliant goods until the obligations are met.

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Recycling compliance and "Extended Producer Responsibility" (EPR) are new and significant parts of Georgia's environmental policy. These regulations oblige manufacturers and importers of certain products to take responsibility for the collection and recycling of their product waste (packaging, tires, oils, electronics, batteries). The EPR principle is simple: "polluter pays." Companies are required to join an "Extended Producer Responsibility Organization" (PRO) and pay a fee used for waste management, or establish an individual collection system. Failure to comply leads to significant fines and restrictions on placing products on the market. Legal services help businesses navigate complex EPR schemes and comply with the law.

What Does Recycling Compliance Service Cover?

Our lawyers will assist you in joining the EPR system and fulfilling recycling obligations:

  • EPR Subject Identification: Determining whether a company's products (imported or manufactured) are subject to Extended Producer Responsibility.
  • Organization Membership: Selecting a Producer Responsibility Organization (PRO) with the best conditions and legal analysis of the membership agreement.
  • Individual Scheme: Developing an individual performance scheme and agreeing it with the Ministry (if the company does not join a collective organization).
  • Reporting Management: Legal oversight of reporting on products placed on the market and waste collected.
  • Recycling Targets: Monitoring compliance with statutory recycling targets.
  • Disputes on Fines: Appealing fines imposed for non-compliance with EPR obligations.

Common Scenarios and Needs

Importers often forget that importing tires, oils, or electronics automatically makes them EPR subjects. Customs clearance or sale of goods without registration is a violation. Also, many companies do not realize that the packaging (plastic, cardboard) in which their products arrive is also subject to regulation. Disputes often arise regarding the amount payable to collective organizations, as tariffs depend on the weight of products placed on the market.

Georgian Legislation and Regulations

The field is regulated by the "Waste Management Code" (Article 9) and special technical regulations for 4 main streams: "Waste Oils", "Tires", "Electrical and Electronic Equipment", and "Batteries and Accumulators" management. Packaging waste regulation will also come into force in the near future.

The Process: How a Specialist Works

The lawyer analyzes the company's imports/production. If products fall under regulation, registration in the EPR registry is performed. The lawyer negotiates with the PRO. If the company chooses an individual scheme, the lawyer helps with contracts for collection points and relations with recyclers. At the end of the year, the lawyer checks if the statutory recycling percentage has been met.

Why Legal.ge?

EPR is a new and complex system for Georgian business. Non-compliance leads not only to fines but also to the suspension of product imports. Legal.ge gives you access to lawyers who thoroughly know EPR regulations. Specialists on our platform will help you optimize costs and legally fulfill obligations. Be a responsible producer with Legal.ge.

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