The Cooperation Agreement sets out the obligations of parties such as the accredited compliance organisations, companies responsible for packaging and industrial unpackers.

If you fail to meet your obligations, you risk incurring an administrative fine and penal sanctions.

Sanctions may be imposed if you do not fulfill your take-back obligation or reporting obligation, if you fail to submit a packaging prevention plan or repeatedly submit a prevention plan deemed inadequate, and if you obstruct the supervisory activities of the IRPC.


Administrative fine: a concrete example

The following administrative fines can be applied for failure to comply with the take-back obligation:

  • 500 euros for each tonne or part tonne of packaging waste that has not been recovered or incinerated with energy recovery in waste incineration plants within the prescribed time limits,


  • 1,000 euros for each tonne or part tonne of packaging waste that has not been recycled within the prescribed time limits.

However, the total amount of the administrative fine may not exceed 25,000 euros.


Penal sanctions

The penal sanctions can be severe, depending on the seriousness of the offence. The most serious offences are punishable by a custodial sentence of between one and twelve months and a fine ranging from 1,000 to 2,000,000 euros.

These penal fines must be increased by the statutory multiplication factor (to correct for inflation).

You can find out more about sanctions and penal provisions in Chapter 6 of the Cooperation Agreement (p. 22).

Interregional Packaging Commission (IRPC)