REPORTING AND FILLING IN THE QUESTIONNAIRE

DOES A FIRM HAVE REPORTING RESPONSIBILITY IF ITS TURNOVER IS OVER EUR 1M, BUT THE PACKAGING QUANTITIES ARE VERY SMALL? FOR EXAMPLE, A FIRM THAT IMPORTS LARGE, EXPENSIVE MACHINES?
Yes. The turnover threshold is EUR 1m, while the quantity of packaging placed on the market is insignificant.

DOES A FIRM THAT PACKS ITS OWN PRODUCTS AND THOSE OF OTHER FIRMS HAVE TO REPORT ALL PACKAGING?
No, it only reports the packaging on its own products. The firm that owns the product at the time of packing has a reporting responsibility even though it buys in the packing service from another firm.

WHO HAS THE RESPONSIBILITY TO REPORT IF A FIRM BUYS IN PACKING SERVICES FROM ANOTHER FIRM?
The firm that owns the product at the time of packing.

A FIRM PACKS RAW MATERIALS FOR INDUSTRIAL USE, FOR EXAMPLE, FOR FACTORIES AND NOT DIRECTLY FOR CONSUMERS. DOES THIS CONSTITUTE PLACING PACKED PRODUCTS ON THE MARKET?
Yes. An exception to this would be internal transfers within the firm. A product is perceived to be placed on the market when it changes owner.

DOES A FIRM HAVE TO REPORT LEASING PALLETS OR OTHER PACKAGING?
Yes. The owner of the packaging is of no significance in statistics. Packaging is to be reported by the firm that owns the packed product at the time of packing.

DOES ONE ENTER A PAPER SACK DELIVERED TO AN AGRICULTURAL SHOP UNDER CONSUMER PACKAGING OR INDUSTRIAL WRAPPING?
Under industrial wrapping. The differences between consumer packaging and industrial wrapping are described in the materials definitions posted with the questionnaire. Consumer packaging is packaging that is smaller than industrial wrapping, generally packaging going to an individual consumer, such as sugar or flour bags.

A FIRM PACKS PRODUCTS NOT DESTINED FOR THE FINNISH MARKET BUT FOR EXPORT BY ANOTHER FIRM. IN WHICH COLUMN DOES ONE ENTER THE PACKAGING FOR SUCH PRODUCTS?
If a firm sells products to another Finnish firm, the packaging for these products is entered in the “Packed in-house” column, because they are not the firm’s own exports. The only exception is when the export firm belongs to the same group, i.e. there is an ownership relationship between the firms. In this case an explanation must be given with the questionnaire.

WHAT SHOULD A PACKAGING MANUFACTURING FIRM REPORT?
A packaging manufacturing firm only reports the packaging it uses for the protection, handling and transport of its own products (in this case, the packaging).

DO THE REGULATIONS APPLY TO A FOREIGN IMPORTER AND DOES IT THEN HAVE TO REPORT?
An importer is responsible for packaging placed on the market in Finland regardless of its domicile and therefore has the responsibility to report if its turnover exceeds the EUR 1m threshold.

DOES A FIRM HAVE TO REPORT PACKAGING THAT IT REMOVES FROM AROUND INCOMING PRODUCTS AND IN WHICH IT PACKS PRODUCTS FOR EXPORT?
No. This packaging is not entered on PYR’s questionnaire. Only imported packaging and packaging remaining in Finland is reported.

DOES AN IMPORTER HAVE TO REPORT PACKAGING WEIGHTS IF IT DOES NOT EVEN SEE THE PACKAGING AS THEY ARE DELIVERED STRAIGHT TO THE CUSTOMER?
Yes. The importer has an obligation to declare packaging weights using the best available information.

WHICH IS THE IMPORTER WITH THE OBLIGATION TO REPORT – THE FIRM SENDING PRODUCTS FROM ABROAD OR THE FIRM IN FINLAND THAT RECEIVES THE PRODUCTS?
The firm with the reporting obligation is the one that owns the product when it crosses the border or the one considered by law to be placing the product on the market. Even if the importer is a foreign firm, it is nevertheless responsible for the packaging it has placed on the market in Finland regardless of domicile. Consequently, it also has a responsibility to report, provided that its turnover is at least EUR 1m.

SHOULD AN IMPORTER ENTER UNDER THE IMPORTS COLUMN ALSO THE PACKAGING THAT STAYS IN-HOUSE, WHICH IS NOT DELIVERED TO A CUSTOMER?
Yes it should. One should enter all imported products in the Imports column. Packaging is on the market in Finland when it has crossed the border. The only exception to this is packaging going abroad via Finland. Only packaging staying in Finland is entered in the Imports column.

A FIRM IMPORTS PRODUCTS, WHICH IT SELLS TO ANOTHER FIRM LOCATED IN FINLAND. THE LATTER EXPORTS THE PRODUCTS. SHOULD THE IMPORTER ENTER PACKAGING OF THESE PRODUCTS ON THE QUESTIONNIARE EVEN IF THEY GO ABROAD?
Yes, because the importer has sold products to a firm located in Finland, that is, to the market in Finland. Whatever happens to the products after that is no longer the responsibility or the concern of the importer.

A FIRM IMPORTS PRODUCTS IN TRANSPORT PACKAGING THAT IS RETURNED TO THE EXPORTING COUNTRY. SHOULD SUCH PACKAGING BE ENTERED ON THE QUESTIONNAIRE?
Transport packaging circulating between two countries should not be entered on the questionnaire, as it does not end up on the market in Finland.

A FIRM IMPORTS EMPTY PACKAGING. SHOULD THIS ALSO BE ENTERED ON THE QUESTIONNAIRE?
No, unless the importer later packs products in them in-house whereby it should be entered under “Packed in-house for the Finnish market”. Only the user of the packaging, namely the importer, is responsible for entering the packaging on the questionnaire. The importer of empty packaging, however, should remember to enter the share of the transport packaging.

SHOULD ONE PAY RECOVERY FEES FOR ALL PACKAGING ENTERED ON THE QUESTIONNAIRE?
Recovery fees are payable only on the packaging entered in the “Packed in-house for the Finnish market” or “Imports” columns, as the packaging stays in Finland. Packaging that is exported and its recovery fees are the responsibility of the recipient firm in compliance with the law of its own country.

HOW SHOULD ONE REPORT PACKAGING GOING TO ÅLAND?
Packaging going to Åland is entered under exports, as Åland has its own laws and recovery scheme.

IN WHICH COLUMN SHOULD ONE ENTER REUSABLE PALLETS, ROLLER CAGES, PLASTIC FOOD TRAYS AND THE LIKE THAT ARE IN CIRCULATION?
Completely new packaging used for the first time should be entered in the "Packed in-house" column. After that it is entered in the "Reuse" column where the annual number of times the packaging is refilled is multiplied by the weight of the packaging. Each instance of reuse is included in the calculations, as it always replaces the use of new packaging.

IF ONE DOES NOT KNOW THE MATERIAL OF THE PACKAGING, CAN IT BE ENTERED IN THE ROW FOR OTHER PACKAGING?
The row for other packaging is only intended for rarely used packaging material, for example, textile, ceramic or biodegradable material. The material of the packaging should be determined before entering it on the questionnaire.

WHY IS THERE NO COLUMN FOR RECOVERED IN-HOUSE ON THE QUESTIONNAIRE?
PYR and the producer organisations have come to an agreement about this. It is clearer if all firms that recover packaging report the quantities of recovered packaging directly to the producer organisations. The latter can then check if this really does constitute recovery.

HOW DOES IN-HOUSE RECOVERY LOWER RECOVERY FEES?
Firms report to PYR about the packaging of products that are packed in-house or imported and pay recovery fees on this packaging. If in-house recovery takes place, this should be reported to the producer organisation for that specific material so that it can grant compensation for this.