Singapore Singapore issues guideline on mandatory packaging reporting requirements

On September 13, 2021, the National Environment Agency (NEA) of Singapore issued the Mandatory Packaging Reporting – Guide on Assessing if a Company is Required to Comply with the Regulation. This document provides instructions for business entities on how to determine whether they are subject to the mandatory reporting requirements under the Resource Sustainability (Packaging Reporting) Regulations 2020. The Guide also indicates regulated and non-regulated packaging materials with their pictures.

Criteria for determination

To help business entities determine if they fall under the definition of the “Producer” of Specified Packaging, the Guide asks the following questions:

  1. Do you “Supply” goods as defined in Article 19 of the Resource Sustainability Act 2019 (“RSA”)?
  2. Are any of the goods supplied considered “Regulated Goods”?
  3. Do you carry on a business of supplying Regulated Goods in Singapore?
  4. Do you import Specified Packaging in furtherance of that business? The list of examples of Specified Packaging is given in Annex B.
  5. Do you in furtherance of that business use Specified Packaging in any of Use 1 to Use 4? (For details of each Use, please refer to the Guide.)
  6. Do you only engage in Use 1 (and not in Use 2 to 4) as described in Question 5, and do only for or on behalf of a Singapore connected person?
  7. Are you a retailer who is required to use the Specified Packaging in Use 3 as described in Question 5, and you do not engage in Use 1,2 and 4?

Examples of packaging materials to be regulated

Examples of specific packaging materials to be regulated as indicated in Annex B of this Guide include: labels, stickers, spray cans, blister packaging, desiccants, pouches, body soap/shampoo bottles, PET bottles (including caps), food containers, beverage cans, and drink cartons, as shown in the table below.

The following containers/packaging (shrink film, pallets, packaging inner support materials, boards, carton boxes, crates, etc.) are also subject to the regulation, but are excluded from the mandatory reporting obligations if they are used to consolidate multiple selling units and are not delivered to consumers.

On the other hand, the following containers and packages do not fall under the definition of “Specified Packaging.” However, some of them are scheduled to be added to the scope of regulation in 2023-2024.

The original text of the Guide can be downloaded from:
https://www.nea.gov.sg/docs/default-source/default-document-library/mandatory-packaging-reporting-simplified-guide-as-of-13-september-2021.pdf