Mandatory Packaging Reporting
MPR in a nutshell
Who is impacted?
All businesses which import or use packaging in Singapore and with a turnover >S$10M. It includes:
- Retailers such as supermarkets, sport, medicines, cosmetics…
- Brand owners
- Other outlets using packaging such as hotels, chain of restaurants, caterers, food delivery businesses…
What do businesses have to do?
Quantify the amount of packaging (Data Report) introduced to Singapore and provide a packaging improvement plan (3R Plan).
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Why engage a consultant?
The level of details
A high level of details is expected by the regulator. For instance, for a beer bottle, the business must report separately the glass bottle, the paper label, the aluminium cap, and the plastic lining under the cap.
In some cases, it can be difficult to determine who is responsible for the reporting when the importer, manufacturer, brand owner, and retailers are different entities.
Identifying areas of improvement is not a straight forward process and companies will need support. Also, many companies do not know if their packaging is recyclable in the first place.
For companies with an extensive range of products, it will be a very time-consuming exercise.
What are regulated goods?
Regulated goods are anything, except the following:
- Any machine, equipment, appliance or other device that is designed solely for industrial or manufacturing usage or application (including commercial food processing or production) and any spare part, accessory or peripheral item designed for use with or in the equipment, appliance or device.
- Any specified goods and any spare part, accessory or peripheral item designed for use with or in the specified goods.
- Any arms or explosives within the meaning of the Arms and Explosives Act (Cap. 13).
What is specified packaging?
“Packaging” means any material or combination of materials used for the containment, protection, handling, delivery or presentation of any goods. Note that several exclusions apply such as reusable packaging and packaging for transportation. Contact us to know more.
What is a data report?
Obligated producers will have to report the quantity packaging supplied to Singapore per type and materials. The quantities must be reported using a prescribed template by the NEA.
What is a 3R Plan?
The 3R Plan refers to an activity that the company commit to undertake over the next 3 years to improve packaging or improve the communication around best practices (Reduce, Reuse, Recycle). It must contain at least one of the following improvement plans:
- packaging reduction;
- collect packaging for re-use;
- collect packaging for recycling;
- engage and educate consumers on the reduction, re-use or recycling of packaging;
- engage and educate any industry sector on the reduction, re-use or recycling of packaging;
- use recycled content in packaging material;
- improve the recyclability of packaging used.
Will Zero Waste City be drafting all our reports/plans or any other documents required in the MPR?
If you engage us for everything (screening, packaging assessment, data collection, and 3R Plan), the answer is ‘yes’. The outcome of the tasks “Data Collection and Reporting” and “3R Plan” basically included all the required evidence prepared in an auditable format so they can be submitted to the NEA immediately.
Will Zero Waste City submit these reports/plans/documents to NEA on our behalf?
Yes, if possible.
Note that we are yet to discover how the NEA portal will look like and if you can assign us the right to submit the document on your behalf.
- If it is possible, the answer is ‘yes’.
- If not possible, we will prepare all the required documents so your compliance officer will be able to upload them easily and quickly. In other words, we will prepare all the answers for you, so you just need to copy and paste.
What if NEA comes back with RFI?
When engaged, it is our role to ensure that your company will be complying with NEA rules. There might be times where communication with the NEA will be necessary (to clarify specific items for instance) or additional evidence will be required by the NEA subsequent to a desktop audit post-submission. If that the case, we will be assisting you on this at no additional cost (it is our role to get it right the first time).
Will you come on site?
The first stage (Screening) will require to spend time with the operation and procurement teams to determine the tools we can use to monitor packaging usage. This task could be done remotely via video calls. Also related to the screening step, we will conduct a site visit to observe products and ensure that we have captured all packaging items.
Depending on the findings from the screening step, the packaging assessment might require a site visit to do physical measurements of the packaging used for different products. The time required to complete this task will depend on the number of items to investigate.
Data collection and reporting, as well as 3R Plan, could be all conducted remotely via video calls.
Do we do physical measurements?
Yes, if relevant.
We own a calibrated high-precision scale that we can use to measure the weight of separable and mono-material packaging. The measurement can then be used to submit the data report.
When such measurements are not possible, we use an engineering approach to calculate the weight of each material using the specification sheets from the manufacturer.