Become a member of Valorlux?

If your company puts household packaging on the Luxembourg market, it could need to fulfil several legal obligations. 

 

When exactly is your company seen as a party responsible for packaging? And as such, which legal obligations do you have to fulfil? How can Valorlux help you with this? How much does membership cost? And how do you become a member?

 

Find answers to all your questions in the following FAQs.

A party responsible for packaging


Useful information about packaging responsability.

 

The following companies are seen as parties responsible for packaging and therefore must fulfil three legal obligations (take-back obligation, information obligation and prevention plan):

 

  • Companies established in Luxembourg that package household products or have such products packaged in Luxembourg in order to put them on the market under their own brand name or under a neutral brand.

  • Companies established in Luxembourg that import packaged household products or have such products imported in order to put them on the Luxembourgish market.

  • Companies established in Luxembourg that produce or import service packaging in order to put it on the Luxembourgish market. Service packaging is applied in the place where products or services are offered to consumers. Examples include wrapping paper, bread bags, pizza boxes and checkout bags.

  • Companies established outside of Luxembourg that sell packaged products in Luxembourg directly to households or to users outside of households for professional purposes, no matter the sales technique used, including via distance contracts as defined in article L. 222-1 of the Consumer Code.

Companies that fall within the category of parties responsible for packaging have to fulfil three legal obligations:

 

  1. Take-back obligation: Every year, companies must achieve a set recycling percentage for the packaging that they put on the market. To do this, they must manage their waste (collection, treatment, etc.).
  2. Information obligation: Companies must inform the Luxembourgish Environment Agency of the nature of their packaging and the recycling percentages that they have achieved. Furthermore, they must inform consumers about the available return, collection and recovery systems.
  3. Prevention plan: Companies must draw up a prevention plan setting out the measures that they are taking to reduce their quantity of packaging and the goals that they aim to achieve. They must also inform the general public about their taken actions and prepare an annual report.

Become a Valorlux member: You can join an approved organization such as Valorlux, which will then register your company to the Luxembourgish Environment Agency and cover your legal obligations. In this case, you take part in a collective mechanism.

 

Currently, Valorlux is the only organism competent for household packaging. Those who sell both household and industrial packaging can declare their household packaging with us. For packaging that you put on the market in other countries, you should contact the European organizations EXPRA and PRO-EUROPE.

 

Once you have joined Valorlux, you submit an annual declaration of all the packaging that you have put on the Luxembourgish market.

As a member, Valorlux covers your obligations as follows:

 

1. Take-back obligation (waste management by collection and treatment): Valorlux organizes the collection of the blue bag in Luxembourg. The packaging collected in the blue bag is then transported to the sorting center of "Hein déchets" in Bech-Kleinmacher (Luxembourg). The sorted fractions are among others PET, PE, PP, PS, beverage cartons, iron & aluminum. The collection of the glass and paper-cardboard fractions is supported by financial support towards municipalities or syndicates. The different fractions are then transported to the corresponding recycling branches.

 

2. Obligation to inform: By organizing the collection and treatment of the different materials required by law, we can establish and communicate a percentage of collection & recycling to the Luxembourgish Environment Agency, if we receive the packaging data for Luxembourg from all our members once a year. As a non-profit organization, the costs to support our collection, treatment and prevention measures are paid by our members in relation to their packaging declaration. Members who declare more packaging or packaging which is more difficult to recycle do pay a higher amount to support our collective system. The obligation to inform the public is covered by our blue bag communication campaigns 

 

3. Prevention plan: In collaboration with the Luxembourg Confederation and the Luxembourgish Environment Agency, Valorlux has developed an exchangeable and reusable shopping bag for fruit and vegetables among others, the Superbag®. Another project, the Eco-bag, a reusable shopping bag, also aims to reduce the use of disposable packaging. Both projects and the associated communication campaigns also apply to our members.

 

As a member of Valorlux, you pay an annual contribution. The amount depends on the type and quantity of packaging that you put on the market.

 

The annual contribution for your company is calculated based on the Green Dot rates (detailed reporting, simplified reporting). Each packaging material is allocated a Green Dot rate that reflects the actual cost of collection, sorting and recycling. The revenue that Valorlux obtains from the sale of the materials is also considered.

 

Depending on the declaration system that you choose, the rates are applied per kg or per unit. The minimum contribution is EUR 50. You do not pay any contribution for reusable packaging in your declaration. If you declare solely reusable packaging, you pay the minimum contribution.

 

Consult our current Green Dot rates on the following link (detailed reporting, simplified reporting).

Not entirely sure whether you should become a Valorlux member? In that case, fill out our checklist and get an answer to your question right away. 

 

Any questions left?

Our helpdesk is at your disposal: +352 37 00 06 1 or [email protected]

 

Do you want to become a member of Valorlux?

Go to the contact form in our member section and register your company. After sending the form, a Valorlux employee will contact you to finalize your membership. 

 

Valorlux has over 1,000 members. In our list of members, you can find the companies that are already affiliated.

 

The packaging report


As a member of Valorlux, every year you must submit a declaration for all the household packaging that your company puts on the market.

 

You enter your declaration via our online reporting system Valbase Online

 

The key contact for your declarations which was defined together with us at the time of your subscription can set a password and access the system. He can also add or delete new contacts to your company's access and give them reading or writing roles.

 

As a Valbase user you cannot only prepare your packaging report in Valbase Online, but also access your invoices, request reports and manage your account

 

Not having access to Valbase Online?

Contact us by email via [email protected] or by phone +352 37 00 06 - 30 to solve the problem.

 

Having trouble to use Valbase Online? 

A user guide for Valbase Online is available in the media library of Valbase Online.

The deadline for the annual packaging report is always 28 February for the packaging that you put on the market the previous year. In other words, you have to submit the report for the packaging that you put on the market in 2023 by 28th February 2024 at the latest.

 

Be sure to submit your declaration on time! Otherwise, you risk a fine amounting to 1% of the contribution from your previous report per month of delay.

After joining us, you need to submit your first packaging report at the beginning of the following calendar year.

 

If your company has already put packaging on the Luxembourgish market in past years, you can also join us retroactively.

 

After sending us your contact form and signing your membership contract, you will receive emails from us with useful information on how to fill in your first packaging report.

Once a year, we need to a receive a packaging report from you. In the report, you state all the household packaging that your company puts on the market, including reusable packaging (for more information, see question No. 8). By household packaging we mean the sales, grouping and transport packaging of products intended for a usage in households or comparable environments such as offices, communes, restaurants, etc.

 

If you are situated in Luxembourg, you would need to declare all the products you pack yourself and the packaging you import and distribute in the country. Service packaging constitutes a specific case, please have a look at question 7 in this FAQ to see if you are affected.

 

Please note: If the supplier of your imported products is already a member of Valorlux, you can exclude their packaging from your packaging report.

 

Have a look on our member list to see which of your suppliers is already a member of Valorlux. 

It is usually clear whether an element around a product is packaging or not. Bottles, butter tubs and tin cans are clear examples of packaging. After all, their sole function is to package a product.

 

For some other products, such as coffee capsules, cloth hangers or cases for films and video games etc. the situation is sometimes less clear. In case of doubt, please consult our list of distinction between packaging and non-packaging.

Only household packaging needs to be reported to Valorlux (primary, groupage and transport packaging). Industrial packaging on the other hand must not be included in your report. To better distinguish, it is important to know that the use of the packaged product determines the category into which the packaging falls. So, the packaging around a household product is household and the packaging around an industrial product is industrial.

 

Some products can be used for both household and industrial purposes:

 

  • A television set is usually a household product, but it can also be used industrially. In both cases, however, the packaging around a television set is considered to be household packaging.

 

  • The volume plays a role for certain products. Drinks packaging with a content of less than 10 liters, for example, is considered to be household packaging. Drinks packaging with a content of over 10 liters is industrial. 

 

Valorlux has drawn up a list of products that may cause doubts about which category they belong to.

Service packaging is packaging that is used to offer goods or services to the consumer. This packaging is usually only applied the moment when the product is sold to the consumer.

 

Examples of service packaging include bread bags, wrapping paper, pizza boxes, processed meat pots, checkout bags, disposable cups, etc.

 

Service packaging which is purchased in Luxembourg must be declared by your supplier. If you use service packaging from foreign suppliers, please check out our member list to see if you have to declare it or not.

 

A list to identify service packaging is available here.

 

From the reporting year 2023 onwards, reusable packaging used in a closed loop has a Green Dot tariff of € 0 per kilogram and has to be included in the packaging report.

 

A reusable packaging element in a closed loop system is a packaging solution designed to be used multiple times, while remaining within a defined circuit. In this system, the goal is for the packaging's function to remain unaltered, even though the user may change. For packaging to be considered as evolving in a closed loop system, the ownership of the packaging needs to be maintained by ensuring the collection, the cleaning, and the reintroduction into circulation after each use.

Reporting types


Please find below an overview of the different reporting types. If necessary, you can also combine different reporting types.

 

Please note: Once you sign up, Valorlux will evaluate with you which type of reporting is most appropriate for your company The decision depends on your sector of activity, the size of your company and the type of packaging.

If you do not know the detail of your packaging, you need to report in a simplified manner by product categories, the smallest sales unit. This classification is often necessary if you are not the producer of your goods and do not know the material or the composition of your packaging. The simplified categories are predefined by Valorlux, to finalize your report your need to map your products to our simplified categories and indicate the units you want to declare in the appropriate category.

 

Example: if you want to report a six-pack of soda, you must declare 6 units in the simplified category "Sodas, colas, lemonades and syrups".

 

The tariffs for the simplified reporting can be downloaded here.

This reporting type is assigned to members with a good knowledge of their products, which is often the case for producers.

 

With a detailed report, your contribution is calculated based on the quantity of packages you put on the market and their exact composition. For each product, you need to create a packaging sheet with the packaging material and the weight of each packaging element. Afterwards, you indicate the units you want to declare per product.

 

The tariffs for the detailed reporting can be downloaded here.

 

In some very specific cases, members who have submitted their first packaging report, the reference declaration, in a simplified or detailed format, can have their following packaging reports calculated based on their sales revenues.

 

If this is the case for your company, it is sufficient to indicate your turnover rates for Luxembourg to successfully submit your declaration. Your contribution will then be calculated based on the variation of your sales revenue.

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