Become a member of Valorlux?
If your company puts packaging on the Luxembourg market or unpacks products in Luxembourg, there is a possibility that it needs 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 the membership cost? And how do you become a member?
Find answers to all your questions in the following FAQs.
The extended producer responsibility – Legal obligations
Useful information about packaging responsibility for household and industrial packaging
The following companies are seen as parties responsible for packaging and therefore must fulfil three legal obligations: take-back obligation, information obligation and setting up a prevention plan.
Companies established in Luxembourg that
- package household or industrial 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.
- import products with household or industrial packaging or have such products imported in order to put them on the Luxembourg market.
- produce or import service packaging in order to put it on the Luxembourg market. Service packaging is filled at the point of sale where products or services are offered to consumers. Examples include wrapping paper, bread bags, pizza boxes and checkout bags.
- which manufacture transport packaging in its final form (wooden pallets and crates) with the aim of making it available on the Luxembourg market.
Companies established outside of Luxembourg that
- sell packaged products in Luxembourg directly to end users, no matter the sales technique used, including via distance contracts as defined in article L. 222-1 of the Consumer Code.
If you’re not sure whether you’re responsible for packaging, complete our checklist to get an immediate answer.
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 rate for the packaging that they put on the market. In order to achieve this, they must manage their waste (collection, treatment, etc.), as well as the relevant data. The results must then be submitted to the Environment Agency.
2. Information obligation: Companies must inform the Luxembourg Environment Agency of the nature of their packaging and the recycling rates that they have achieved. Furthermore, they must inform consumers about the available return, collection and recovery systems and raise their awareness regarding the correct sorting of packaging waste.
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 of these measures and prepare an annual report.
Become a member of Valorlux: You have to join an approved organisation such as Valorlux, which will then register your company at the Luxembourg Environment Agency and cover your legal obligations. You are then taking part in a collective mechanism.
Currently, Valorlux is the only organism competent for packaging. Those who sell both household and industrial packaging must declare their packaging to us. For packaging that you put on the market in other countries, you should contact the European organisations EXPRA and PRO Europe.
Once you have joined Valorlux, you submit an annual report of all the packaging (household and/or industrial) that you have put on the Luxembourg market.
As a member of Valorlux, your obligations are covered as follows:
1. Take-back obligation (waste management by collection and treatment): Valorlux organises the collection of the blue bag in Luxembourg. The packaging collected in the blue bag is then transported to the sorting centre of Hein déchets in Bech-Kleinmacher, Luxembourg. The sorted fractions are plastic (PET, PE, PP, PS), beverage cartons, iron an aluminium. The collection of the glass and paper/cardboard fractions is carried out by municipalities or syndicates for which they receive financial support from Valorlux. The different fractions are then transported to the corresponding recycling streams.
2. Obligation to inform: Thanks to the packaging declarations submitted by our members, the sorting centre's weighing slips and the recyclers’ certificates, we are able to calculate the recycling rates achieved for each material and submit them to the Environment Agency. This annual report is then published and sent to our members. We ensure the general public is kept informed on sorting, waste prevention and littering through our awareness campaigns.
3. Prevention plan (obligation to implement waste prevention and awareness-raising measures, including for the general public): In collaboration with the Luxembourg Confederation and the Environment Agency, Valorlux has developed a reusable shopping bag and a reusable bag for fruits and vegetables in order to reduce the number of plastic bags placed on the market. To expand and diversify projects in this area, Valorlux has been supporting a few prevention projects in the takeaway food sector since 2026.
Beyond helping you meet your current legal obligations, your Valorlux membership also provides support for future challenges.
Advice on improving your packaging for sorting
We have advised members on optimising their packaging to make it easier to identify at sorting centres, thereby enabling it to be recycled. These collaborations have made it possible to turn packaging waste that was previously not recycled into a resource.
This type of advice can be useful for members who wish to make their packaging sortable and better suited to existing collection and recycling channels. Depending on the characteristics of the packaging and how it evolves, this may also affect its tariff classification. It also enables members to anticipate future requirements regarding packaging recyclability by 2030, when non-recyclable packaging will no longer be allowed to be placed on the European Union market.
Collaboration with Extended Producer Responsibility (EPR) organisations in neighbouring countries
We have a collaboration agreement with the EPR organisations in Belgium, France and the Netherlands (Fost Plus, Valipac, CITEO, CITEO Pro, Verpact). This collaboration offers numerous benefits for our members.
- Optimisation of ‘shared’ costs: the costs associated with audits of recyclers or traceability checks for industrial packaging can be shared with other EPR organisations with which we collaborate.
- Pooling of knowledge: joint analysis and the establishment of a common understanding of the practical aspects of new legal obligations.
Support with procedures relating to Extended Producer Responsibility (EPR)
Our teams assist our members in correctly completing their declarations regarding the placing on the market of household and industrial packaging. This support enables members to optimise their declarations so that their contributions accurately reflect the actual volume of packaging they place on the market.
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 type of packaging material is allocated a Green Dot rate that reflects the actual costs of collection, sorting and recycling. The Green Dot tariff for non-recyclable materials is higher. The revenue that Valorlux obtains from the sale of the materials is also taken into account. When applicable, any excess amounts charged are redistributed to members through a rebate.
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).
Industrial packaging
Détails sur la responsabilité élargie du producteur pour les emballages industriels/non ménagers
According to European Directive 2018/852/EU, Member States must set up extended producer responsibility schemes for all packaging by 31 December 2024. In Luxembourg, the authorised organisation in charge of fulfilling this obligation is Valorlux.
What does this mean in practice?
In practice, responsibility for managing industrial packaging is shared between the company concerned and Valorlux. Here's how it works:
The operational management of your waste remains unchanged; you are free to manage it as you prefer. Valorlux will take care of the administrative management so that we can calculate the recycling rate in Luxembourg and carry out prevention and awareness-raising campaigns.
Yes,same as they do with for household packaging, foreign suppliers have the option to take on their customers' obligation for industrial packaging placed on the Luxembourg market.
In order for a company to fulfil its extended producer responsibility obligations, Valorlux must carry out several tasks.
First, it is necessary to calculate recycling rates in Luxembourg. This requires audits of recyclers and collection centres, as well as ensuring traceability of packaging flows right through to the final recyclers. Notably, some plastic packaging is recycled outside the EU. To reduce these costs, we work with Valipac in Belgium to carry out joint audits, which helps lower overall costs.
Furthermore, member companies benefit from the pooling of declared and recycled volumes. This collective approach enables us to achieve the required recycling rates in Luxembourg and ensures that companies comply with regulatory requirements regarding recycling targets.
Companies with sorted waste containers (of any size) can receive a recycling incentive if these containers are collected by one of the approved collectors listed below.
To be eligible for a recycling incentive, companies must have sorted waste containers that are then collected by an approved collector. The recycling incentive applies to plastic, wooden and metal packaging, and no incentive is granted for mixed waste containers.
This incentive can be claimed each year from May to November. The amount of the incentive is calculated on the basis of the weight of packaging waste collected by your approved collector.
Approved collectors
- Ecotec
- Eu-Rec
- Hein Déchets
- Lamesch
- Liébaert
- Logico
- Paprec
- Polygone
- Remondis
- Renewi
- Steil Entsorgung
The packaging report – Practical aspects
As a member of Valorlux, every year you must submit a declaration for all the packaging that your company puts on the Luxembourg market.
You submit your declaration via our online reporting system Valbase Online.
The key contact for your declarations, which was defined with us at the time you became a member, can set a password and access the system. They 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
You don’t have access to Valbase Online?
Contact us by email via [email protected] or by phone +352 37 00 06 - 30 to solve the issue.
Having trouble with Valbase Online?
The deadline for the annual packaging report is always 28th February for the packaging that you put on the market the previous year. Thus, you have to submit the report for the packaging that you put on the market in 2025 by 28th February 2026 at the latest.
Be sure to submit your declaration on time! Otherwise, you risk being issued a contractual penalty 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 Luxembourg 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, you need to file a packaging report. In the report, you state all the packaging that your company puts on the market, including reusable packaging (for more information, see question No. 4 in the next section). Your report includes packaging for selling, grouping and transporting your products for household consumption, for the industry or for sales in the retail trade.
If you are situated in Luxembourg, you 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 5 in the next section of 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 at our members list to see which of your suppliers is already a member of Valorlux. There is also a feature in Valbase that allows you to specify your supplier relationships directly within your report.
Definitions and distinctions between types of packaging
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. Their sole function is to package a product.
For some other products, such as coffee capsules, hangers or cases for video games, the situation is not always as straight forward. In case of doubt, please consult our list of distinction between packaging and non-packaging.
Household packaging (primary packaging of household products) and industrial packaging (secondary and tertiary packaging and the primary packaging for products of more than 10 kilograms or litres) need to be reported separately. To better distinguish both types of packaging, 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 domestic 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 in an industrial setting, such as in an office. 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 litres, for example, is considered to be household packaging. Drinks packaging with a content of over 10 litres is industrial.
Valorlux has drawn up a list of products that may cause doubts about which category they belong to.
All the packaging you place on the Luxembourg market must be declared, including:
- Packaging for products packaged by your company
- Packaging for products imported by your company. Imported products only concern packaging from suppliers who are not members of Valorlux.
The 4 materials that need to be declared are paper/cardboard, wood, metal and plastic.
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Method A: Product sheets or annual consumption data
Method B: Certificate from your waste management collector
From the reporting year 2023 onwards, reusable packaging used in a closed loop has a Green Dot tariff of EUR 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.
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, deli containers or checkout bags.
Service packaging that 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.
Reporting types - Household and industrial
You will find below an overview of the different reporting types for packaging. If necessary, you can also combine different reporting types.
Please note: when 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 you distribute.
If you do not know the detail of your packaging, you need to report the smallest sales unit in a simplified manner by product categories. 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 finalise your report your need to map your products in 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 packaging 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 benchmark 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.
Industrial packaging needs to be reported since 2024.
There are two methods for declaring industrial packaging put on the Luxembourg market, which can be used individually and in combination:
Method A: Declaration of the mass on the basis of the product sheets or of the yearly consumption data
Applicable to packaging whose theoretical mass is known. The declaration is made on the basis of product sheets or annual consumption data.
Product sheets
- If you have product sheets containing a description of the packaging used (material and weight), all you need to do is obtain the number of sales units in Luxembourg.
- Then multiply the quantities of industrial packaging by the number of units sold in Luxembourg to determine the quantity of packaging to be declared.
Annual consumption data
- If you have the annual consumption quantities required to pack your products (for example, rolls of stretch film), you simply need to calculate the ratio between products sold in Luxembourg and those sold abroad, and then multiply this ratio with the quantities of packaging consumed.
- If you don't know the ratio of products sold in Luxembourg, you can also base your calculations on the turnover achieved in Luxembourg compared with that achieved abroad.
Method B: Declaration of mass collected in waste containers
Applicable when the theoretical mass is not known. The declaration is made on the basis of the waste recovery certificate you get from your waste management collector.
1. Firstly, you need to obtain the total annual quantity of packaging waste collected by your waste management collector.
2. Next, you need to apply a percentage by dividing the number of suppliers who are not Valorlux members by the total number of your suppliers. You do not need to declare packaging already declared by suppliers who are Valorlux members. To check which suppliers are already members, we recommend that you consult our members list. Please document the method you used to calculate this percentage.
3. Finally, a ‘packaging waste percentage’ is automatically applied on the Valbase platform, as waste containers do not only contain packaging. This prevents you from declaring too much. This percentage is visible when you declare your packaging. If you think this percentage needs to be adjusted, please contact us.
Download our guide to help you declare your non-household/industrial packaging (in French).
Be compliant!
To ensure your compliance with household and industrial packaging regulations, join Valorlux. As a member, you will benefit from comprehensive support in declaring your packaging and contribute to responsible waste management in Luxembourg.
Fill in the Valorlux membership form today and make sure you are legally compliant.
You don’t know if you have to become a member of Valorlux? Complete our check-list and you will have the answer immediately.
You still have questions?
Our helpdesk is at your disposal +352 37 00 06 1 or [email protected]
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