Industrial packaging
As a member of Valorlux, you are required to declare industrial packaging placed on the market from 2025. This page will guide you through the declaration process, the types of packaging concerned, and the responsibilities to be met in order to comply with the regulations in force.
Declaration of industrial/non-household packaging from 2025.
The declaration will have to be made between January and February 2025, and will cover industrial packaging placed on the market in 2024.
Legal context
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, this means that those responsible for packaging must contractually entrust an approved organisation with the fulfilment of this obligation, in whole or in part, according to Article 8 of the Law of 9 June 2022 on packaging and packaging waste.
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.
Who is responsible for industrial/non-household packaging?
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A company established in Luxembourg that directly or indirectly packages industrial products for placement on the Luxembourg market.
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A company established in Luxembourg that imports, directly or indirectly, products with industrial packaging.
Can I take over the extended producer responsibility as a foreign company?
As with the declaration of household packaging, foreign companies have the option to take on their customers' obligation for industrial packaging placed on the Luxembourg market.
What is industrial/non-household packaging?
Industrial packaging includes:
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tertiary packaging (stretch film for pallets, protective corners, one-way pallets)
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secondary packaging (cartons, boxes, canisters)
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primary packaging* for products intended for professional use
*If you have any doubts about the distinction between industrial and household packaging, please consult our grey list.
For the first reporting year in 2025, reusables do not have to be reported (e.g. Euro pallets, but all single-use pallets must be reported).
How do you declare this packaging?
There are two methods for declaring industrial packaging put on the Luxembourg market, which can be used both individually and in combination:
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.
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.
- Firstly, you need to obtain the total annual quantity of packaging waste collected by your waste management collector.
- Next, you need to apply a percentage by dividing the number of suppliers who are not Valorlux members by the total number of 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.
- 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.
Please note that the costs and figures shown in this image are for illustrative purposes only and may be adjusted at any time.
What industrial packaging must be declared?
All the packaging you place on the Luxembourg market must be declared, including :
- Packaging for products packaged by your company: Finished products
- Packaging for products imported by your company: Imported products*, raw materials, spare parts
* Imported products only concern packaging from suppliers who are not members of Valorlux.
Method A: Product sheets or annual consumption data
Method B: Certificate from your waste management collector
Recycling incentive
Companies with sorted waste containers (of any size) collected by an approved collector can receive a recycling incentive. This incentive applies to plastic, wood and metal packaging and can be claimed each year from May to November. The amount of the incentive is calculated on the basis of the mass of packaging waste collected by your collectors.
Please note that no incentive is paid for mixed waste containers.
Our FAQ
For any other questions, please consult our FAQ or contact us directly.
The first declaration must be made between the beginning of January and the end of February 2025, covering industrial packaging placed on the Luxembourg market in 2024.
All industrial packaging placed on the Luxembourg market, including packaging for products packaged by your company (finished products) and packaging for imported products* (raw materials, spare parts).
* Imported products only concern packaging from suppliers who are not members of Valorlux.
Industrial packaging is used mainly for products for professional use and includes tertiary and secondary packaging, as well as primary packaging for products weighing more than 10 kg or litres. If in doubt, you can consult our grey list.
There are two methods: on the basis of product sheets or yearly consumption data (method A) for packaging whose mass is known, or on the basis of the mass collected (method B) for packaging whose mass is not known.
Yes, if your waste containers are sorted and collected by an approved collector. The recycling incentive applies to plastic, wood and metal packaging, but no incentive is granted for mixed waste containers.
Yes, foreign suppliers can take on their customers' obligation for industrial packaging placed on the Luxembourg market, in the same way as for household packaging.
In this case, you can use the declaration method based on the mass of packaging collected, using the recovery certificate provided by your waste management collector.
In order for your company to comply with the European directive and fulfil its obligations in terms of extended producer responsibility, Valorlux must carry out several tasks.
Firstly, it needs to calculate the recycling rates in Luxembourg. This requires audits of recyclers and waste collection centres, as well as work to trace packaging flows back to the final recyclers. Some plastic packaging is recycled outside the EU. To reduce costs, we are working with Valipac in Belgium to carry out joint audits, thereby reducing overall costs.
In addition, Valorlux runs prevention campaigns to promote the proper disposal of packaging waste and optimise the quantities of packaging used for products.