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Singapore Allows Deferral of Submitting Mandatory Packaging Report and 3R Plan

On May 25, 2023, the Resource Sustainability (Packaging Reporting) (Amendment) Regulations 2023 (hereinafter referred to as the Rule) was made public in the Government Gazette by Singapore’s Ministry of Sustainability and the Environment (MSE). According to the Rule, the deferral of the submission deadline for Mandatory Packaging Reporting (MPR) and 3R plan* may be allowed if the National Environment Agency (NEA) permits it in certain cases. The Rule has come into force on May 26, 2023.

*3R plan: A plan to reduce, reuse, or recycle packaging in Singapore.

To lay the foundation for an EPR system for managing packaging waste, the packaging reporting framework - MPR came into force on July 1 of 2020 under the Resource Sustainability Act (RSA). The Rule is a subsidiary legislation supplement under the RSA, prescribing the reporting requirements for packaging materials. Previously, obligated stakeholders should submit an annual report on specified packaging that is imported or used in Singapore and the 3R plan to the NEA before March 31 of each year. Now, in Article 7(1) and Article 8(1) of the Rule, after “March 31 of each year”, “or any later date that the Agency may allow in any particular case” is inserted.

The official document can be accessed here.

Requirements for MPR and 3R Plan of Packaging

So far, in Singapore, the EPR system does not cover packaging. However, mandatory reporting requirements (MPR and 3R plan) apply to specified packaging under the RSA.

Who shall submit?

Brand owners, producers, importers, and retailers such as supermarkets) in Singapore that meet all the following criteria are obligated to fulfill the requirements:

- Supply regulated goods in Singapore

- An annual turnover of more than SGD 10 million

- Import or use specified packaging

What information shall be provided?

  • For Mandatory Packaging Reporting:

    The report should provide information on the material, weight (amount) and form of specified packaging imported or used in the year. More specifically, the type of packaging material (e.g., plastic, paper, metal, glass) and packaging form (e.g., carrier bags, bottles).

  • For 3R plan:

    The plan shall provide details on the key initiatives, key performance indicators (KPIs) and targets, reporting on the progress of these plans in subsequent years of reporting. The types of 3R plans for packaging that companies could consider, including:

        (i) packaging reduction,

        (ii) packaging collection for reuse and/or recycling;

        (iii) consumer and/or industry outreach related to packaging 3Rs;

        (iv) use of recycled content in packaging material; and

        (v) improving recyclability of packaging.

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