NVC MERGE - Luxembourg demo

Background information
The EC Directive on packaging and packaging waste is transposed in a Regulation of 31 October 1998 (in place from 1 January 1999). In March 2017 new packaging regulations (in French, consolidated version) came into force. One of the changes is that the producers/importers are responsible for service packaging waste instead of the companies that sell the (last-minute) packaged product to the consumer. In 2022, the legislation was amended.
In June 2022, three laws published as part of the Circular Economy Package:
Law on packaging and packaging waste: Loi du 9 juin 2022 modifiant la loi du 21 mars 2017 relative aux emballages et aux déchets d’emballages (in French).
Law on waste: Loi du 9 juin 2022 modifiant : 1° la loi modifiée du 21 mars 2012 relative aux déchets ; 2° la loi modifiée du 31 mai 1999 portant institution d’un fonds pour la protection de l’environnement (in French)
Law on the reduction of the impact of SUPs on the environment: Loi du 9 juin 2022 relative à la réduction de l’incidence de certains produits en plastique sur l’environnement. Article 5 prohibits selling certain fruit and vegetables packaged in plastic as of 1 July 2023.
More information can be found here (in French).

The responsible parties are the producers, distributors and importers. They must provide for the collection and recycling of the produced waste. The responsible parties can use their own collection schemes or participate in an authorised collection and recovery system.

Organisations
Valorlux is the authorised collection and recovery system in Luxembourg. Valorlux holds the license for the Green Dot in Luxembourg. Companies that join Valorlux pay membership fees (scroll down) depending on the type of material and the volumes they place on the market.
Valorlux used to only deal with household and commercial packaging waste. In October 2024, Valorlux reported that industrial/non-household packaging must be declared from 2025. In 2022, the packaging legislation was amended (in French) to extend the scope.

The Food, Health and Beauty industry in the Netherlands and the FMCG industry in Belgium and Luxembourg require companies to include packaging information in the GS1 data pool (called GS1 Data Source in the Netherlands and Central Data Bank (CDB) in Belgium & Luxembourg). This enables suppliers and retailers to exchange trade item data via the Global Data Synchronisation Network (GDSN). The information can then be used for, among other things, the declaration to the Packaging Waste Fund, Fost Plus and Valorlux. You can find more information here.

Consumer sorting symbols and other logos
Only members of Valorlux are allowed to use the Green Dot on packaging placed on the Luxembourg market. Use of the Green Dot is not mandatory for Valorlux-members.
In June 2022, a new Law on packaging and packaging waste was published: Loi du 9 juin 2022 modifiant la loi du 21 mars 2017 relative aux emballages et aux déchets d’emballages (in French). Article 10 makes makes material identification labelling mandatory. As far as we know, the material identification symbol is not mandatory in the EU. However, if you do place the symbol on the packaging you must do this according to the rules stated in the European regulations (PDF 126 kB).
In March 2021, the EC published SUP marking requirements for beverage cups and other SUPs, including corrigenda. As of 3 July 2021, the pictograms (use ‘Available Translations’ for the different languages) must be printed in the official language or languages of the Member State(s) where the SUP is placed on the market.

Plastic tax
No information at the moment.

Beverage packaging
So far we have found no information about deposit schemes being in place.

Exporting to this country
The Luxembourg packaging regulations state that the producer or the importer is the responsible party. This means that the importer is the party to join Valorlux. It is however possible for foreign companies to become a member. If they do this they do it on behalf of their importer, who remains legally responsible.
Using the Green Dot is not mandatory in Luxembourg. If you place the Green Dot on the packaging, it might be a suggestion to make sure your importer is a member of Valorlux. Only Valorlux-members are allowed to use the Green Dot in Luxembourg.

The packaging regulations that came into force in March 2017 contain the measures to be taken to reduce the amount of plastic bags. As of 1 January 2019, no plastic bags are allowed to be given away for free at the point-of-sale.

Ongoing matters
In June 2022, a new Law on packaging and packaging waste was published: Loi du 9 juin 2022 modifiant la loi du 21 mars 2017 relative aux emballages et aux déchets d’emballages (in French). Article 7 states that beverage packaging used for human consumption is subject to a single national deposit system. The date and terms of implementation of the deposit system will be defined by the Grand-Ducal Regulation.

Any questions?
If you have any questions there are a number of possibilities for you.

NVC Netherlands Packaging Centre has comprised this guide with due diligence. NVC Netherlands Packaging Centre cannot be held responsible for any incorrect information.
No part of this publication may be multiplied or made public without acknowledgement unless you have prior written permission.