The Return Guarantee System (SGR), a partnership between the private sector and the Romanian state to improve the recycling rate of packaging waste, is to become fully functional by the end of November 2023. As a result, interested companies, namely manufacturers, importers and retailers of beverages operating in the local market, are obliged to comply with a number of requirements established by current legislation by this date. The main and closest one is related to mandatory registration in the database of the administrator of the SGR, namely February 28, 2023.

In particular, the system requires the consumer to pay a guarantee of 0.5 lei/package for the purchased drink and return it on the spot when returning the package to one of the return points organized by merchants in stores, without depending on the presentation of a tax receipt. In addition, the buyer is not required to return the packaging to the store where he purchased the drink, but can return his warranty at any store.

The guarantee applies to such products as beer, beer mixes, alcoholic drink mixes, cider, other fermented drinks, juices, nectars, soft drinks, mineral and drinking waters of any kind, wines and spirits, in single-use packaging (single-use) with plastic, glass or aluminum, with a volume of 0.1 to 3 liters. The rule also applies to companies in the hospitality industry that sell these products, but in this case the warranty is only maintained for products consumed off-site.

The operation of the system is under the responsibility of the SGR administrator, established in accordance with the applicable legislation, which manages the flow of the guarantee from the manufacturer/importer to the end user. It operates on the basis of an administrative commission collected from those who bring the drinks to the market, but in turn pays the retailers for the investment made in the return points.

Stages of registration in the system

But, in addition to these organizational aspects, companies that are required to register in this system face a number of financial, fiscal and legal problems related to compliance with regulations in this field.

First, a manufacturer or importer of goods in the affected categories must register in the administrator’s database by February 28, 2023, which means they will have to complete the necessary documentation by that date. Those who do not register face a fine of 20,000 to 40,000 lei and the loss of the right to sell their products on the Romanian market. After registration, the company signs a contract with the SGR administrator and pays the administrative fee set by him.

In parallel, the relevant company will have to identify and label the products of its range in SGR packaging and analyze the financial and accounting impact associated with the payment of the guarantee in the amount of 0.5 lei/package, including taking into account the time gap between the payment of the SGR guarantee and its return . Last but not least, all involved organizations must keep track of SGR packaging and set up their operational and logistics flow for this packaging.

Therefore, this approach is commendable, but it involves a significant administrative effort for the affected companies, so they must carefully prepare the necessary documentation and carefully analyze the financial and fiscal impact of the entire procedure.

The conclusion material is signed by Adrian Timpeu, director of Deloitte Romania