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As a member of the European Union, the Republic of Croatia is obliged to implement the provisions of Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 2019 on reducing the impact of certain plastic products on the environment by 3 July 2021. Therefore, the new Law on Waste Management has entered the legislative procedure, which in relation to the previous Law on Sustainable Waste Management, imposes additional requirements regarding placing single use plastic products on the market, their marking and disposal. The proposal of the Law on Sustainable Waste Management is currently in the phase of second reading in the Croatian Parliament, so it is expected to be adopted soon.

A variety of products such as filter tobacco products, wet wipes, ear sticks, cutlery, straws, food and beverage containers, glasses, bottles, stoppers, lids, etc., are considered to be single use plastic products.

The Republic of Croatia has set certain goals by the proposal of the law regarding disposable single use plastic products. Thus, one of the goals is that all PET bottles placed on the market in the Republic of Croatia from 2025 on average contain at least 25% recycled plastic, and from 2030 at least 30% recycled plastic. The permitted composition for individual products will be prescribed in more detail by by-laws, the adoption of which is still pending.

In addition to the composition of disposable single use plastic products, the new law imposes additional marking requirements. The manufacturer of a product that places a disposable plastic product on the market of the Republic of Croatia will be obliged to ensure that the product has a visible, legible and indelible mark on the packaging or product itself, which must contain a notice to consumers of waste management or ways by which disposal of waste from that product can be avoided in accordance with the waste management order of priority, and the presence of plastic in the product and the negative consequences of disposing of waste into the environment or other inappropriate disposal of waste from that product.

Single use plastic products that are subject to the marketing obligation of 3 July 2021 may be on the market after this date, without being properly marked if they have already been placed on the market in the Republic of Croatia before 3 July 2021 (specifically, entered in the business records of manufacturers) and can be sold until stocks last in the Republic of Croatia even after 3 July 2021. However, products subject to the marking obligation of 3 July 2021 that have already been placed on the market in the Republic of Croatia before 3 July 2021 will not be available in other EU Member States. The same applies to products whose placing on the market will be banned from 3 July 2021 by the new Law on Waste Management.

Although the new law has not yet been adopted, it is already clear that the legislator has provided high fines for violating its provisions. Therefore, we advise you to harmonize your business with the new requirements regarding disposable plastic products in a timely manner.

Sunčica Šimić