The Resource Sustainability Act (RSA) was gazetted on 4 October 2019 in Singapore. RSA is an Act to impose obligations relating to the collection and treatment of electrical and electronic waste and food waste, to require reporting of packaging imported into or used in Singapore, to regulate persons operating producer responsibility schemes, and to promote resource sustainability.
Part 4 "Report in Relation to Packaging" of the Act specifies the requirements of Mandatory Packaging Reporting (MPR). It is stated that companies that meet the prescribed threshold criteria of an annual turnover of more than $10 million and are currently supplying regulated goods in Singapore, will be required to submit annual reports on specified packaging imported/used and the 3R (Reduce, Reuse and Recycle) plan for packaging in Singapore based on prescribed requirements. Companies are also required to keep records related to reports and plans based on the prescribed requirements and retention period.
The objective of Mandatory Packaging Reporting (MPR) is to bring greater awareness and spur companies to see the potential benefits and take action to reduce the amount of packaging used and packaging waste disposed of. This is also key to prepare companies for the Extended Producer Responsibility (EPR) framework for packaging waste management which will be implemented no later than 2025. These packaging data collected could also aid in future review and development of policies and programmes on packaging waste management.
The initial plan was for obligated companies to submit online the 6 months of packaging data from 1 July 2020 to 31 December 2020 by 2021 and repeated annually by producers. However, in light of the COVID-19 pandemic and its impact on the industry, the timeline for the Mandatory Packaging Reporting (MPR) has been revised. The first annual packaging reports containing the 2021 packaging data must be submitted by 31 March 2022 together with the 3R plans. The National Environment Agency (NEA) will also be publishing an Administrative Guidance at the MPR website in 2Q/3Q 2021 to provide obligated companies with more clarity on how to comply with the MPR requirements.
In preparation for the MPR regulation, there are no specific tests to be completed as of now. However, National Environment Agency (NEA) did release records and documents that may have to be presented for MPR. Some examples of records to be kept and supporting documents include:
1. Supporting documents that show how packaging quantities imported/used are calculated in the report:
Import/export receipts/custom declaration and summary
Packaging specification with packaging weight information
Inventory records
2. Supporting documents that show the progress of implementation of 3R plans
Specification for old and new packaging
Amount of packaging collected for reuse or recycling
No. of people or companies engaged through outreach activities
No. of outreach events
Regarding the impact of this regulation on cosmetic companies, it is not possible to predict the impact as the regulation and guidelines have not been put in place or implemented.
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