fAQ

SECTION A: Obligated Parties

Who does Section 18 define as a “Producer” in the industrial container sector?

A producer is any person or company that manufactures, imports, fills, distributes, or places industrial containers (steel/plastic drums and IBCs) onto the South African market for the first time.

If you introduce the product into South Africa’s economy, you are obligated under EPR.

Who must register with SAICRA?

Any company involved in the manufacturing, importation, filling, resale, or distribution of industrial containers must register. This includes converters, brand owners, chemical & lubricant manufacturers, paint companies, exporters, and industrial distributors.

Who is responsible for paying the EPR fee?

The obligated party at the top of the value chain is responsible:

  • Locally produced containers: the manufacturer or converter
  • Imported empty containers: the importer
  • Imported filled containers: the importer of the finished goods

Fees must be paid to the relevant PRO (SAICRA) as required by law.

Are exporters required to pay the EPR fee?

Exported containers do not attract an EPR fee. Producers may apply for export credits based on auditable proof of export.

SECTION B: Fees & VAT

Are EPR fees VAT-inclusive, VAT-exclusive, or zero-rated?

EPR fees are subject to VAT. They should appear as a VAT-bearing item on invoices.

How are SAICRA’s EPR fees calculated?

Fees are based on the weight (kg) or volume (L) of qualifying industrial containers placed on the market.

The fee structure is reviewed annually to align with legislative targets and operational requirements.

How must EPR fees be shown on an invoice?

Fees may be shown as either:

  • A separate EPR line item, or
  • Incorporated into the unit price

But they must be included and traceable for audit purposes.

What happens if a producer does not belong to a PRO or operate its own approved EPR scheme?

Non-participation is a breach of the EPR Regulations under Section 18 of NEMWA.

This exposes the company to enforcement actions, penalties, and non-compliance status with major supply chains.

How does SAICRA help producers remain compliant?

SAICRA provides the approved EPR scheme, reporting templates, annual performance reviews, and end-of-life support infrastructure to ensure producers meet all legal targets.

What are the annual reporting requirements?

Producers must submit:

  • pAnnual performance data
  • Proof of EPR fee payments
  • Tonnage/volume declarations
  • Any additional information required under Section 18 audit protocols

SAICRA consolidates this and reports to the Department of Forestry, Fisheries & Environment (DFFE).

What is the ten-tonne threshold?

Companies placing 10 tonnes or more of identified products onto the South African market per year must comply with the EPR regulations.

Below this threshold is exempt, unless otherwise required by DFFE.

SECTION D:
Declarations & Data Submissions

What information must be included in the monthly declaration?
  • Locally produced or imported volumes
  • Exported volumes (if applicable)
  • Sales to downstream users
  • Any changes in product categories or materials
  • Supporting documents for audits
How often must producers submit declarations to SAICRA?

Declarations must be submitted monthly, detailing volumes (litres) or tonnages (kg) of industrial containers placed on the market.

What proof is required for export rebates?

Auditable documentation is required, including:

  • Export invoices
  • Bills of lading
  • Customs documentation
  • Delivery confirmations

Credits cannot be issued without verifiable documentation.

SECTION E:
Targets, Circularity & Industry Impact

What are SAICRA’s EPR targets?

Targets are based on:

  • Annual collection volumes
  • Reconditioning & reuse outputs
  • Recycling percentages
  • Waste diversion from landfill

Targets increase progressively as required by DFFE.

What end-of-life activities qualify under SAICRA’s EPR scheme?

Only approved activities count toward compliance:

  • Reconditioning
  • Reuse
  • Recycling
  • Safe disposal of non-recoverable containers
  • Traceable collection and certification

Activities must align with SAICRA’s audited processes and DFFE reporting standards.

SECTION F: SAICRA EPR DICTIONARY

A simple guide to the key terms used in the industrial packaging and reconditioning value chain.

C
Circular
Reuse
.

Circular Reuse refers to the process of cleaning, reconditioning, testing, and returning industrial drums and IBCs back into the market for another safe lifecycle.

It reduces manufacturing demand, limits waste generation, and supports the circular economy requirements set out under Section 18 of the Waste Act.

L
Litres Placed
on Market
(LPM)

This is the total volume of industrial container capacity that a producer introduces into the South African market.

Because these containers are measured in litres rather than weight, LPM is the basis for all EPR declarations and fee calculations.

E
EPR Fee (Extended Producer Responsibility Fee)

A mandatory fee paid by obligated producers—manufacturers, importers, fillers, and reconditioners—to support the recovery, collection, responsible management, and reconditioning of industrial containers as required by Section 18.

A
Accountable
Parties
(Producers)

These are companies that manufacture, import, fill, or recondition industrial packaging and place it into the South African market.

They carry the legal responsibility for meeting EPR requirements, including monthly reporting and fee declarations.

R
Reporting & Recovery Verification

This is the monthly declaration process where accountable parties report all litres placed on the market, along with proof of recovery, reuse, reconditioning, or export.

It ensures that circularity is measured accurately and that compliance can be verified.