PRODUCER RESPONSIBILITY

Under Section 18 of the Waste Act, each business in the industrial container value chain has specific obligations.

Below is a clear summary of who does what.

Container Manufacturers (Plastic & Steel Drums, IBCs)

Local manufacturers placing new industrial containers on the South African market must:

$

Charge the EPR fee when selling new containers to customers (either as a line item or built into the price).

$

Declare all locally produced containers placed on the market each month.

$

Submit monthly declarations to SAICRA for all new units sold.

$

Pay the EPR fees due for those units each month.

$

Issue credits for exported containers when verifiable audit proof is supplied.

Reason:
They are the first entity placing the regulated packaging item into the SA market.

Importers (Empty or Filled Industrial Containers)

Businesses importing new or reconditioned containers must:

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Pay the EPR fee for every imported container entering South Africa.

$

Declare monthly volumes of all imported containers (empty or filled).

$

Submit monthly declarations to SAICRA reflecting imported units.

$

Ensure accuracy and traceability of all import documentation.

$

Issue export credits where containers are re-exported, subject to proof.

Reason:
Importers are treated as the first placer of regulated packaging in SA.

Reconditioners (Refurbished Drums & IBCs Returned to Market)

Reconditioners placing refurbished containers back into circulation must:

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Charge the EPR fee when selling reconditioned units into the market.

$

Declare all reconditioned containers sold each month.

$

Submit monthly declarations to SAICRA for all units reintroduced to the market.

$

Maintain audit trails for cleaning, testing, and certification.

$

Ensure containers meet safety, quality, and compliance standards before resale.

Reason:
A reconditioned container re-entering the economy is considered a “new placement”.

Fillers, Producers & Distributors Using Industrial Containers

Businesses filling, transporting, or distributing goods using drums/IBCs must:

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Ensure the containers they buy are EPR-compliant (new or reconditioned).

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Check that the EPR fee has been paid by the manufacturer, importer, or reconditioner.

$

Declare imported filled containers, if they import the product themselves.

$

Maintain internal traceability for volumes purchased, used, exported, or disposed.

$

Request export credits with verifiable proof where applicable.

Reason:
These businesses rely on compliant packaging to avoid downstream penalties.

Retailers or Wholesalers Selling Industrial Packaging or Filled Goods

Retailers/wholesalers operating in the B2B industrial space must:

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Ensure that all suppliers they purchase from are EPR-compliant.

$

Include EPR compliance requirements in procurement policies.

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Verify that all packaged products or containers they sell have been covered through an approved EPR scheme.

$

Request compliance evidence from suppliers when needed.

These steps ensure full compliance with Section 18 and maintain your status as a member in good standing.

Through structured governance and accountability, SAICRA turns regulation into measurable progress, ensuring every member contributes to a cleaner, compliant, and sustainable South Africa.