Packaging Accounting

Producers and importers intending to place filled packaging on the Lithuanian domestic market, packaging manufacturers intending to place empty packaging on that market, foreign persons and authorised representatives must:

• Register in the Register no later than one working day before first placing the relevant products on the Lithuanian domestic market or exporting them from Lithuania. Since 2018, registration has been completed through the Unified Product, Packaging and Waste Accounting Information System (GPAIS) at www.gpais.eu.
• If information changes, submit a completed application containing the updated information through GPAIS no later than ten working days after the change.

The following are exempt from registering in the Register of Producers and Importers and maintaining packaging records:

• companies that are not required to register for value added tax (VAT) under the Lithuanian Law on Value Added Tax, except producers and importers placing products in packaging covered by a deposit system on the Lithuanian domestic market;
• goods imported by a company during the reporting period, including packaged products, that are exempt from import VAT under the Law on Value Added Tax.

Packaging Accounting

The following are exempt from registering in the Register of Producers and Importers and maintaining packaging records:

• companies that are not required to register for VAT under the Lithuanian Law on Value Added Tax, except producers and importers placing products in packaging covered by a deposit system on the Lithuanian domestic market;
• goods imported by a company during the reporting period, including packaged products, that are exempt from import VAT under the Law on Value Added Tax.

Members of Žaliasis taškas may contact our specialists for a more detailed explanation of packaging accounting. In response to current legislative changes, we prepare additional information about the organisation of packaging and packaging waste management.

Members can also request an additional service: qualified Žaliasis taškas specialists can carry out an environmental audit at their company.

Main Packaging Accounting Requirements

Packaging accounting is carried out in accordance with the Rules on Packaging and Packaging Waste Management.

Regardless of the quantity placed on the Lithuanian market, all producers and importers must maintain records of all packaging filled with products, while all packaging manufacturers and importers must maintain records of all empty packaging.

Packaging accounting must be organised as follows:

1. Records must be maintained according to a procedure established by the head of the company.
2. The head of the company appoints persons responsible for:
   • maintaining the packaging records and correctly submitting all data;
   • correctly determining packaging weight;
   • retaining documents.
3. The head of the company approves the method used to determine packaging weight.

Packaging records are maintained and reports submitted through GPAIS (www.gpais.eu) according to the following principles:

1. empty packaging and packaging filled with products are recorded separately;
2. according to their material, empty and filled packaging are classified as glass, plastic, PET, paper and cardboard, metal, composite, wood or other packaging;
3. the predominant material in composite packaging is recorded separately;
4. packaging filled with products is classified as sales (primary), grouped (secondary) or transport (tertiary) packaging; by use it is classified as single-use or reusable, and by the way it is supplied to the Lithuanian market as used for own needs or transferred to another person;
5. single-use and reusable packaging filled with products are recorded separately;
6. packaging filled with products and used for own needs is recorded separately from packaging transferred to another person;
7. packaging filled with products for which a deposit must be charged is recorded separately from other filled packaging;
8. single-use packaging subject to a deposit is recorded separately from reusable packaging subject to a deposit;
9. the recorded packaging weight includes the weight of its components and ancillary elements, although those weights may also be stated separately;
10. packaging designed and used repeatedly without initial processing, such as wooden pallets, must be recorded as reusable packaging. Once products received in such reusable packaging have been unpacked, the packaging must be returned to the producers and/or importers that supplied it unless otherwise agreed by contract;
11. for single-use packaging, records must additionally state whether the packaging or its waste is recycled or non-recyclable.

When maintaining packaging records in GPAIS:

1. lists of product units and their packaging are prepared;
2. the packaging accounting journal for the relevant calendar quarter is completed at least once per quarter;
3. after the quarter ends, a quarterly packaging accounting summary is generated and approved within 30 calendar days. If it is not approved by the deadline, the person responsible for packaging accounting may incur administrative liability;
4. after the calendar year ends, an annual packaging accounting report is generated within 30 calendar days and submitted to the Environmental Protection Agency for assessment within 50 calendar days. If the company ceases operations or is deregistered, the annual report must be generated and submitted before operations cease or deregistration takes effect.

Once a quarterly packaging accounting summary has been approved, the underlying data may be corrected only by stating the reason for the correction. At the request of environmental control officers or other authorised officials, the person responsible for packaging accounting must immediately provide evidence and/or information supporting that reason.

Data and information in the packaging records must be supported by the company's other accounting documents, purchase and sale documents, documents concerning the import of goods into and export of goods from Lithuania, transport documents, and other documents confirming the existence and movement of packaging.

Information recorded for reusable packaging subject to a reusable-packaging deposit system, and for single-use packaging and its waste subject to a single-use deposit system, must match the data held by barcode-recognition systems.

Important: producers and importers placing packaging used for their own needs on the market must also maintain waste-generation records and additionally register in GPAIS as waste producers.