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AFM & Environmental Fund · Circulad'OR Blog

The AFM declaration without fines: the monthly guide, in 10 minutes

Marius Cristian BrînzeaMarius Cristian Brînzea · Managing Partner 24 August 20267 min read
In shortBy the 25th of the month you declare to the Environmental Fund Administration (AFM) what you placed on the market last month: packaging by material category, batteries, electrical equipment. Late filing: 1,000-5,000 lei (RON). But the small fine is the distraction - the real risk is the contribution of 2 lei/kg for unmet targets.

Who declares, and what

Anyone who produces or places packaging (including the packaging of imported products), batteries or EEE on the Romanian market declares - from the factory to the online shop that brings goods in from abroad. The declaration is filed monthly, by the 25th, for the previous month, by material category: paper-cardboard, plastic, glass, metal, wood.

The classic mistake is not lateness - it is declaring quantities that do not tie in with reality. You weigh a piece of packaging once at goods-in, declare it for two years running at the same weight, and in the meantime the supplier has reduced it by 15%. Or the reverse: you declare less than you place on the market, and at an inspection the difference becomes a contribution with penalties.

Where the money is really lost

The real financial stake is the recovery target: for the quantities for which you cannot prove recovery through an OIREP (producer responsibility organisation) or individually, you pay the contribution of 2 lei/kg. At dozens of tonnes a year, a poorly kept packaging portfolio - inflated weights, wrong categories - means thousands of euros paid for nothing.

That is why we always tie the AFM declaration to the actual packaging portfolio, code by code. It is the same discipline Yvora imposes for PPWR: a single source of truth, from which all the documents are generated.

Legal basis: Government Emergency Ordinance (GEO) 196/2005 on the Environmental Fund, as subsequently amended and supplemented.
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