The Packaging Ordinance, which entered into force on 23 November 2023, introduced additional financial, administrative and logistical burdens. AmCham believes that different labelling of beverage packaging for the domestic and export markets discourages exports and increases costs. A dialogue with the authorities is proposed to find sustainable solutions in line with the goals of the circular economy.

AmCham highlighteed key concerns in the new Ordinance and gave concrete recommendations how to improve this regulation.

Key Concerns:

1. Double labeling requirement for beverage packaging — one for domestic sale (with a deposit refund label) and one for export (without the label) — is burdensome.
2. This regulation increases production costs, storage and logistics complexity, energy consumption, and reduces production efficiency.
3. Export competitiveness is threatened, potentially increasing prices for consumers and reducing employment and investment in the beverage industry.

Recommendations:

1. Introduce a flat-rate fee for beverage packaging intended for export — a more manageable and fair alternative to the current labeling requirements.
2. Implement a reporting-based fee model, where producers report market data and pay deposit refund fees only for packaging not returned.

AmCham supports Croatia’s circular economy goals but stresses that industry-government cooperation is essential for achieving them. AmCham advocates an ongoing dialogue to ensure that regulations are both environmentally effective and economically sustainable.