What is Chile EPR Packaging

Chile’s packaging EPR regime is governed by Law No. 20.920 of 2016 (Ley REP) and, for packaging specifically, by Supreme Decree No. 12/2020 of the Ministry of the Environment, published on 16 March 2021. The decree sets collection and recovery targets and related obligations for envases y embalajes. The packaging targets began to apply from 16 September 2023.

Under this framework, producers must organize and finance the waste management of packaging they place on the Chilean market, either individually or through a management system. The regime covers both household and non-household packaging and is supervised through Chile’s national REP infrastructure.

Does this apply to e-commerce & online sales

Yes. Chile’s REP rules apply regardless of the sales channel. The producer test is based on whether a company introduces the packaged consumer good into the national market, not on whether the sale happens in-store or online. The official producer definition applies “independently of the commercialization technique,” which captures e-commerce and distance selling.

For cross-border sales, the key compliance question is who is legally introducing the packaged product into Chile. If a foreign company is the entity first selling the packaged good into the Chilean market, sells under its own brand, or imports packaged goods for its own professional use in Chile, it may be the REP producer. In practice, Chile’s registration system requires a RUT, a registered establishment and Clave Única, so foreign sellers usually comply through a Chilean legal entity, importer, or local business presence rather than through a purely foreign registration.

Who is the “producer” under Chile EPR?

Under Law No. 20.920, a producer is any person who, independently of the commercialization method:

1. Places a priority product on the Chilean market for the first time
2. Places a priority product on the market under its own brand, where it was acquired from a third party that is not the first distributor
3. Imports a priority product for its own professional use

For packaging, the law and DS No. 12/2020 specify that the producer is the person who introduces the packaged consumer good into the Chilean market. The decree further defines “introducing into the national market” as first sale, own-brand sale of a packaged product acquired from a non-first distributor, or import for own professional use.

Who must register for EPR packaging in Chile

All in-scope producers of packaging must register in the REP system and comply with REP obligations. Law No. 20.920 expressly states that producers of priority products must register, organize and finance waste management, and comply with collection and recovery targets through a management system.

The relevant authority is the Ministry of the Environment. Registration is done through the Ventanilla Única of the RETC (Registro de Emisiones y Transferencias de Contaminantes) under the REP producer system. Once the registration request is reviewed by the Ministry, access to the REP producer module is enabled.

Chile EPR Packaging Registration Threshold

Chile does not apply a general turnover or tonnage threshold for packaging EPR comparable to some EU markets. The packaging decree applies to producers introducing packaged consumer goods into the market, and the core exemption recognized in the official training material is for microenterprises as defined by Law No. 20.416. That law defines microenterprises as businesses with annual sales and service income not exceeding 2,400 UF in the previous calendar year.

As a result, foreign companies should not assume there is a broad de minimis threshold. The main practical threshold issue is whether the relevant Chilean entity qualifies as a microenterprise under Chilean law. If not, the packaging REP regime should generally be treated as mandatory once the company is the producer for Chilean market-entry purposes.

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Packaging Covered (and Excluded)

Chile’s packaging decree covers packaging in the main material categories used for REP compliance, including paper and cardboard, plastic, glass, metal, carton for liquids, wood, and other non-wood materials within the REP registration structure.

The decree distinguishes among:

1. Primary packaging
2. Secondary packaging
3. Tertiary packaging

It also distinguishes between:

1. Household packaging (envases domiciliarios)
2. Non-household packaging (envases no domiciliarios)
3. Reusable packaging and packaging that has become waste

Important special categories also exist, including service packaging, composite packaging, agro-industrial packaging, and packaging containing hazardous substances. Containers are excluded from the definition of tertiary packaging.

Producer Responsibility Organization (PRO)

Chile’s REP law allows producers to comply individually or collectively through a management system (sistema de gestión). For packaging, collective systems are a central part of compliance, particularly for household packaging.

The main collective packaging system currently active in the market is ReSimple, the collective management system for packaging and packaging waste. However, ReSimple is not the regulator or the producer register itself. The legal registration remains with the Ministry of the Environment through RETC/Ventanilla Única, while the management system is the operational vehicle through which producers meet collection and recovery obligations.

EPR Registration in Chile

The registration process in Chile is handled through the national REP platform. The practical steps are:

1. Confirm that the company is the REP producer for packaged goods in Chile
2. Register the company’s main establishment in Ventanilla Única del RETC
3. Ensure the responsible person has a RUT and Clave Única
4. Submit a request for the sectoral REP producer system
5. Select the relevant priority product categories and subcategories for packaging
6. Wait for review by the Ministry of the Environment
7. Once enabled, use the REP producer profile to access annual reporting and download the proof of registration

The official 2025 instructions make clear that only one establishment, typically the casa matriz or principal establishment, should represent the company for REP producer registration.

Authorized Representative

Chile’s packaging REP framework does not operate with a standard foreign-producer authorized representative model similar to several EU jurisdictions. Instead, the system is structured around a Chilean registered producer profile using RUT, Clave Única, and a registered principal establishment in the REP portal.

For foreign companies, this usually means compliance is handled through:

1. A Chilean subsidiary
2. A local importer that is the REP producer
3. Another local legal entity that is actually introducing the packaged product into the Chilean market

So while Chile does not clearly require an “authorized representative” by that name for packaging, foreign companies generally need a Chilean legal and administrative footprint to register and report in practice.

What Data Must Be Reported

The REP producer system requires annual reporting on the priority products placed on the market. The producer profile in the REP system includes an Informe Anual for products placed on the market during the calendar year.

For packaging, businesses should be prepared to report at least:

1. Packaging quantities placed on the market
2. Material category
3. Household versus non-household classification
4. Relevant packaging subcategory
5. Whether packaging is reusable or non-reusable where applicable
6. Data supporting compliance through the relevant management system

Because Chile’s targets are built around material categories and household/non-household streams, data mapping at SKU or packaging-component level is important from the start.

First Reporting Period & EPR Reporting Deadlines

Chile’s packaging targets under DS No. 12/2020 began on 16 September 2023. Since then, producers in scope must be affiliated with a management system and comply with the associated obligations.

Chile also operates annual information requests through the REP system. In the 2025 reporting cycle, the Ministry of the Environment opened the information request for REP-regulated producers through Resolution No. 4771 of 15 July 2025, with the filing window running until 15 September 2025 for data relating to 2024 commercialization.

In practice, companies should distinguish between:

1. The date on which packaging REP obligations became effective: 16 September 2023
2. The annual producer information-reporting cycle through RETC/Ventanilla Única
3. Separate contractual or periodic reporting requirements imposed by the management system the producer joins

Labels & Marketing Claims

Chile’s packaging REP regime does not currently impose a general nationwide mandatory consumer sorting label for all packaging under DS No. 12/2020. The decree focuses primarily on targets, management systems, actor obligations, and operational compliance rather than a universal packaging-marking regime.

That said, producers should still treat on-pack environmental claims with caution. If recyclability, reusability or sustainability claims are used, they should be supportable and consistent with the packaging’s actual management route in Chile. This is especially relevant because the REP system is built around real collection and recovery performance by material and stream.

EPR Eco Fees & Eco-Modulation

Chile’s law requires producers to organize and finance waste management, but the state framework does not publish a single national packaging fee table in the same way as some European producer registers. In practice, the cost burden is implemented through the producer’s chosen management system, which finances the collection and recovery obligations needed to meet the REP targets.

This means packaging fees in Chile are generally operationalized through scheme participation and the producer’s packaging portfolio rather than through a simple statutory national tariff published in the decree itself. Public official sources confirm the obligation to finance the system, but detailed fee schedules are generally managed at scheme level.

Chile’s current official framework also does not clearly set out a mature nationwide eco-modulation model in the packaging decree comparable to the highly granular bonus-malus systems used in some EU countries. Businesses should nevertheless expect packaging material mix and household/non-household classification to affect cost exposure through scheme membership.

Risks, Penalties & Common Mistakes

Common compliance mistakes in Chile include:

1. Assuming cross-border e-commerce is outside scope
2. Misidentifying the Chilean producer where a brand owner, importer and distributor are all involved
3. Failing to register in RETC/Ventanilla Única before relying on a management system
4. Ignoring household versus non-household packaging classification
5. Reporting only primary packaging and omitting secondary or tertiary packaging
6. Treating microenterprise status as a generic foreign-seller exemption when the legal test is specific under Chilean law

Enforcement powers sit with the Superintendence of the Environment (Superintendencia del Medio Ambiente). Law No. 20.920 states that sanctions can include written warnings and fines of up to 10,000 UTA.

What E-Commerce Sellers Should Do Now

1. Determine which entity is legally introducing the packaged good into the Chilean market.
2. Check whether the relevant Chilean entity qualifies as a microenterprise under Law No. 20.416.
3. Build a packaging data file by material and by household/non-household stream.
4. Register the producer in Ventanilla Única del RETC using the principal establishment.
5. Join an appropriate packaging management system to cover REP targets.
6. Prepare for annual REP reporting through the Ministry’s producer reporting process.
7. Review online-sales structures so the importer, own-brand seller, and local entity roles are legally aligned.

FAQ

• Yes. Packaging EPR is mandatory under Law No. 20.920 and DS No. 12/2020, and the packaging targets started applying on 16 September 2023.

• Potentially yes. If the foreign business, its Chilean affiliate, or its importer is the entity introducing the packaged product into the Chilean market, REP obligations can apply.

• There is no general turnover or tonnage threshold for packaging REP like in many EU systems. The main recognized exemption is for microenterprises under Law No. 20.416.

• Chile does not currently have a general mandatory REP disposal label for all packaging under DS No. 12/2020. Producers should still ensure that any environmental claims are accurate and supportable.

• Not automatically. Liability follows the statutory producer definition and who introduces the packaged product into the Chilean market, not marketplace status alone.