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Packaging compliance
Your One-Stop-Shop Solution for the 27 EU Member States,
Switzerland, Norway and UK
The Packaging regulation
What is it?
The new packaging regulation voted on in 2024 aims to reduce the steadily increasing amount of packaging waste, stimulate circular economy and protect human health.
Why packaging compliance?
If you manufacture, sell or import packaging or packed products on the European market, you must comply with the European Packaging Directive.
The Packaging and Waste Packaging Directive (94/62/EG) setted out regulations for putting packaging and waste packaging on the market, both for collection, recycling and disposal. As a producer or distributor of packaging or packed products, you had to comply with this directive.
By the end of 2024, the European legislators voted on the new Packaging and Packaging Waste Regulation (PPWR) that will significantly change the requirements on PACK over the coming years.
While the packaging directive sets a common framework, specific requirements vary by EU member state, which forces producers and distributors to manage compliance processes individually per country. Although the new European legislation is not a directive anymore, but has been published as regulation, we still need to expect a variety of country specific requirements also in the future.
Who is considered a producer?
The term “producer” encompasses manufacturers, importers, and retailers who sell packed products or packaging. It is not always the case that the manufacturer of a packaging is considered the “packaging producer” in a given member state. In order to ascertain the identity of the Packaging obligation in each market, it is essential to conduct an analysis of the organisation’s sales structure and business entities.
We support you in selling your products...
...while being in compliance with the law across the whole European market with a One-Stop-Shop approach.
Our packaging experts will provide guidance throughout the process, ensuring the accuracy of your packaging data and compliance with all relevant regulations.
The EU Packaging Regulation
General Packaging responsibilities across the EU 27, Switzerland, Norway and the UK
Registration
As a producer, many countries in Europe will oblige you to register with the national PACK authorities. Without being registered, the Put on Market in a country is not permitted and may be subject to penalties.
Financing Take-Back
Producers are obliged to finance the collection and recycling of packaging material. You can do this by setting up your own take-back solution or by joining a collective scheme. We cooperate with the leading collective Producer Responsibility Organisations (PROs) in each market.
Information obligations and other requirements for producers
The new packaging regulation requires to provide a large variety of information about the packaging, including
- a label about the material composition to simplify sorting for end users
- re-usable packaging material must be classified and labelled as such, additional information needs to be provided digitally
- information about the %-value of recycled material the packaging is made of
- producers are obliged to avoid unnecessary packaging
- it must be possible to recycle all packaging material in the future
- some types of packaging will not be allowed anymore (e.g. certain single use plastic material)
Reporting
Producers must regularly report the volumes (in kg) of packaging material placed on the market in each country. Based on this reporting, the PROs will charge you with the recycling fees. In addition, they usually also take care of the reporting towards the national authorities.
Blog
To get a first overview of your producer obligations have a look at these articles regarding everything you need to know about PACKAGING compliance.
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Practical Steps to Compliance
How do you comply with the Packaging Regulation?
Assess your producer status by country
Depending on your organisational structure and the sales channels you are operating in, you may be considered producer in a country with subsequent obligations or alternatively can fulfil such producer obligations voluntarily on behalf of your clients. When fulfilling producer obligations in countries where you are not represented with an own legal entity, legislation in most of these countries requires you to appoint a so called Authorised Representative (AR). We provide you with the necessary solutions, either through our PROs who offer this kind of service themselves or through external service providers with extensive knowledge on the topic. Our first step in leading you to compliance is the detailed assessment of your individual situation with a detailed overview of obligations, fixed and variable costs and ongoing tasks you need to fulfil. You receive the information you need, while we make sure that we arrange for everything you need during the contract phase.
Join a PRO to finance collection and recycling
In each country we work with our network of market leading Producer Responsibility Organisations (PROs) to ensure you fulfil your compliance obligations. We will set up the necessary contracts between you and the PROs in each country and coordinate the process of signing and transmission by country. This is why we will ask for detailed company information as well as some additional documents or other details from you.
Report the amount of packaging placed on the market
When being registered, and in case the volume of PACK material put on the market in a country exceeds any existing threshold, one of your main producer obligations is the regular reporting of the quantities placed on the market in each of your relevant countries.
In order to do so, a differentiation is required if packaging is considered primary, secondary or tertiary packaging and into which (sub-) category the material needs to be reported
To simplify this, PRONEXA allows you to declare all of your packaging put on the market directly to us and therefore in one single place. We support you with the correct allocation of the PACK material and handle all the rest of reporting to PROs on your behalf. You will only need to pay the invoices that will be issued by the PROs based on your reports and can fulfil your obligation in an efficient and effortless way, while we ensure that you keep full control of your reported data during the whole process.
Make your products and sales documentation compliant
As a producer who places EPR (Extended Producer Responsibility)-affected products on the market in the European Union, you have several obligations in providing transparent information to end-users and other stakeholders. These obligations may include the following:
- Show registration number
- Labelling material composition
- Labelling recycling content
- Labelling on re-usability
PRONEXA proactively and comprehensively informs you about existing and upcoming new compliance topics in your countries of activity.
FAQs
and compliance guidance
Frequently asked questions clarify packaging definitions, obligations under EU directives and regulations, registration thresholds, cost variations, labelling rules, and consequences of non-compliance, emphasizing the need for businesses to assess and fulfill packaging compliance in each relevant market.
What is Packaging?
Packaging refers to all products made from any material, used for containing, protecting, handling, delivering, and presenting goods, from raw materials to processed products, from the producer to the user or consumer. Non-returnable items used for these purposes are also considered packaging.
What is considered to be Packaging that is placed on the market in Europe?
In Europe, packaging that is placed on the market (PoM) is defined by Directive 94/62/EC on packaging and packaging waste. This directive covers all packaging and packaging waste, regardless of the material used or the level at which it is used or released (industrial, commercial, office, shop, service, household, etc.).
What does the EU Packaging Directive say?
The EU Packaging Directive 94/62/EC, amended by Directive (EU) 2018/852, regulates packaging in EU member states. It aims to harmonise national measures for managing packaging waste, prevent its production, promote reuse, recycling, and minimise environmental impact. This directive sets recycling targets and quotas, placing responsibility on producers, importers, sellers, and online shops. Each member state must incorporate these regulations into their national laws, creating a complex situation for e-commerce businesses shipping to multiple European countries.
What is the “Packaging Regulation” (in short PPWR)?
The forthcoming Packaging and Packaging Waste Regulation in short PPWR (Regulation EU 2025/40) will replace EU Directive 94/62/EC. This regulation will standardise producer obligations across the EU, increasing the requirements for the collection, recyclability, and recycled content of packaging and packaging waste.
The PPWR will be valid and legally binding as a regulation in all EU Member States from 12 August 2026, without the need for transposition into national law. This ensures uniform application in all Member States.
What is the definition of Packaging?
Packaging is material used for the containment, transport, handling, protection, marketing or sale of an item. It also includes all packaging consumed on a business premises. The definition can be found Article 3 – 1. of the Packaging Directive.
Can the Packaging quantities that are placed on the market abroad simply be licensed by one declaration on a single market registration?
The quantities placed on the market must be licensed in every country. The business needs to register in each market if obligated by the country-specific packaging regulation. If you sell or distribute packaging or packed products abroad, you must check the packaging obligation criteria and thresholds in the respective country.
Do I need to register or license even for small quantities?
The regulatory framework varies from country to country. In some countries, there are so-called de minimis limits above which registration or licensing is required. It should be noted that in many countries, a licensing or registration obligation exists from the first gram. Consequently, even micro-distributors (businesses with small packaging quantities) are required to assess their packaging compliance based on sales distribution and their packaging quantities.
Are Packaging costs the same everywhere?
The calculation of contribution fees (compliance fees) varies not only between countries but also between packaging materials, due to differing criteria used by respective take-back systems, market collection costs, or the specific design of the packaging. In some countries, additional costs may be incurred for administration, registration, or authorisation. We will provide you with comprehensive and transparent information on this as part of our Service Agreements (service type: 1 Compliance Assessment).
What does "packaging license" or "packaging licensing" mean?
The German packaging law requires all producers and retailers, including online shops, to license their packaging with recycling schemes. This involves paying a fee, typically a few cents per kilogram, based on the type of material such as paper, plastic, wood or others. By paying these fees, producers finance the recycling of their packaging waste and are encouraged to reduce packaging.
Similar systems exist in other EU countries, though terms, institutions, fees, thresholds, and legal obligations vary. Consequently, online retailers offering EU or international shipping often struggle to manage their legal obligations and EPR. This is why we provide our Europe-wide compliance service.
As a small online shop, are we required to license our packaging?
In some countries, small companies have minimum thresholds or exemptions, but this is not the case everywhere. By using our service, PRONEXA will inform you if no action is required in a specific country. However, in many countries, even small companies have obligations from the first package shipped or by offering product shipments on their websites.
What is the difference between sales, grouped and transport packaging?
Sales packaging or primary packaging is designed to be a sales unit for the final user or consumer at the point of purchase.
Grouped packaging or secondary packaging is intended to group a certain number of sales units at the point of purchase, either sold as such to the final user or consumer or used to replenish shelves at the point of sale. It can be removed without affecting the product’s characteristics.
Transport packaging or tertiary packaging is designed to facilitate handling and transport of multiple sales units or grouped packaging, preventing physical handling and transport damage. Transport packaging does not include road, rail, ship, and air containers.
Is there a general labelling rule for packaging in Europe (TRIMAN, Green Dot, ...)?
Various EU member states have their own labelling requirements for recycling symbols, with no uniform system currently in place. These labelling requirements are primarily implemented to ensure regulatory compliance and to provide customers and consumers with the necessary information to sort their waste appropriately. The table below refers to packaging placed in household packaging.
| Country | Labelling requirement for |
|---|---|
| AUSTRIA | (x) |
| BELGIUM | (x) |
| BULGARIA | x |
| CROATIA | (x) |
| CYPRUS | (x) |
| CZECH REPUBLIC | (x) |
| DENMARK | (x) |
| ESTONIA | (x) |
| FINLAND | (x) |
| FRANCE | x |
| GERMANY | (x) |
| GREECE | (x) |
| HUNGARY | (x) |
| IRELAND | (x) |
| ITALY | x |
| LATVIA | (x) |
| LITHUANIA | (x) |
| LUXEMBOURG | (x) |
| MALTA | x |
| NETHERLANDS | (x) |
| NORWAY | (x) |
| POLAND | (x) |
| PORTUGAL | x |
| ROMANIA | (x) |
| SLOVAKIA | (x) |
| SLOVENIA | (x) |
| SPAIN | x |
| SWEDEN | (x) |
| SWITZERLAND | - |
| UNITED KINGDOM | (x) |
(x) Voluntary labelling x Mandatory labelling – No Packaging EPR
Household Packaging in Spain (ES), France (FR), and Italy (IT) must meet labelling requirements.
In France (FR), businesses must add a sorting notice with the TRIMAN logo and a sorting icon indicating how to dispose of the waste packaging. In Italy (IT), the labelling requirements depend on the intended user. Packaging materials must be labelled with an alphanumeric code, and consumer packaging must also include Italian waste collection information.
PRONEXA can consult your business on labelling and provide PRO sorting instructions if required.
Is there any obligation to use the ‘Green Dot’?
There is no obligation to use the ‘Green Dot’. Since 1 January 2023, it is no longer required to affix the ‘Green Dot’ in Spain either.
What happens if a company in a country does not fulfil its obligations and, for example, cannot show any registration evidence?
Local authorities are responsible for enforcing the packaging regulations. If a business fails to comply, they will be taken to court and prosecuted by the relevant local authority. Given these potential consequences, businesses must ensure they meet their obligations under these regulations. For example, a warning may be issued or a fine imposed, which can reach five figures. In the worst case, the company may be banned from selling its products in that country.
We take care of all the details, you benefit from our expertise
If you have packaging obligations in one or more countries and don’t have a compliance team with the respective know-how on dealing with the subject or the capacity to work on your EPR compliance, we recommend to use the support of our compliance experts. We’ll take you by the hand and lead you to compliance.
Detailed Assessment
We provide you with an in-depth analysis of your organisational status and product scope on a country by country basis, so you perfectly understand your obligations and are able to take the necessary actions. In addition, you will receive an overview on both the fixed and variable costs to expect in each country. Based on the results of the assessment we will take you along to the next step of contractual arrangements with our PRO network.
360° Full Service
We offer a unique combination of many years of expertise and experience in international EPR compliance within our team in Munich and a network of handpicked partner PROs and their teams in Europe to achieve our goal in providing best-in-class services in all the countries you need.
One Single Point of Contact
New developments in any of your relevant countries, questions about the invoice you received from one of our partner PROs or simply managing your reporting obligations in the variety of countries relevant for you: we support you with one compliance specialist as your dedicated contact point for all your questions and with our centralised and harmonised reporting platform you are able to manage your PoM Reporting - simple and quick.
A Partner network for the extra mile
We take your obligations serious - and are willing to go beyond the standard: We help you closing the loop by facilitating innovative recycling projects for circular business models.
Reporting Made easy
Meet our PRONEXA® Customer Data Management platform to comply with your reporting obligations
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