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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
In addition,
  • 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.

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.

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.

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.

You require additional details?​

Free consultation call

We offer you a free consultation call to give you an overview of your obligations and provide you with a non-binding offer for our services with full cost transparency to simplify your decision-making process.

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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