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From 2025, a large number of new regulations will come into force in Europe that will pose major challenges for companies, particularly manufacturers and producers. From stricter sustainability requirements to extended responsibility for products and innovative reporting obligations, the upcoming changes are aimed at further raising environmental and social standards while strengthening competitiveness.
Start now with our Quick check questionnaire to get an overview of your company’s EPR obligations in Germany, France, Spain and Austria.
Adoption of the Packaging and Packaging Waste Regulations (PPWR) in the European Parliament?
The European Union continues to forge ahead with its ambitious strategy to promote a circular economy. A central component of these efforts is the Packaging and Packaging Waste Regulation (PPWR), which aims to drastically reduce packaging waste, increase recycling rates and accelerate the transition to more sustainable packaging solutions. This regulation has the potential to impact businesses, consumers and the environment alike, and sets a new benchmark for the packaging industry in Europe.
Approval of the European Parliament
On 26 November 2024, the final version of the Regulation on Packaging and Packaging Waste (PPWR) was orally presented at the plenary session of the European Parliament. As part of the corrigendum procedure, corrections to the version provisionally adopted in April 2024 were automatically adopted because no objections were raised within 24 hours of publication. As a result, the PPWR tacitly received the consent of the European Parliament on 27 November 2024.
Wide-ranging impact: new packaging regulations apply to manufacturers, importers and retailers
The new regulation affects all economic operators that work with packaging in the European Union. These include, in particular, manufacturers, importers and distributors.
After the Council’s approval, the final version will be published in the Official Journal of the European Union. The regulation will enter into force 20 days after this publication and will be applicable 18 months later.
Read more about the PPWR, its requirements and objectives here.
France asked to bring labelling rules into line with free movement of goods rules
On 14 November 2024, the European Commission decided to send a reasoned opinion to France as part of infringement proceedings that have been ongoing since February 2023. The Commission considers that the current French labelling rules, i.e. the Triman logo with sorting information, are incompatible with the principle of the free movement of goods in the EU. It regards these requirements as an unnecessary barrier to trade that could affect the free flow of goods in the single market.
France under pressure: the impact of the EU statement on packaging manufacturers and distributors
The regulations affect companies that bring packaging onto the French market for the first time and that subsequently accumulates as waste in private households, such as primary and, to some extent, secondary packaging. Producers of goods destined for the French market could also be indirectly affected. France now has two months to respond to the European Commission’s statement and take appropriate action. Otherwise, the Commission could refer the matter to the European Court of Justice.
France postpones planned polystyrene ban from 2025 to 2030
The French government announced on 28 September 2024 that it would postpone the planned ban on non-recyclable polystyrene packaging, originally scheduled for 1 January 2025, to 2030. This decision has been taken to align the regulations with the upcoming European Packaging and Packaging Waste Regulation (PPWR). The ban will not take effect until the new EU recyclable design criteria come into force, which classify packaging into recycling classes (A, B or C). These criteria are to be established by 2028, giving manufacturers more time to adapt their packaging.
The regulation affects all companies planning to offer non-recyclable polystyrene packaging on the French market. However, its implementation requires the passing of a corresponding law.
Read more about EPR obligations in France here.
New minimum standard in Germany from 2025: Changes to the recyclability of packaging
On 29 August 2024, the Central Packaging Register Office (ZSVR) published the revised minimum standard for the recyclability of packaging subject to system participation requirements. The most important changes include:
- New validity: the standard applies from 1 January of the following year instead of from 1 September of the year of publication.
- Liquid cartons: individual proof of plastic and aluminium components is no longer mandatory, but recommended, thanks to increased recycling capacities.
- Flexible PE films: The differentiation by size has been removed; all PE films are assessed uniformly, including the incompatibility of certain printing inks.
- Separate assessment: Packaging components are assessed individually to more accurately capture the recyclability of complex packaging.
- Clear structure: Standardised material designations and a clearer structure make it easier to use.
Outlook: minimum standard to be aligned with upcoming EU requirements
The minimum standard is revised annually. For the new version, which is expected to be published at the end of August 2025, a further alignment with the provisions of the EU Packaging and Packaging Waste Directive (PPWR) has already been announced (provided that it has come into force by then).
Since recycling is becoming increasingly important and will be mandatory with the upcoming PPWR from 2030, companies should check the recyclability of their packaging today to be well prepared. The requirements of the minimum standard already provide a good orientation for this.
Single-use plastic fund in Germany: mandatory registration for manufacturers starts on the DIVID platform
On 1 August 2024, the German Environment Agency announced that, with immediate effect, foreign manufacturers can also register on the DIVID single-use plastic fund platform. This implements an important step in the Single-Use Plastic Fund Act, which has been in force since 15 May 2023. The regulation affects all manufacturers of single-use plastic products, such as to-go containers, tobacco filters and other single-use plastic items, whether they are domestic or foreign.
Manufacturers that were already operating before 1 January 2024 must register by 31 December 2024 at the latest. For new manufacturers, the registration requirement applies from the moment they start operating. From 2025, all manufacturers are required to report the quantities of single-use plastic products they have sold via DIVID.
What does this mean? All producers of single-use plastic products must register with DIVID and report the quantities of their products sold from 2025 onwards.
Read all about the packaging obligation in Germany here.
New labelling requirements for packaging in Spain: What companies need to know
Since the Spanish Packaging Law of December 2022, sorting instructions on packaging have been mandatory. Companies can decide for themselves how to implement these instructions. Organisations such as Procircular provide free symbols that can be used for the correct separation of packaging. A manual explains how the symbols may be used.
All companies that sell packaged products to private final consumers from 1 January 2025 are affected by the new labelling requirements. Until the end of 2024, sorting instructions are voluntary. From 1 January 2025, they are mandatory on all packaging concerned. The instruction must show how the packaging should be disposed of correctly.
Read more about labelling requirements in Spain here. Do you need an authorised representative in Spain? Read more about the requirement to appoint an authorised representative for Spain here.
New penalty rules in the Austrian Waste Management Act (AWG): Changes for companies in Austria
On 17 July 2024, new rules were published in the Austrian Waste Management Act (AWG). The most important changes:
- Penalties will only be calculated from 5% too little reporting on the total costs, no longer on individual categories. This prevents companies from having to pay penalties despite credit notes.
- The regulation now also applies to littering costs (SUP reports).
- Penalties are only due from 50 euros.
All companies that sell packaging in Austria and participate in the system of extended producer responsibility. The new rules have been in force since 18 July 2024. They affect audits for 2024 and all subsequent years.
Deposit system for single-use beverage containers in Austria: the most important information at a glance
The deposit regulation for single-use beverage containers has been in force in Austria since 26 September 2023. The aim of the deposit system is a collection rate of 80% by 2025, rising to 90% by 2027.
From 1 January 2025, the following will apply:
- Mandatory deposit: for plastic and metal beverage containers holding between 0.1 and 3.0 litres (except for milk and milk products).
- Deposit amount: a standard 0.25 euros per container, regardless of material or size.
- Labelling: all containers must be labelled with an EAN code or GTIN deposit symbol.
The organisation is carried out by EWP Recycling Pfand Österreich GmbH, a non-profit central office that manages logistics, recycling and cash flows. Producers finance the system through eco-modulated fees that take into account the recyclability of the packaging.
Obligations of initial distributors
All producers and importers of single-use beverage containers who sell their products in Austria must register with Recycling Pfand Österreich. Registration is required for the collection of the legally prescribed producer contributions. Every beverage in a non-returnable plastic bottle or can must be registered with Recycling Pfand Österreich so that it can be recognised by reverse vending machines and manual return points in the future.
Take-back obligation
Points of sale must take back empty packaging. Exceptions apply to restaurants and highly frequented locations where alternative return points are possible. (Special rules for sales via vending machines, online retailers and food delivery services: operators of vending machines do not have to take back the containers, but instead pay a compensatory fee for each container).
Transitional arrangement
Products filled before 1 April 2025 may be sold without a deposit until the end of 2025.
Read more about the deposit system for single-use beverage containers in Austria here.
Circular Pro Account – get started now!
Create a free Circular Pro Account today and, find out your which countries your company has EPR obligations. Follow the sign-up steps and get started. Get your free Circular Pro Account here.