Packaging regulations: Compliance and legal requirements for packaging 

Increasingly stringent packaging regulations require companies in the European Union to take responsibility for the disposal and recycling of their packaging. If manufacturers, importers and online retailers want to continue offering sustainable and EPR-compliant packaging (EPR = Extended Producer Responsibility) to comply with legal requirements, they face complex challenges. 

Compliance with these regulations varies from one EU Member State to another. Some countries have already established comprehensive systems for packaging licences, labelling requirements and recycling quotas. In other markets, the new rules are only being phased in as part of the planned Packaging and Packaging Waste Regulation (PPWR). 

Anyone who places packaging on the market in Europe or distributes certain products in other EPR categories, such as single-use plastics (SUP), batteries or waste electrical and electronic equipment (WEEE), must therefore not only be familiar with national requirements, but also keep an eye on future developments. Incorrect implementation of the applicable regulations can result in heavy fines, sales bans or damage to your image. 

In this article, you will learn: 

• the differences between the packaging laws in the EU, 
• how to stay up to date on new packaging regulations, compliance and legal requirements for packaging, 
• which labelling requirements are particularly relevant in e-commerce, 
• and when an authorised representative is necessary to correctly fulfil your EPR obligations in Europe. 

We will also use specific examples from Germany, Austria, France and Spain to show you how to design your packaging in a sustainable and legally compliant manner – and what the new PPWR will mean for your compliance strategy in the future. 

How does packaging waste legislation differ between the EU member states? 

Each EU member state has its own packaging waste legislation, which is based on the European Packaging and Packaging Waste Directive but is implemented differently at the national level. This diversity of packaging regulations means that companies must meet different requirements in terms of registration, recycling quotas, licensing and labelling, depending on their target market. There is not (yet) a one-size-fits-all solution for all markets – instead, companies must adapt individually to the respective legal framework. In the future, the PPWR will ensure harmonisation, but it will take some time before this happens. 

For companies that sell products in several EU countries, this means a considerable amount of additional organisational work. While the German Packaging Act (VerpackG) requires mandatory registration in the LUCID packaging register and participation in a dual system, France has additional requirements such as the Triman logo for consumer information. Spain and Austria, on the other hand, require separate notifications and, in some cases, the appointment of an authorised representative. To avoid legal risks such as fines or sales bans, it is therefore crucial to be familiar with the packaging regulations applicable in each market and to stay up to date. 

How can you stay informed about upcoming changes and updates in sustainable packaging regulations? 

Sustainable packaging regulations are evolving rapidly in Europe and presenting companies with new challenges in complying with national and European regulations. Every national packaging regulation is continuously updated to meet increasing environmental and recycling standards. In particular, the planned Packaging and Packaging Waste Regulation (PPWR) is intended to create uniform requirements and significantly strengthen the sustainability of packaging across the EU. 

To stay up to date with these developments, an active information strategy is recommended. Companies should regularly follow announcements from the authorities, subscribe to updates from PROs (product responsibility organisations) and use specialised platforms for packaging law and EPR compliance. Only early information enables necessary adjustments to be made in good time and regulatory risks to be minimised. 

Tip: Sign up now for our newsletter to receive important updates on sustainable packaging regulations, new packaging laws and EPR obligations directly in your email inbox! 

What are the packaging labelling requirements for eCommerce businesses? 

Packaging labelling requirements are an essential part of the regulatory requirements that companies in e-commerce must comply with. Every national packaging legislation prescribes certain symbols, recycling instructions or consumer information that must be displayed on packaging. In markets such as France (Triman logo) and Italy (material labelling according to UNI standards), in particular, there are very strict regulations that change regularly and require precise knowledge. 

Online retailers who sell their products across borders must ensure that their packaging complies with local requirements in each target market. Failure to comply with packaging labelling requirements can not only result in heavy fines but also undermine consumer confidence. Careful planning and legally compliant design of labels and symbols are therefore essential for a successful and sustainable market presence. 

Tip: Our Labelling Essential Kit helps you to implement all important labelling requirements quickly and in a legally compliant manner. Discover it now and prepare your packaging optimally for the legal requirements! 

What is packaging compliance? Overview of packaging waste laws in the EU and their local markets 

Packaging compliance in the EU is an essential part of extended producer responsibility (EPR), which obliges companies to take responsibility for the collection, recovery and recycling of their packaging. This obligation applies equally to manufacturers, distributors and importers and is enshrined in law in every EU member state – albeit with different requirements and implementations in the respective packaging waste legislation. 

Basically, EPR compliance means that companies must register their packaging quantities with the relevant authorities or PROs (product responsibility organisations), pay disposal fees and submit regular reports on the packaging they place on the market. Depending on the country, additional obligations such as special labelling, participation in take-back systems or the provision of consumer information may also be required. Fulfilling these packaging compliance regulations is a prerequisite for avoiding sanctions and ensuring market access in the respective countries. 

Packaging compliance regulations: Which local PROs support your compliance journey? 

Packaging compliance regulations present companies in Europe with the challenge of implementing complex legal requirements in different markets in a legally compliant manner. So-called PROs (product responsibility organisations) are central points of contact for registration, licensing and quantity reporting. Each PRO is responsible for a specific country and acts as an interface between companies and waste disposal systems – with individual requirements and processes that can vary significantly depending on national packaging regulation. 

At Circular Pro, we work with experienced partners who offer companies reliable support in implementing their obligations. In Germany and Austria, Reclay guides companies through the entire EPR process. In France, this role is performed by Leko, while in Spain, Procircular is available as a competent point of contact. These organisations not only provide support with legally compliant registration, but also advise on quantity reporting, licence fees and other legal requirements. Working with established PROs makes compliance with national packaging regulations much easier and more transparent. 

Packaging Licensing for businesses in various countries (Germany, France, Spain) 

Packaging licensing is a basic requirement in many European countries for placing packaging on the market in compliance with the law. Companies are obliged to register with an approved system operator or product responsibility organisation (PRO), report their packaging quantities on time and pay the corresponding licence fees. The requirements for packaging licensing vary depending on the country and the respective packaging law. 

In Germany, the Packaging Act (VerpackG) requires registration in the central packaging register LUCID and participation in a dual system. In France, companies must register with a recognised system such as Leko and affix national symbols such as the Triman logo to their packaging. In addition to licensing with organisations such as Procircular, Spain often requires companies that are not based in the country to appoint a local representative. Those who are familiar with the national requirements and obtain correct packaging licensing can minimise legal risks and offer their products safely on the respective markets. 

Tip: Find out now how you can register easily and legally compliantly in Germany, France, Spain and other EU countries with the right Packaging License from Circular Pro! 

The role of an authorised representative for companies without a physical presence in the country 

An authorised representative is essential for companies without their own registered office in an EU member state to properly fulfil their EPR obligations. According to the applicable packaging waste regulations, manufacturers and distributors who sell goods on European markets must appoint a local representative in many countries. This authorised representative assumes responsibility for registering with the relevant authorities, licensing the packaging and complying with reporting and payment obligations on behalf of the company. 

The tasks of an authorised representative typically include monitoring reporting obligations, communicating with local PROs and authorities, and ensuring that all legal requirements in the respective country are correctly fulfilled. In countries such as France, Spain and Austria in particular, appointing an authorised representative for foreign companies is a necessary step to secure market access and avoid fines or distribution bans. Legally compliant representation by an experienced partner makes EPR compliance much easier and ensures transparency throughout the entire licensing process. 

When is it mandatory to appoint an authorised representative EU for your products or services? 

An authorised representative in the EU is always required by law when companies without their own registered office in a Member State place packaging on the market there. This obligation arises from national packaging regulation and is further harmonised by new European regulations such as the planned Packaging and Packaging Waste Regulation (PPWR). The aim is to ensure that foreign suppliers also fulfil their packaging responsibilities properly. 

In France, for example, the obligation to appoint an authorised representative has been in place since 2022 for all companies engaged in distance selling. Spain also requires a local representative if the company does not have a registered office in the country. In Austria, too, companies without a branch must appoint an authorised representative to comply with national packaging regulations. Companies should therefore check at an early stage whether their distribution structure requires authorisation to avoid fines or sales bans. 

What are the objectives of the PPWR and the challenges for European authorised representative? 

The planned EU regulation on packaging and packaging waste (Packaging and Packaging Waste Regulation – PPWR) will also bring new requirements and responsibilities for authorised representatives in the EU. The regulation aims to make packaging more sustainable, increase reuse rates and improve recyclability across Europe. At the same time, uniform regulations are to be created to replace special national solutions and more clearly define the role of authorised representatives. 

The PPWR is expected to impose more comprehensive reporting obligations on authorised representatives in future – for example, on the environmental impact of packaging, the proportion of recycled materials or compliance with design requirements for recyclability. Responsibility for the correct implementation of packaging labelling requirements and compliance with new minimum requirements could also be shifted more towards authorised representatives. Companies should therefore prepare for these changes at an early stage and ensure that their authorised representatives have the necessary expertise and infrastructure to efficiently fulfil their future obligations. 

Tip: In our blog post ‘The objectives of the PPWR and the challenges for authorised representatives in Europe’, you can find out all the details about the upcoming changes – find out now and be prepared! 

Conclusion: Successfully implement packaging regulations and seize opportunities 

Compliance with European packaging regulations is more important than ever for companies today. Whether it’s registration, licensing or labelling, anyone who wants to operate successfully in EU markets must be familiar with national requirements, keep an eye on developments such as the PPWR and, if necessary, seek the support of experienced partners. In many countries, appointing a suitable authorised representative is becoming a key requirement for complying with the law and remaining competitive in the long term. 

With early preparation and a clear strategy, companies can master the challenges of complex packaging regulations and actively contribute to a more sustainable circular economy. Circular Pro supports you in implementing your compliance efficiently and in a legally compliant manner – today and in the future.