Legally compliant packaging licensing throughout Europe

At the end of November 2022, the EU presented the draft Packaging & Packaging Waste Regulation - PPWR - which regulates the rules for packaging and its disposal in the member states of the European Union. The EU Packaging Regulation is binding for companies based in an EU country as well as companies importing packaging into the EU and applies to both domestic and imported products. Read the most important facts about the PPWR here.

As an “initial distributor” (or importer) in the respective country, the national packaging laws and regulations for that country will require you to participate in a system that handles the correct collection, sorting and recycling of your packaging. All of your quantities must be registered and licensed accordingly. 

The fees for packaging licensing differ from country to country, and are primarily based on the type of packaging (domestic or commercial packaging) and the quantity of packaging to be licensed. The price also reflects the type of material involved: paper, paperboard and cardboard (PPC) is much less expensive than plastic per kg, for example.

Practice differs from country to country in Europe. Some countries do apply quantity thresholds or other kinds of de minimis limits and requirements. As a result, you may be partially or wholly exempt from licensing if you do not exceed the quantity threshold or meet the requirements.

So far, these European countries have passed legislation requiring packaging labelling: Typically, labelling legislation only affects packaging that is supplied to private consumers. One exception is Italy, where packaging supplied to commercial consumers must also be labelled in accordance with legal requirements. 

Bulgaria: The use of Mobius loop and the so-called "tidy man" is voluntary, the indication of the alphanumeric code is mandatory

France: Triman logo consisting of the “Triman”, the packaging and disposal pictogram

Italy: Mobius loop with alphanumeric code and the “tidy man” Packaging destined for private households (B2C) must be labelled with information about separate waste collection provided in Italian.

Romania: The indication of the alphanumeric code is mandatory. It needs to be applied directly to the packaging (+ add. packaging parts) or the label and must be visible, readable and permanent even when the packaging has been opened.

Spain: From 1 January 2025, new labelling requirements will come into force for packaging that is generated as waste by end consumers in private households. With Royal Decree 1055/2022, this labelling of packaging will become a legal obligation for manufacturers and distributors.

We will be happy to advise you in detail on your corresponding labelling duties and discuss how your packaging should be printed to ensure compliance.

In Portugal, Spain, Greece, Hungary, Slovenia and Austria, companies without a registered office in these countries need to appoint an authorised representative tasked with taking care of their licensing obligations. We can also handle the appointment of your authorised representative.

In France and Austria, marketplaces such as Amazon are subject to certain legal requirements that make increased verification of sellers necessary. The EPR number plays a central role in this. This number serves as proof that the seller fulfils their legal obligations with regard to recycling and environmental protection.

The obligation to provide evidence aims to ensure that products are properly recycled and disposed of in an environmentally friendly manner. By verifying the EPR number, marketplaces ensure that their sellers comply with environmental regulations and thus promote sustainable trade.

For online retailers, this means that they must prove their environmental responsibility in order to be active on these marketplaces. The EPR number is therefore not only a regulatory requirement, but also a tool to raise awareness of environmental protection in e-commerce.

Strictly speaking, it is not a tax, but a method of calculating contributions from the member states. Countries that produce a lot of packaging waste have to pay more than those that produce less non-recycled plastic.

By taxing non-recycled plastic, the aim is to incentivise people to use less plastic and switch to more sustainable alternatives. 

So far, the UK, Spain and Portugal have introduced the plastic tax and are therefore obliging companies to pay the tax.

Germany and Italy have announced their intention to introduce a plastic tax. In Germany, it was planned that the tax would have to be paid by manufacturers and importers from 2024. However, the introduction has been postponed until 1 January 2025 earliest. Italy was already planning to introduce the plastic tax in 2023, but has postponed it indefinitely.