If your business is actively trading in the European Union, you will be aware of the various Extended Producer Responsibility (EPR) Regulations currently enforced across the bloc.  Most prominently, Packaging EPR remains one of the most prominent categories that businesses to comply with.  

Despite widespread enforcement across the EU, for years, businesses have had to navigate a complex mix of national labelling laws. 

For example, implementing the ‘Triman’ logo and ‘Info-tri’ labelling system in France whilst complying specific environmental codes in Italy, and conforming with other unique regional requirements has often meant designing multiple packaging variations or overcrowding product packaging with various different symbols for different markets.

Fortunately, the regulatory landscape is set to become much clearer. 

The EU has officially introduced the new Packaging and Packaging Waste Regulation (PPWR), which entered 11 February 2025 and seeks to create a single, unified set of rules for all Member States.  These unified rules will eventually replace the fragmented national systems currently in place throughout the EU. 

Standardised labelling to be introduced 

The primary objective of the new regulation is to eliminate consumer confusion and improve recycling rates.

To achieve this, a new unified visual labelling system will be introduced based on the composition of materials, rather than the product end-of-life disposal process.  The new system will rely on standardised icons representing different materials that are easy to recognise and understand across the EU.  

These icons will identify specific materials, such as different grades of plastics, paper, metal, and glass. They are also designed to match the symbols and colours used on local recycling bins throughout the EU. This ensures consumers know exactly how to dispose of their packaging properly, regardless of which country they are in.

To help keep physical packaging artwork uncluttered, the new rules also strongly encourage the use of streamlined digital data labels such as QR codes.  A quick scan can then provide consumers with the relevant multilingual disposal instructions without compromising packaging design or taking up valuable space on smaller items.

Updated rules on multi-component products

The new rules will be highly specific when it comes to products that use a mix of materials, such as a sturdy cardboard box containing a protective plastic bag and a paper insert. 

Under the PPWR, it will no longer be possible to use a single, generic recycling logo to represent the entire complex package.  Instead, each easily separable component requires its own specific label to ensure it ends up in the correct waste stream.  

However, for practical reasons, it will be permitted to group these labels on the outermost layer of the packaging. The requirement is that the consolidated design clearly indicates which symbol applies to specific parts of the packaging (e.g. outer vs. inner packaging etc.) ensuring that the sorting process is entirely clear for the consumer.

Additionally, regulations on which types of materials can be used for packaging will become stricter – ‘forever’ chemicals (PFAS) are set to be banned under the PPWR from August 2026. 

Transition period

We are currently in a transition period, with the new mandatory labelling rules are scheduled to apply from mid-2028.  

In addition to updated labelling requirements, many businesses will also face updated requirements for registration and reporting, such as the introduction of Authorised Representative requirements and new material reporting obligations.  

The transition period provides businesses with an opportunity to review their packaging inventory and prepare for the necessary updates. Early preparation is highly recommended to avoid bottlenecks as the deadline approaches.  Understanding how these new regulations might affect your business can seem daunting. 

That is where TBA Global steps in to guide you. 

We are an experienced team specialising in comprehensive compliance services across the European Union. With a thorough understanding of environmental legislation, we are perfectly positioned to help your business transition smoothly and successfully.  Some of the rules under the PPWR may also undergo further changes prior to implementation – we’re here to ensure that you can stay on top of everything. 

We provide full-service packaging advisory and registration support, with specific expertise in major markets including Belgium, France, Germany, Ireland, Italy, the Netherlands, Poland, Spain, and Sweden.

As implementation progresses, taking proactive steps now will prevent future disruption to your business and protect your brand reputation. Let our team handle the regulatory complexities and allow you to focus on expanding your business.

Reference：
https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en
https://publications.jrc.ec.europa.eu/repository/handle/JRC141706?mode=full