EU Packaging Regulation: opportunities and challenges for economic operators

On Wednesday, November 27, 2024, the European Parliament finally adopted the linguistically and legally revised version of the EU Packaging Regulation (corrigendum). The only thing missing now is the approval of the Council of the European Union, but this can probably be expected by the beginning of 2025. Even though the regulation will come into force shortly afterwards, its application will not begin until 18 months later, and individual regulations will not even come into force until several years later. This leaves time for implementation.

The EU Packaging Regulation is one of the most comprehensive reforms in the area of packaging and the circular economy. The aim of the regulation is to reduce packaging waste, increase recycling rates and – this is often omitted – promote the use of reusable packaging. These measures are a decisive step towards a sustainable economy – but they also present new challenges for economic players. At the same time, they offer innovative opportunities to optimize operational processes and secure competitive advantages.

Obligations for economic operators

Economic operators who place packaging on the market are faced with a number of obligations:

1) Implementation of reuse systems

Companies must establish systems or participate in existing systems in order to keep reusable packaging efficiently in circulation. This applies in particular to transport and sales packaging such as pallets, crates and containers.

2) Recyclability of the packaging

All packaging used must be recyclable, i.e. it must be compatible with the recycling infrastructure in the EU. The regulation also prohibits the use of problematic substances such as heavy metals.

3) Reporting obligations

Regular reports on packaging quantities, types and materials are mandatory. Companies must also provide evidence of the recycling and reuse rates achieved and their participation in extended producer responsibility (EPR) systems.

4) Promotion of sustainability

Companies should minimize the use of disposable packaging and increasingly rely on environmentally friendly reusable solutions.

5) Financial participation

Contributions to the collection, sorting and recycling of packaging waste must be made as part of the EPR systems.

Possible advantages of implementation

Cost savings, increased efficiency, market advantages, legal certainty

These requirements go hand in hand with a considerable conversion effort, but this can pay off in the long term. Companies that invest in reusable packaging systems and innovative technologies such as IoT tracking benefit from efficiency gains and cost savings. By tracking packaging in real time, losses can be minimized and logistics processes optimized. In addition, the automated collection of relevant data makes it easier to fulfill reporting obligations, which reduces the administrative burden.

The implementation of the regulation also offers the opportunity to position oneself as a pioneer in terms of sustainability. Customers increasingly value environmentally friendly solutions, and the introduction of reusable packaging can strengthen the brand image and tap into new target groups. At the same time, compliance with the legal requirements means increased legal certainty and protects companies from potential sanctions.

Challenges and risks

Investment costs, complexity in logistics, reporting obligations

Nevertheless, the challenges should not be underestimated. The development of new systems and the integration of tracking technologies require high initial investments. The complexity of logistics and ensuring sufficient availability of reusable packaging also pose challenges for companies. In addition, extensive reporting requires precise planning and management, especially for internationally active companies that are confronted with different regulatory requirements in the member states.