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EU gets down to business: EU regulation finally sets standards for environmentally friendly packaging!

On November 30, 2022, the EU Commission presented the draft for a new, EU-wide uniform packaging regulation. The guidelines are primarily aimed at comprehensively reducing the negative impact of packaging and packaging waste on the environment.
EU gets down to business: EU regulation finally sets standards for environmentally friendly packaging!

In the following, we summarize the most important points of the amendment and take a look at how packagings are currently changing and how they could possibly develop in the future.

Background to the new EU packaging regulation

The basis for the new packaging regulation is the EU’s ‘Green Deal’, according to which Europe is to be climate-neutral by 2050 at the latest. The core element here is the ‘Circular Economy Action Plan’: by 2030, all packaging on the internal market is to be made reusable or recyclable, but not just any old way, but in an economically viable manner.

New packaging regulation replaces old EU packaging directive

The proposed EU Packaging Regulation is intended to replace the 1994 EU Packaging Directive 94/62/EC, while displacing national packaging legislation.

Unlike the old directive, the new regulation would not have to be transposed into national law. Instead, it would be applicable in all EU member states as soon as it came into force and would, so to speak, supersede national regulations on packaging.

This naturally raises the question of whether the national packaging law would then still be needed at all.

On the one hand, the new packaging regulation would lead to a uniformity of the specifications for packaging and packaging waste at EU level, but on the other hand, it would cancel out sensible national regulations, which could also be a disadvantage, as can be seen clearly in the example of Germany:

If one compares the drafted EU Packaging Regulation with the level already achieved in the Federal Republic of Germany at the current time, the former lags behind in some points with its targets, or introduces more demanding requirements only very late.

In any case, as soon as the new EU packaging regulation comes into force, all member states of the European Union must comply with it.

We advise companies to start looking at the expected requirements now to have more time to implement the changes in their own operations, thus stretching and easing the transition.

Primary objectives of the new EU packaging regulation

Basically, that’s what the Commission’s EU Packaging Regulation is all about,

– reduce packaging waste,
– promote high-quality recycling, and
– Promote the internal market for secondary raw materials.

Note: In terms of packaging waste reduction, each EU member state is to reduce per capita packaging waste generation by

– 5% by 2030,
– 10% by 2035, and
– 15% by 2040

To achieve these targets, the EU Packaging Regulation proposal primarily aims to,

– unnecessary packaging and to promote reusable
– reusable packaging.

A look at the practice: potential effects of the law change

Below, we take a look at a few requirements of the proposed regulation (in excerpts) and address how they might affect packaging design.

How reusable packaging is (could be) implemented.

Chapter 3, Article 11 of the EU Packaging Regulation states:

“Reusable packaging must be provided with a QR code or other data carrier that provides access to information that facilitates its reuse…”


Take the mineral water bottle, for example: in accordance with the regulation, it will be converted from a disposable to a reusable bottle and provided with a QR code, which the consumer can use to find out what to do with the bottle after drinking the water or what will happen to it afterwards. In the future, packaging design could also change drastically: away from labels and bright colors for less waste and easier recycling?


A current example is Nestlé’s popular Nesquik cocoa, which now comes in practical reusable packaging.

Use of compostable plastics

Chapter 2, Article 8 of the EU Packaging Regulation states:

“… Fruit and vegetable attached labels…. must be compostable…”


Example Pink Lady Apple: At first “only” the material of the sticker transforms, later perhaps the optics?

“… Coffee capsules… must be compostable…”

Here, too, manufacturers of coffee capsules change the material in the first step. There are now also already some capsules that are fully compostable. In organic versions, this is basically the case. If we dare to look into the future: Will coffee capsules even become completely superfluous at some point?

“Other packaging… Are eligible for material recycling.”

Take Matchachin’s guayusa tea, for example: instead of composites, monomaterials could soon be increasingly used.


Uniform labeling for easier disposal

Chapter 3, Article 11 of the EU Packaging Regulation states:

“Uniform marking on packaging for disposal…. Marking is also to be seen on the waste containers…”


Take yogurt, for example: Until now, each brand has been able to design its “tips for the garbage can” more or less individually. In the course of the introduction of the new regulation, however, the labeling is to be standardized so that it is easier for the consumer to assign the packaging to the correct waste garbage can.

Packaging recycling

Annex 2, Table 1 of the EU Packaging Regulation states:

“… Plastic packaging used at retail for grouping goods…. as a convenience to enable or encourage end consumers to purchase more than one product…”


Example shampoo: According to the specification, the products in “advantage packs” are initially linked with paper or in cartons. In the future, the direction could be to couple an always reusable main bottle with refill packs.

Article 7 of the EU Packaging Regulation states:

“From January 1, 2030, the recycled content must be at least 10% for touch-sensitive plastic packaging and at least 35% for all others…. From January 1, 2040, it will already be 50% and 65% respectively…”

Example dishwashing detergent: from 2030, the recycled content of the plastic must be at least 35%, and from 2040 it will be at least 65%.


Example cheese slices: From 2030, the recycled content of the plastic must be at least 10%, and then at least 50% from 2040.


Article 6, paragraph 7 of the EU Packaging Regulation states:

“… Assessment by performance levels for recyclability…”

The classification of product packaging into different performance classes is intended to help quickly assess recyclability.


Prohibitions in the design of packaging

Annex 2, Table 1 of the EU Packaging Regulation states:

“… Portion packs will be prohibited.”

Take condensed milk, for example: small portion packs, which are particularly popular in cafés and hotels, are no longer permitted under the new regulations, so that in future only “normal” packaging units may be offered and used.


Take tomato ketchup, for example: Or will there perhaps be an interim solution in the future with compact packaging that can be recycled without difficulty?


Another example: small shampoo packages in hotels are no longer allowed



The new EU Packaging Regulation brings with it numerous innovations. Although it is only a draft so far, it is safe to say that the regulation will come into force in the foreseeable future. We advise companies to actively deal with the requirements as early as possible. We will be happy to support you in implementing the necessary changes.

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