Mandatory labelling of packaging in the EU
According to the decisions of the EU Commission, manufacturers and retailers are obliged to ensure legally compliant labelling of packaging in the EU. The labelling obligation is intended to facilitate collection, reuse and recycling and to provide end consumers with important information about the packaging. These requirements are laid down in Directive 94/62/EC.
Since its first adoption in 1994, the EU Directive on packaging and packaging waste has been continuously developed, in particular through the significant amendment by means of Directive (EU) 2018/851. A central aspect of the agenda is the tightening of labelling requirements for packaging, which are intended to standardise and optimise the implementation and monitoring of recycling processes within the EU.
Development of the EU labelling obligation
In 1994, the EU adopted the “Packaging and Packaging Waste Directive”. Since then, there have been several amendments, such as the amending Directive (EU) 2018/851, which the Commission believes is the only way to drastically minimise packaging waste by 2030 and increase the recycling rate at the same time.
The objectives of the EU Packaging Directive 94/62/EC, which apply to all EU member states, include
- Reduction of packaging waste and its environmental impact: The directives call on EU member states to take measures to reduce the amount of packaging waste and minimise the impact on the environment.
- Harmonisation of national disposal measures: A standardised framework is to be created within the EU to make the handling of packaging waste and the labelling requirements for packaging material in the EU more efficient and environmentally friendly.
- Improving environmental quality: By preventing and reducing the impact of packaging and packaging waste on the environment, the overall environmental quality should be improved. This means both reducing the pollutants released into the environment and minimising the amount of physical waste.
- Promoting the circular economy: The updated measures of Directive (EU) 2018/851 aim to promote the prevention of packaging waste and encourage the reuse, recycling and other forms of recovery of packaging waste instead of final disposal.
However, there are no standardised regulations for this. In other words, there are different requirements in Germany than in France or Italy, for example regarding the labelling obligation for packaging in the EU. If you want to fulfil your obligations with a good feeling and at the same time save time, effort and costs, we at Deutsche Recycling GmbH are happy to be at your side.
Current regulations and labelling requirements for packaging in the EU
The basic requirements of the EU Packaging Directive include.
- Minimisation of volume and weight: Packaging should be as small as possible in volume and weight without compromising the safety and hygiene of the contents.
- Reduction of hazardous substances: The use of harmful substances in packaging should be limited to the minimum necessary.
- Design for recycling: Packaging should be reusable or efficiently recyclable, including the possibility of material or organic recycling and energy recovery.
It is also necessary for the individual EU member states to take further, targeted measures to ensure that the specific recycling targets for different types of packaging are met. This also includes the mandatory labelling of packaging in the EU using EU recycling codes or national recycling labels.
The labelling obligation for packaging in Europe
Labelling requirements vary depending on the country and product category. In Germany, manufacturers must label packaging with certain mandatory information, such as product name, ingredients, nutritional information, best-before date and manufacturer information. Specific information on the type of material must also be provided to enable correct disposal.
According to Annex 5 of the German Packaging Act (VerpackG), the use of certain, precisely defined numbers and abbreviations for material labelling is mandatory under the labelling obligation in the EU. In addition, the manufacturer must also clearly indicate the mass of the packaging material. Any deviations from the labelling specified in Annex 5 are not permitted by law.
National differences and special features of mandatory labelling of packaging in the EU
As a rule, the responsibility for the EU labelling obligation lies with the person who places the goods on the market. Producers or consignors are obliged to package the goods properly and, depending on the regulations of the EU country, to label them. Retailers or third parties should ensure that the goods and packaging have already been correctly labelled by the upstream supplier.
Compulsory labelling of packaging in the EU: Germany
There is no general statutory labelling requirement for packaging in Germany. However, the corresponding packaging and labelling requirements for packaging in the EU country of destination must be taken into account for exports. However, environmental labels and various symbols are usually also used voluntarily on packaging in Germany.
The following information must be provided when registering:
- Contact details and identification number of the manufacturer
- Name of the person authorised to represent the company
- Tax number and brand name of the product
- Declarations on take-back obligations and the accuracy of the information
Packaging details are also required:
- Registration number
- Material type and weight
- Name of the waste disposal system
- Period of system participation
Every year, a declaration of completeness must be submitted by 15 May, listing the packaging placed on the market in the previous year. Manufacturers who do not exceed certain quantity thresholds are exempt from this obligation.
Compulsory labelling of packaging in the EU: France
In France, the labelling requirements for packaging are strictly regulated in accordance with EU guidelines, particularly in the B2C segment for household packaging. All of this packaging must be labelled with the Triman logo in France, which includes clear instructions on correct disposal and separation in addition to the logo.
All labelling must be in black and white and the Triman symbol must have a minimum width of 0.6 cm. Misleading packaging labelling has been penalised in France since 2020. The EU labelling obligation does not apply to packaging in the B2B sector that is supplied to companies.
Compulsory labelling of packaging in the EU: Italy
A new labelling requirement for EU packaging has been in force in Italy since 1 January 2023. All packaging must bear a numerical code to identify the material used as well as instructions for correct disposal and waste separation in Italian. This regulation affects packaging manufacturers, processors and importers in both the B2B and B2C sectors. Violations of these regulations can be penalised with fines of up to EUR 40,000. This involves labelling the packaging material, not the contents. In addition, all manually separable components of the packaging must be labelled accordingly.
Compulsory labelling of packaging in the EU: Spain
From January 2025, labelling will be mandatory in accordance with Royal Decree 1055/2022. All packaging must then be clearly and legibly labelled with the appropriate pictogram indicating the intended disposal container. This is intended to ensure better waste separation and recycling rates.
Challenges of mandatory labelling for packaging in Europe
While Germany and many other European countries often do not have strict labelling requirements for packaging in accordance with the EU, other countries have introduced strict regulations. Future EU plans aimed at tightening and standardising regulations may bring new challenges.
Deutsche Recycling GmbH will be happy to support you in taking into account all current and future relevant obligations, complying with EU packaging labelling regulations, complying with your packaging licensing and ensuring that all legislative changes can be implemented correctly. With us at your side, you can reduce the effort and costs and avoid potential penalties.
