The Packaging and Packaging Waste Regulation (PPWR) replaced the previous directive, creating a single, stricter set of rules across all 27 EU member states. This change aims to reduce packaging waste by 15% per person by 2040 compared to 2018 levels. For food exporters, this means all packaging placed on the EU market must be recyclable by 2030 and meet specific performance grades. From January 1, 2030, any packaging with a recyclability performance grade below 70% will be banned from the market. This shift from a directive to a regulation eliminates national loopholes and creates one unified compliance standard. These new rules require immediate attention to your packaging material declarations. The regulation harmonizes rules on everything from material choice to labeling, demanding a complete review of your current packaging strategy.

The PPWR introduces mandatory targets that directly impact packaging design for food and beverage products. By January 1, 2030, all packaging must be designed for recycling and achieve at least a Grade C recyclability rating (70% recyclable by weight). By 2038, this requirement tightens to Grade B, which demands 80% recyclability. Furthermore, plastic packaging must meet specific minimum recycled content thresholds. For instance, single-use PET beverage bottles must contain at least 25% recycled plastic by 2025, a figure that rises to 30% for all plastic bottles by 2030. Many companies are unprepared for the 7.5% recycled content requirement for contact-sensitive plastic packaging. These targets are not suggestions; they are legal obligations for market access. Understanding the packaging and packaging waste regulation is the first step toward compliance.

Beyond environmental rules, exporters must comply with strict safety standards for Food Contact Materials (FCM). The primary EU law, Regulation (EC) No 1935/2004, mandates that packaging must not transfer substances to food in quantities that could endanger human health or change the food’s taste or composition. This regulation covers all materials, including plastics, paper, glass, and metals. A critical deadline is the ban on per- and polyfluorinated alkyl substances (PFAS) in food-contact packaging, which takes effect in 2026. To prove compliance, businesses need a Declaration of Compliance (DoC) and must follow Good Manufacturing Practices (GMP) as outlined in Regulation (EC) 2023/2006. A single non-compliant material can lead to a recall of your entire product line across the EU. These legal requirements for shipping are as important as customs duties. This dual focus on safety and sustainability requires a comprehensive compliance strategy.

Germany, as the EU’s largest market, enforces one of the strictest national laws, the Verpackungsgesetz (VerpackG). This law requires any company placing packaged goods on the German market to register with the LUCID packaging register before the first product is sold. There is no minimum threshold; the rule applies from the very first package shipped. Following registration, you must license your packaging volumes with a dual system provider, effectively paying for their future recycling. Failure to comply can lead to fines of up to €200,000 per violation and an immediate ban on sales. Online marketplaces like Amazon are now legally required to verify your LUCID registration, making evasion impossible. To comply with the German Packaging Act, you must take these three steps:

• Register your company and brand names in the LUCID portal, managed by the ZSVR.
• Sign a contract with a German dual system provider to license your annual packaging volumes.
• Report your licensed volumes to both your dual system and the LUCID register.

These steps are not optional; they are a prerequisite for market entry.

The entire EU regulatory framework is built on the principle of Extended Producer Responsibility (EPR). EPR shifts the financial and operational burden of managing packaging waste from municipalities to the companies that produce it. By December 31, 2024, all EU member states are required to have EPR schemes for packaging in place. This means that as an exporter, you are legally and financially responsible for the collection, sorting, and recycling of the packaging you place on the market. These obligations are fulfilled by paying fees to a national Producer Responsibility Organization (PRO), which vary based on the material and weight of your packaging. Eco-modulated fees mean that less recyclable packaging will incur higher fees, creating a direct financial incentive for sustainable design. Understanding your role is key to fulfilling recycling obligations. This system makes sustainable packaging a matter of financial prudence, not just corporate responsibility.

The consequences for ignoring these regulations are severe and designed to be dissuasive. In Germany, failing to register with LUCID or license your packaging can result in fines of up to €200,000 and the seizure of profits from illegal sales. One online pharmacy faced back payments of at least two million euros for failing to participate in a dual system for five years. Beyond fines, non-compliant companies face immediate sales prohibitions, meaning your products can be stopped at the border or pulled from shelves. Distributors and online marketplaces are legally obligated to verify your compliance and will refuse to stock or ship your goods if you cannot provide a valid EPR registration number. The risk is not just financial; it’s a complete loss of access to the entire EU market of over 450 million consumers. The time for a proactive compliance strategy is now, before these penalties impact your business.

The complexity of these new regulations requires expert guidance to ensure 100% compliance and avoid business disruption. Waiting can result in costly fines and a complete halt to your EU sales. The requirements are active now, and enforcement is only becoming more stringent. For companies that have not yet taken action, the situation is urgent. You must ensure your products are properly registered and that your packaging meets all new EU and national standards immediately. The most direct path to achieving this is to partner with a specialist who manages these obligations on your behalf. A single point of contact for all EU countries simplifies a complex and fragmented regulatory landscape. To secure your market access and register your product packaging correctly, you must act without delay. Contact the experts at Deutsche Recycling today for a consultation to ensure your food and beverage products remain compliant and available to customers across the European Union.