The most significant shift in EU policy is the replacement of the old packaging directive with the Packaging and Packaging Waste Regulation (PPWR). Unlike a directive, this regulation applies with immediate and uniform force across all 27 EU member states, eliminating national interpretation differences. The primary goal is a 15% reduction in packaging waste by 2040, compared to 2018 levels. This requires a fundamental redesign of packaging strategies for countless companies.

The PPWR introduces several non-negotiable technical requirements. For e-commerce shipments, the void space ratio is now capped at a maximum of 50%, forcing a move away from oversized boxes with excessive filler material. By 2030, all packaging placed on the market must achieve at least a Grade C recyclability standard, meaning it must be at least 70% recyclable by weight. This single requirement will render many current packaging designs obsolete. You can learn more about the specifics in our PPWR explainer. These rules mean that producers must re-evaluate their entire packaging portfolio within the next 24 months. The time to begin this process is now, as supply chain and design changes require at least 18 months of lead time.

A critical operational change introduced by the PPWR is found in Article 45. It mandates that any company selling goods into an EU member state where it is not physically established must appoint a local Authorized Representative for EPR. This obligation, which was previously only required in a few countries, now extends across the entire EU trading bloc. This representative assumes the legal responsibility for the producer’s EPR obligations, including registration and reporting. For thousands of cross-border online sellers, this is a new and complex administrative requirement.

Here is how this will impact businesses selling into the EU:

• Producers must contract with a representative in every single EU country they ship to.
• This representative handles all communications with national authorities.
• Marketplaces like Amazon will be required to verify that their sellers have these representatives in place.
• Failure to appoint a representative will result in a de facto sales ban in that country.

This new rule adds a significant layer of complexity to EU market access. Navigating these new requirements is a challenge, but our experts can help you navigate complex EPR regulations. The immediate appointment of representatives is crucial to prevent any interruption in trade.

While the WEEE Directive itself is under review for a future update, recent evaluations and changes to related regulations signal a much stricter enforcement environment starting in 2025. A July 2025 European Commission evaluation revealed a stark gap: while 14.4 million tonnes of electronic equipment were put on the market in 2022, only 5 million tonnes of e-waste were officially collected. This nearly 65% discrepancy has triggered a crackdown on undocumented and illegal waste streams. As of January 1, 2025, stricter rules for the cross-border shipment of WEEE are in effect to prevent illegal exports disguised as used equipment.

Producers of electrical and electronic equipment must now be more diligent than ever. Regulators are specifically targeting the insufficient recovery of critical raw materials from the 9 million tonnes of uncollected e-waste. This means increased scrutiny of producer registration, reporting, and financing of collection schemes. Companies must ensure their compliance is flawless to avoid penalties. It is time to prepare for WEEE directive changes and ensure your take-back systems are fully compliant with the latest enforcement standards.

The new EU Batteries Regulation (2023/1542) fully replaces the old directive on August 18, 2025, introducing a comprehensive lifecycle approach. From this date, producers are subject to much stricter EPR obligations, including mandatory registration in each member state and the financial responsibility for all waste battery management. The changes introduce new battery categories and specific rules for each, demanding a granular level of compliance that did not exist before. The deadlines are imminent and require immediate preparation.

Key dates and requirements producers must act on now include:

1. CO₂ Footprint Declaration: Required for electric vehicle batteries from February 18, 2025.
2. Increased Collection Targets: The collection rate for portable batteries must reach 63% by 2027 and 73% by 2030.
3. Digital Battery Passport: Mandatory for certain battery types from 2027, providing detailed information on origin and material composition.
4. Due Diligence: Companies with over €40 million in revenue face new supply chain monitoring obligations.

Many businesses are not prepared for the Digital Battery Passport requirement, which necessitates data collection starting now. These new laws are a core part of the EU’s push to get companies ready for circular economy laws. The complexity of these new rules makes immediate action a necessity. If you have not yet started adapting to these regulations, you must contact Deutsche Recycling to ensure you can continue to place batteries on the EU market legally.