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Everything you have to know about packaging compliance in the EU

In the ever-evolving landscape of e-commerce, it’s crucial for sellers to stay informed about the regulations that govern their operations.

In the European Union (EU), one of the key aspects that demand your attention is the Packaging Directive, which regulates the handling of packaging waste. This directive carries significant implications for online retailers worldwide, including those who sell alcoholic beverages in Europe. However, navigating the labyrinth of EU packaging laws can be a daunting task, with various member states imposing their own unique rules and penalties for non-compliance.

In this blog post, we’ll provide you with a comprehensive overview of what you need to know about complying with the EU Directive, what is meant by EPR, Circular Economy, special issues when selling glass packed products and the potential penalties you could face in Europe.

Understanding the Packaging Law in Europe and its objectives

The Packaging law in Europe is a set of regulations aimed at managing packaging and packaging waste within the EU. Formally known as Directive 94/62/EC, this directive was renewed by the amending Directive EU 2018/852. Its primary goal is to harmonize national rules concerning the disposal of packaging waste while minimizing environmental impact to achieve a high level of environmental protection.This directive applies throughout the European Union to all types of packaging, regardless of their source, whether it’s produced by industry, commerce, administration, trade or elsewhere, and regardless of the materials used. The Amending Directive (EU) 2018/852 places a strong emphasis on promoting and prioritizing reuse, recycling, and other forms of waste recovery, aligning with the principles of the circular economy.

In pursuit of these objectives, the EU focuses on:

  • Conservation of resources
  • Waste prevention
  • Recycling and reuse
  • Labelling of materials
  • Advancing towards a circular economy

These regulations also assign responsibility to waste producers and importers through Extended Producer Responsibility (EPR).

What is meant by Circular Economy, EPR, and Compliance?

  • Circular Economy: The circular economy model prioritizes the reuse, repair, refurbishment, or recycling of materials and products before their ultimate disposal at the end of their life cycle. This underscores the importance of knowing the materials used in your products, especially when it comes to recycling.
  • Extended Producer Responsibility (EPR): Companies are obligated to ensure the proper disposal or reuse of their products in the EU market. This includes ensuring that products and their packaging can be recycled and reused after being disposed of by consumers, as mandated by the Packaging Directive.

Compliance: Compliance means meeting the legal requirements of the country in which you operate. Failure to comply can result in hefty penalties, making it essential for sellers to be well-versed in the laws of their target countries.

Navigating the Landscape and Identifying Strict Regulations

To effectively implement the circular economy model, producers and distributors must register with relevant disposal systems in individual countries. While the Packaging Directive seeks to promote uniformity within the EU, many member states have enacted their own specific rules and regulations, creating a complex environment for sellers. Notably, countries like Germany, France, and Italy have stringent regulations, including requirements for packaging labeling.

Germany: Importers must license all packaging entering Germany, and non-compliance or inaccurate declarations can lead to penalties. This is regulated in §36 of the Packaging Act. Registration is handled by the Central Packaging Register (ZSVR), which issues a unique LUCID Packaging number necessary for all sales.

Italy: Italy enforces strict packaging labeling requirements, with online traders required to provide precise material information, using an alphanumeric code and Italian sorting advice as outlined in Decree No. 116.

France: France mandates packaging licensing through registration with the French environmental authority, ADEME, issuing a Unique Identification Number (UIN). Different UINs are required for various waste streams, necessitating separate registrations and data reporting. Furthermore, France introduced a legal labeling obligation in 2022, including the Triman Logo and the Infotri separation notice, subject to specific design criteria.

These three countries are just examples. In fact there are even more and different obligations in all other European Countries.

Streamlining Compliance with ecosistant

If you find yourself confused by the intricate web of regulations across European countries, ecosistant is here to assist you. Our digital service covers all European countries, simplifying the compliance process. With ecosistant, achieving compliance becomes quick, easy, and penalty-free.

Special Issues when shipping alcoholic beverages

When it comes to selling alcoholic products, especially those packaged in glass containers, shipping becomes a critical consideration for some reasons. The two most important are those:

1.     Glass, while an excellent choice for preserving the integrity of beverages, is also fragile and requires special handling to ensure it reaches customers undamaged. So you need a lot of cushioning material that nothing gets broken. These materials also have to comply with the laws and regulations. And they also have to be registered.

2.     Glass itself is very heavy. Often, the laws of the countries apply depending on the weight of the goods and the corresponding waste. Therefore, sellers who ship relatively small quantities of these glass packaged goods are also  affected. 

It’s essential to align your packaging and shipping practices with the EU’s packaging regulations. By doing so, you not only comply with environmental laws but also enhance the overall customer experience by delivering pristine, intact products to your valued customers.

You also need to think of your alcohol excise duties, which can be handled by Eurotax, more info in our page or contact us here.

Obtaining Your EPR Number and Fulfilling Recycling Obligations

The process of obtaining an EPR number and meeting recycling obligations may vary from country to country. can guide you to the right contact point for each country.

The general steps involve:

  1. Registering with the authority in the respective country.
  2. Acquiring a license from a national recycling scheme.
  3. Reporting sales quantities at regular intervals to track waste generation.

Penalties for Non-Compliance

Penalties for non-compliance can range from market exclusion and sales bans on platforms like Amazon to hefty fines imposed by individual countries. In Germany, violations of the Packaging Act can result in fines of up to €200,000 or distribution bans. The loss of profit due to Amazon blocking your listing is another significant risk.

Ensuring Compliance

Staying on top of EPR and recycling laws across Europe may seem challenging, but it’s essential for environmental sustainability. Different marketplaces provide some information about obligations in different countries, but sellers must remain vigilant and ensure compliance, including timely quantity reporting.

In conclusion, complying with packaging regulations in Europe is crucial for sellers of alcoholic products. ecosistant is your trusted partner in navigating these complex laws, ensuring your business operates sustainably and penalty-free across the EU. Let’s work together to make the European e-commerce sector more environmentally conscious.

About the Author and ecosistant:

Jessica Krahl, Head of Marketing at ecosistant, is passionate about spreading the message of sustainable e-commerce. 

ecosistant serves as your digital advisor on packaging licensing in Europe, offering services that cover EPR and recycling regulations, as well as labelling obligations in all European countries. We are dedicated to promoting sustainability in the e-commerce industry and are eager to connect with innovative players in the field.

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