On 1 January 2025, Royal Decree 1055/2022 will introduce a labelling requirement for packaging in Spain, which will present companies with new challenges. From this date, all packaging that can be categorised as household waste must be clearly labelled with recycling information. This not only affects Spanish companies, but also anyone who exports products to Spain.

But why is this change necessary? Spain has set itself targets to promote environmental protection and improve recycling rates. The labelling requirement is intended to make it easier for consumers to dispose of packaging waste correctly, which should contribute to higher recycling rates and a more efficient circular economy.

These new regulations will have a direct impact on you if you export packaged products to Spain that are generated there by private end consumers. Regardless of whether you use plastic packaging, paper packaging or glass containers – specific labelling requirements will apply to each type of packaging from 2025 and must be met. It is therefore high time to review and adapt your packaging to meet the new requirements.

The labelling obligation applies to all so-called ‘household packaging’ – i.e. packaging that typically accumulates with end consumers in private households. In Spain, the term ‘envases domésticos’ is used for this. This means that food packaging, beverage packaging as well as packaging for household goods and consumer goods are affected by the regulation.

If you export packaging to Spain or sell your products there, you must ensure that the packaging is correctly labelled. This applies not only to the outer packaging, but also to all packaging components. This includes, for example, labels, plastic sleeves or boxes that wrap the product. Even if your packaging consists of different materials, you are obliged to attach the appropriate disposal labelling for each material.

An example: Your packaging consists of a glass bottle with a plastic lid. In this case, you must affix two symbols to the packaging – one for the glass container (green container) and one for the plastic lid (yellow container). If the packaging consists of several materials that cannot be separated from each other (e.g. composite materials), you must use the symbol for the material with the largest proportion by weight.

The labelling must be clearly visible, legible and permanently affixed to the packaging. Minimum size and design requirements must also be met to ensure that the information reaches the consumer clearly and unambiguously.

In order to fulfil the new legal requirements in Spain, you must label your packaging with special symbols for waste separation. These symbols inform consumers in which containers they should dispose of their packaging waste. You can either develop a symbol yourself or use existing symbols.

In Spain, packaging waste is sorted into four main fractions, for each of which different containers are provided:

• Yellow container: Plastic and metal packaging (e.g. drinks cans, plastic bottles)
• Blue container: Paper and cardboard packaging (e.g. cardboard boxes, paper packaging)
• Brown container: Compostable packaging (e.g. biodegradable packaging, organic waste)
• Green container: Glass packaging (e.g. glass bottles, jam jars)

For each of these fractions, you must affix appropriate waste separation symbols to your packaging. If it is not possible to use the official colours for labelling (yellow, blue, brown, green) for design reasons, you can also use black and white variants. In this case, however, you must mention the relevant container in writing to avoid any misunderstandings during disposal.

The new labelling regulations in Spain not only require a symbol to be displayed, but also that it meets certain requirements. To ensure that everything is legally correct and remains clearly recognisable for consumers, there are some important requirements that you must observe:

• Minimum size and visibility: Each labelling symbol must be at least 8 mm in size. Ideally, you should use a size of 10 mm to optimise legibility. The symbols must be clearly visible on the packaging and must not be obscured by other design or packaging elements.
• Colour specifications: The official recommendation is to label in the colours yellow, blue, brown and green, according to the respective disposal fraction. If this is not possible for design reasons, you can use black and white or other colour variants.
• Special rules for composite packaging: If your packaging consists of several materials that cannot be separated from each other, indicate the material with the largest proportion by weight. This allows consumers to dispose of the packaging correctly.
• Reusable and compostable packaging: Reusable packaging, such as cans or bottles, must also bear the symbol of the deposit return system (DRS). Compostable packaging must be labelled ‘Do not discard in the environment’ and be certified in accordance with UNE EN 13432:2001 or a comparable standard.

Note: A transitional period applies to products and packaging for which it can be proven through traceability that they were produced, manufactured, purchased or imported in an EU member state before 1 January 2025. These may be marketed without labelling until the stocks expire, but within 6 months at the latest.

The mandatory labelling of packaging in Spain brings new challenges, but also opportunities for companies. With clear guidelines on waste separation and disposal, the legislation aims to improve the recycling process and raise environmental awareness among consumers.

For you, this means adapting your packaging in good time and fulfilling the legal requirements. By implementing the new rules, you not only contribute to a cleaner environment, but also strengthen your customers’ trust in your sustainability efforts.

Commercial packaging is also subject to system participation in Spain since January 2025. While this obligation previously only applied to household packaging, commercial and industrial packaging is also affected now.

So that you can prepare in good time and fulfil all the new requirements, have a look here.

The Danish parliament has approved the delegation of responsibility for packaging and single-use plastic products to companies placing them on the market, based on the polluter-pays principle. This means a significant redistribution of the costs of recycling: what was previously borne by citizens will now be transferred to manufacturers.

Companies placing packaging on the market must now bear the costs of collecting and sorting household waste and participate in programmes to reduce packaging waste and promote recycling. The EPR for packaging applies to all types of packaging, regardless of whether it is plastic, glass, wood, metal, cardboard, paper, etc. In Denmark, a distinction is also made between three types of packaging: primary and sales packaging, secondary packaging and multipacks, and tertiary and transport packaging. It is estimated that around 41,000 companies will be affected by this regulation. In addition, charges will be introduced for the disposal of single-use plastic.

There are exceptions for smaller manufacturers: Companies that put less than 8 tonnes of packaging into circulation in Denmark each year will have to provide less detailed information. This regulation will be reviewed again in 2027.

A registration obligation for packaging according to the Danish regulation (Bekendtgørelse om registrering og indberetning af emballage) in the Danish producer register existed until 31 August 2024.

On 20 September 2024, an additional regulation (Bekendtgørelse om visse krav til emballager, udvidet producentansvar for emballage samt øvrigt affald der indsamles med emballageaffald) was published. This new regulation extends the previous regulations and is expected to come into force on 31 December 2024.

According to this new regulation, there are further deadlines for companies that place packaging on the Danish market:

• All manufacturers must have joined a collective system by 14 January 2025.
• Producers must report the packaging quantities actually placed on the market in 2024 by 1 June 2025. Simplified reporting is available for manufacturers who place less than 8 tonnes of packaging on the Danish market per year.

You are obliged to register your company with Dansk Producent Ansvar DPA and report your packaging volumes for 2024. In addition, you must have participated in a collective system by 31 August 2024 and appoint an authorised representative. Missed this important deadline? Don’t worry! We can help with our licensing service!

This policy decision aims to identify those in the value chain who have the greatest influence on packaging design. It is an important step towards improving waste management and recycling in Denmark and strengthening the circular economy.

In order to reduce the impact of packaging and products on the environment, Finland has adapted its EPR (Extended Producer Responsibility) regulations. Registration with a collective system has been mandatory in Finland since 2024, whether for big players or newcomers. By removing the exemption limit for companies with a turnover of less than one million euros, Finland is taking a major step towards protecting the environment and resources. The adjustment in the Finnish definition of a producer is entirely in line with EU regulations.  

This means that all companies in Finland, regardless of their turnover or size, must now fulfil their extended producer responsibility for their packaging.  

There are also changes in the area of service and agricultural packaging. Producers or importers of service packaging, such as pizza boxes or coffee-to-go cups and agricultural packaging intended for agricultural products, now also fall under the definition of producer in the Finnish Packaging Act. Since then, the producer is responsible for the packaging, not the companies that actually fill the packaging and hand it out to customers. The regulation relieves the burden on small shops and restaurants. 

If you are a foreign company packaging products for the Finnish market or importing packaged products and have a permanent location or branch in Finland or sell packaged products from abroad to Finnish end customers, you are responsible for fulfilling your Finnish EPR obligations.  

Your obligations include registering with a collective system such as Rinki (where you pay a one-off registration fee and annual customer fees) and preparing an annual report on the quantities of your own packaging waste for the Finnish authorities. You also pay annual recycling fees depending on your packaging volumes. If you do not register with a collective system, you are free to set up your own system for collecting, sorting and recycling your packaging, but this involves a lot of bureaucracy.

Saving fees with recyclable packaging? It’s possible! To encourage companies to use recyclable packaging, Finland, like some other EU countries, is implementing eco-modulation.  

This means that you can reduce your recycling fees for packaging based on its recyclability. Fees for packaging made of mono-material, i.e. packaging made of only one type of plastic, are therefore lower than for packaging made of different types of plastic.   

Finland has been implementing this regulation since 2023. At the beginning of 2024, the regulation was expanded to include categories for metal and paper.

With the extension of the EPR obligations in the packaging sector by removing the turnover limit, almost 30,000 companies in Finland will be made more responsible. Costs will be distributed more fairly and recycling will be more effective. Although this increases the administrative burden for some companies, the extension represents an opportunity for the circular economy and thus for environmental and resource protection.

Eco-Fee Modulation is an instrument to promote the European circular economy. It is intended to incentivise companies to increase the use of recyclable packaging. Some EU countries are already using it to differentiate the licence or recycling costs in their respective EPR systems.  

Specifically, modulation aims to incentivise the development of sustainable packaging designs by differentiating the licence fees for sales packaging. In short, companies that use environmentally friendly packaging pay lower licence fees to the EPR systems and thus save costs. On the other hand, packaging that does not fulfil the requirements of eco-modulation is taxed more heavily and is therefore more expensive. This approach is an important step towards an environmentally conscious economic policy that promotes ecological sustainability. 

In the European Union, the Packaging Directive requires companies that put packaging into circulation to ensure its disposal. This principle is known as extended producer responsibility (EPR). However, the specific requirements and obligations vary from country to country, as each country has developed its own laws to implement the EU directive. However, the basic principle remains the same everywhere: companies that put packaging into circulation pay a licence fee to an EPR system that is responsible for the collection, sorting and recycling of packaging waste.

In Germany, for example, companies fulfil their obligations by registering and reporting data in the LUCID packaging register and licensing their packaging with a dual system such as Interseroh+ via Lizenzero. Do you ship to the EU? With our licensing service, we can easily fulfil all your obligations per country for you! 

The standardisation of the eco-fee at European level is a desired goal, but implementation currently varies greatly from country to country. While certain materials are already taxed in some countries, others have not yet introduced eco-fees. Incentive models in the form of eco-fee modulation have already been introduced in France, the Netherlands, Belgium and Finland. However, the exact structure varies from country to country.   

In principle, however, the recyclability of packaging, on which the eco-fee is based, is orientated towards the following criteria:  

• Sortability and separability  
• Source material (paper, plastic, metal, glass)  
• Residual emptiability
• Contaminants in the material 

Do you ship to different EU countries? We take care of your packaging licensing! On top of that, we can also check for you whether the design of your packaging meets the requirements of Eco-Fee modulation in your target markets. If the design of the packaging does not yet meet the Eco-Fee requirements, we can also support you in adapting your packaging to the standards on request.

On 1 July 2023, Hungary tightened the regulations regarding extended producer responsibility in the country. Since then, online retailers in particular have been held more accountable. If you sell goods and packaging to Hungary, they must be licensed with an EPR system from the first kilogramme. This now also applies to retailers who do not have a Hungarian VAT number. Foreign companies that are obliged to obtain an EPR licence must appoint a Hungarian representative for this purpose.  

In addition to the licensing of packaging, there are further obligations for companies that fill packaging with goods for the first time or have it filled and sell it to private individuals. Additional registration with the MOHU licence company and the Hungarian environmental authority is required. In addition to packaging, some product categories are also subject to the new EPR levies.

Until now, packaging did not have to be licensed in Hungary. However, companies above a certain annual turnover with a VAT number pay a product fee through the environmental tax. Since July 2023, however, all distributors of packaging, with or without a VAT number, are now obliged to contribute to the recycling costs. The new EPR requirements replace the previously applicable “product fee for environmental protection”. Since April 2023, the companies concerned have had to register on the MOHU Partner Portal and with the environmental authority.   

The registration and payment obligation always applies to the first Hungarian distributors and also applies if an online shop based outside Hungary sells goods to end consumers in Hungary.   

Unlike in France or Italy, however, there is no labelling obligation for packaging.

In addition to packaging, the new EPR regulations also apply to textiles, wooden furniture, batteries and WEEE products (electrical and electronic equipment).  

If you sell these products in or to Hungary, registration with the above-mentioned bodies and an EPR levy are also mandatory. Retailers are also responsible for the effective disposal of these products. 

The extension of the EPR obligations for manufacturers and retailers in Hungary presents them with new challenges in terms of their registrations, but also due to the costs associated with the EPR levy.    

At the same time, however, these adjustments will also trigger the implementation of more sustainable practices, which in turn will benefit the environment. In addition, the circular economy is strengthened and environmental protection is promoted.  

You need support in implementing your obligations in Hungary? We are happy to help!

As in many other EU countries, single-use plastic is increasingly under scrutiny in the Netherlands to protect the environment. Based on the Single-Use Plastics Directive (EU) 2019/904 of the European Parliament, more and more EU member states are implementing regulations to reduce the environmental impact of certain plastic products. 

Since July 2023, for example, Dutch consumers have been paying an additional fee for their single-use plastic cups or containers, especially for to-go products. The fee also applies to paper cups with a plastic lining and to-go packaging available in supermarkets. Since January 2024, the additional regulation on Single-Use Plastic has been in force. As a result of this regulation, various single-use plastic products are no longer available in Dutch stores. Instead, there is a shift towards environmentally friendly and reusable alternatives. 

In addition to this regulation, a ban on the use of microplastics in cosmetic products has come into effect. The ban on these tiny plastic particles, which are found in many personal care products, is intended to help improve water quality and protect our marine ecosystems.

• Plastic bags, straws, single-use plastic cups 
• Single-use plastic containers, tableware, and cutlery 
• Styrofoam cotton swabs, balloon sticks, and stirrers 
• Styrofoam food packaging 
• Microplastics in cosmetic products    

The new regulation distinguishes between consumption or consumption on-site and consumption on the go, resulting in slightly different interpretations for trade and gastronomy. The Dutch government sets guidelines for the surcharge that consumers must pay for single-use plastic products. For instance, the proposed surcharge for cups is 25 cents per cup, 50 cents per meal, and five cents for small storage containers.

Consumers pay an additional fee for single-use containers with plastic content for ready-to-eat meals at places like supermarkets, bakeries, or kiosks where on-site consumption is not provided. The amount of the surcharge can be determined by the respective companies. However, the costs must be listed separately on the receipt so that consumers can clearly see what they are paying for the use of single-use plastic products. There is no additional fee for containers with food that are not directly ready to eat and, for example, need to be heated before consumption. 

If on-site consumption is offered, single-use containers with plastic may not be provided. Instead, retailers must offer a reusable option or allow customers to bring their own containers.

For on-site consumption, it is prohibited for restaurateurs to provide single-use containers made of plastic. Instead, reusable tableware must be used or the use of customers’ containers must be offered. 

However, for takeaway or delivery of food, single-use containers can be used as long as customers pay an additional fee for the containers. Again, the surcharge must be listed separately on the bill. Alternatively, reusable alternatives with a return system or customers’ containers can also be used here.

Since 2024, the ban on single-use plastic also applies to corporate canteens, offices, or institutions. Washable tableware must be used here. Alternatively, reusable containers or customers’ containers can also be used. An exception is made for healthcare facilities such as hospitals.

With these measures, the Netherlands is implementing the EU directive to reduce single-use plastics. The measures are intended to reduce the large amounts of single-use plastic waste and strengthen the use of reusable alternatives. In the long term, this should protect the environment and strengthen the use of recyclable materials.

The plastic levy is a way of reducing the environmental risks posed by plastic pollution. In the EU, the focus is on plastic packaging waste. The so-called plastic levy has therefore been in place since 2021. This obliges all EU member states to make a payment based on the amount of non-recycled plastic waste produced in each country. The plastic levy is intended to create an incentive to reduce plastic waste. At the same time, it serves as funding for the EU budget until 2027.

The amount of the plastic levy is 0.80 euros per kilogramme of non-recycled plastic packaging waste. Every member state is obliged to pay this levy. However, it is up to the Member States to decide how to finance this levy. There are still no EU legal requirements for the national organisation. Some pay the levy from their national budgets, while others have introduced taxes, fees or contributions for certain plastic products in their countries and thus pass the levy on to consumers and the private sector.

The two terms are often used interchangeably. However, the plastic levy is an EU-wide method for calculating the contributions to the EU budget that each EU member state must make. The term plastic tax, on the other hand, refers to the refinancing of the plastic levy at national level. This is not subject to any EU directives. The individual member states have the freedom to organise this. A plastic tax is therefore not levied in every country.

In order to be compliant when selling goods and packaging abroad, companies must always be aware of the latest developments in their export countries. Whether a plastic tax applies to retailers or producers varies greatly from country to country. The structure of the tax also differs at national level, which can result in billing and pricing implications for companies. For example, it is necessary to consider which materials or products fall under the respective tax regulations and in which part of the supply chain they are taxed. All of this requires financial and human resources, which can be a hurdle for small companies in particular.

While some EU countries focus exclusively on packaging, i.e. both plastic and non-plastic packaging, others draw stricter boundaries and only tax single-use or non-reusable plastics. The origin of the plastics or packaging also plays a role in taxation, depending on the country. In some member states, for example, a tax is levied on plastic products originating both domestically and abroad, while in others only foreign plastic products are taxed.

Here we explain what these regulations actually look like in some EU countries:

Germany is currently planning to introduce a plastic tax for manufacturers and importers of single-use plastic packaging. However, it is not yet known when a draft law will be available.

However, according to the Disposable Plastics Fund Act (EWKFondsG) adopted in 2023, manufacturers and importers will be obliged to make a contribution to a central fund from 1 January 2025. The contribution is calculated based on the quantities of single-use plastic put into circulation by the respective companies in 2024.

There are currently no finalised plans for a plastic tax in France. Here, the national budget finances the plastic tax.

More information on France can be found here.

The introduction of a plastic packaging tax was already planned in Italy for 2020. After several postponements, it is now set to come into force in 2024. The plan is to levy a tax of €0.45 per kilogramme on single-use plastic products, known as “manufatti con singolo impiego” (MACSI). Exceptions are to be made for single-use plastic products that are compostable or used for medical purposes. Companies that manufacture these products in Italy or supply them to Italy from other member states are to be taxed. Companies without a registered office in Italy must appoint a (jointly and severally liable) tax representative in Italy to fulfil their obligations.

There are currently no finalised plans for a plastic tax in the Netherlands. However, the introduction of a plastic tax to finance the plastic levy is being examined.

In the Netherlands, however, a contribution that is not considered a tax is levied on plastic packaging. Companies that import 50 tonnes or more of plastic packaging onto the Dutch market each year or dispose of these quantities after importing them pay a regular rate of 1.05 euros. A reduced rate of 0.79 euros per kilogramme applies to companies whose plastic packaging has a positive market value and can be properly sorted and recycled.

Poland does not yet have a plastic tax for companies. However, in order to avoid packaging waste, a recycling fee law has been in force since January 2018.

In March 2023, the Polish parliament also passed a law to implement EU Directive 2019/904/EU on reducing the impact of certain plastics on the environment. The aim is to reduce the amount of single-use plastics on the Polish market through reporting obligations, product-related fees and annual levies. The obligations mainly apply to companies that introduce products to the Polish market for the first time.

Foreign companies that import single-use plastics to Poland can appoint an authorised representative to fulfil the obligations in connection with the marketing of their products.

A tax on non-reusable plastic packaging products has been in force in Spain since 2023. Among other things, this implements the EU directive on single-use plastics in Spanish law. This is intended to curb the production and use of plastic products. The tax of 0.45 euros per kilogramme applies equally to the manufacture, import and intra-Community purchase of non-reusable plastic packaging. This includes single-use packaging with plastic, semi-finished plastic products for single-use packaging containing plastic and products containing plastic that enable single-use packaging to be placed on the market. Recycled plastic, packaging used for the protection, manipulation, distribution and presentation of specialised medical, agricultural and veterinary products and plastic packaging exported directly from a manufacturer to another Member State or outside the EU are exempt from the tax. In addition, however, a tax is levied on the incineration and landfilling of waste.

Further information on Spain can be found here.

Among other things, the plastic levy serves to protect the environment and promote the circular economy. However, due to the current lack of EU-wide guidelines for implementing this levy, it has unfortunately also created a patchwork of regulations and legislation that can present a hurdle for internationally active retailers and companies when selling their products. Companies that operate in more than one EU member state must therefore carefully check the nationally applicable regulations.

As the plastic tax is currently being discussed in many countries, companies should already consider it in their business strategies and assess the potential impact. Flexible, resource-saving packaging solutions can be a first approach.

All manufacturers of packaging are obliged to join or establish a recognised Producer Responsibility Organisation (PRO). The activities of these organisations must be approved by the Swedish Environmental Protection Agency.Producers must also register with the Swedish Environmental Protection Agency and participate in a take-back system.

Since 1 January 2024, municipalities and local authorities have assumed operational responsibility for the collection of packaging waste from households and selected businesses. They play a key role in providing information on preventive measures and the correct sorting of packaging waste. By 1 January 2027 at the latest, all municipalities must introduce a door-to-door collection system for packaging waste. Collection will be based on material types such as paper, plastic, metal and glass. In addition, bulky packaging waste and materials such as wood, ceramics and textiles must be collected at accessible collection points or municipal recycling centres.

The updated regulation also includes provisions for deposit systems as applied to bottles and cans. Responsibility for these systems has been transferred from the Swedish Board of Agriculture to the Swedish Environmental Protection Agency from 1 January 2023. Existing systems can retain their approval until 1 January 2027, after which they will be reassessed in accordance with the new guidelines.

These extensive changes emphasise Sweden’s commitment to environmental protection and recycling. For companies that sell products to end customers in Sweden, it is crucial to be aware of the new responsibilities and act accordingly.
The EPR Sweden 2024 regulation represents not only a change, but also a significant step in terms of packaging responsibility that will contribute significantly to reducing the environmental impact.