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EPR for Packaging in the EU: Insights from France, Germany, Italy, the Netherlands, and Sweden

The implementation of Extended Producer Responsibility (EPR) for packaging has become a critical component in the European Union’s efforts to enhance sustainability and reduce waste. As the EU continues to grapple with increasing environmental challenges, effective waste management practices have become paramount. Central to this strategy is the Directive on Packaging and Packaging Waste (PPWD). Since its introduction in 1994, the PPWD has significantly enhanced recycling and recovery rates in the EU and mandates that all Member States establish EPR schemes for packaging by the end of 2024 to meet its targets.

EU Target Recycling Rates by Weight of Packaging Waste

While the PPWD establishes a framework for EPR implementation, the autual implementation varies across Member States. This article examines the national regulations developed in five representative countries in alignment with the EU’s harmonized directives and summarizes the supervisory mechanisms in place for packaging EPR in these nations. Furthermore, it is important to note that the schemes and management methods discussed may evolve due to the forthcoming Packaging and Packaging Waste Regulation (PPWR).

  1. France

In France, mandatory EPR requirements apply to household packaging and packaging used in the catering industry. Starting in 2025, industrial and commercial packaging will also fall under these requirements. Notably, the TRIMAN mark is mandatory for all product types and must be displayed on all waste, including packaging waste.

  1. Germany

EPR requirements in Germany are mandated by the Packaging Act, which applies to all types of packaging, including product, secondary, shipping, and service packaging.

Most enterprises participate in one or more systems as required by the Packaging Act. Limited exceptions exist for opting for an industry solution under specific conditions. Participating enterprises must register with the Central Agency for Packaging Registration (ZSVR) in the LUCID packaging register to obtain their EPR number.

  1. Italy

Italian EPR schemes are generally organized collectively through PROs. All companies producing and using packaging must adhere to the national PRO, the National Packaging Consortium (CONAI), which coordinates the activities and guarantees recovery results across six consortia: steel (Ricrea), aluminium (Cial), paper/cardboard (Comieco), wood (Rilegno), plastic (Corepla), bioplastic (Biorepack), and glass (Coreve).

  1. Netherlands

The Netherlands has set a threshold to relieve the burden on small businesses. Producers placing 50,000 kg or less of packaging on the market annually are exempt from certain reporting obligations and waste management contributions.

  1. Sweden

In Sweden, while labeling packaging is not mandatory, if companies choose to label their packaging, it must comply with Commission Decision 97/129/EC. Sweden has increased mandatory labeling requirements for certain packaging, such as plastic bottles and metal cans included in a return deposit system.

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