What are the latest developments? We’ve picked out some highlights for February 2025:
PPWR published in Official Journal
Batteries and electronics: EU Ministers tackle EPR free-riding by online marketers
E-waste: amendments to EU waste shipment legislation officially published
Packaging: EU action against Spain over waste separation labelling
PPWR published in Official Journal
On 22 January 2025, the European Union published the final version of the Packaging and Packaging Waste Regulation (PPWR) in the Official Journal.
The new regulation will officially enter into force on 11 February 2025, with its general provisions becoming applicable 18 months later, on 12 August 2026.
The PPWR replaces the previous Packaging and Packaging Waste Directive (PPWD) and introduces new rules for the entire lifecycle of packaging.
Recyclability and reusability
A key objective of the PPWR is to make packaging more recyclable and reusable. By 2035, all packaging within the EU must be easily recyclable, with harmonised standards for sorting and processing materials into secondary raw materials.
A grading system, ranging from A (most recyclable) to C (least recyclable), will be introduced to incentivise manufacturers to prioritise recyclable materials in their packaging.
Labelling
The regulation also establishes mandatory packaging labels detailing material composition to aid recycling. Labels must display pictograms and QR codes, indicating whether the packaging is compostable, part of a deposit return system or reusable. Harmonised waste receptacle labelling will be required across the EU by 2028.
EPR fee modulation
The PPWR further introduces harmonised criteria for EPR fee modulation, with respect to the efficiency of the internal market.
Recycling targets
The regulation also sets clear targets for recycling different materials, including plastic, glass and paper, aiming for 65% recycling of all packaging waste by 2025 and 70% by 2030.
PFAS
The PPWR will also introduce restrictions on packaging containing harmful substances, such as per- and polyfluoroalkyl substances (PFAS), and will require packaging labels that inform consumers about recyclability.
Recyclates
A minimum recycled content requirement for plastic packaging will be introduced by 2030, boosting the market for recyclates.
The requirements in the PPWR will be further specified in harmonised standards for packaging, guidelines, and the subsequent adoption of implementing and delegated acts.
Please contact us here if you have questions about the PPWR.
Batteries and electronics: EU tackles EPR free-riding by online marketers
EU Member States are calling for action against “free-riding” in e-commerce, where online sellers bypass their extended producer responsibility (EPR) obligations.
At the December meeting of the Environment Council, several Member States voiced concerns over third-country suppliers who sell products like batteries, electronics and packaging in the EU without contributing to waste management or meeting legal requirements.
Countries like the Czech Republic reported losing tens of millions of euros annually in EPR contributions, while a letter by the Czech Republic, Denmark, France, and Slovakia estimated overall losses in customs duties to be in the hundreds of millions. These losses undermine waste management funding and give non-compliant sellers an unfair advantage.
To level the playing field, these Member States are urging the European Commission to address the issue.
Existing laws, such as the Batteries Regulation and Digital Services Act (DSA), already demand registration and verification for online sellers. However, enforcement remains difficult, particularly for small shipments from outside the EU.
Czech Environment Minister Petr Hladík noted that more than half a million producers alone are registered on one Chinese platform.
Austria’s Minister Leonore Gewessler also called for targeting very large online platforms (VLOPs), calling free-riding “a matter of survival” for EU businesses.
Germany also stressed the importance of consistent enforcement to ensure fair competition within the EU’s internal market.
EU Environment Commissioner Jessika Roswall referred to the DSA’s requirement for third-country companies to establish a branch or legal representative in the EU, and is committed to harmonising registration and improving collaboration with national authorities and EPR organisations. However, she also highlighted the need for a “structured” approach, balancing enforcement with practicality.
E-waste: amendments to EU waste shipment legislation officially published
On 20 December 2024, the European Union formally adopted amendments to its Waste Shipment Regulation (WSR), publishing the new rules in the Official Journal.
These updates align the EU’s e-waste shipment rules with recent changes to the Basel Convention and came into effect on 1 January 2025.
Non-hazardous e-waste can no longer be exported to non-OECD countries and is now classified under the new Y49 category. Hazardous e-waste exports to these destinations were already banned. Any shipments to or from countries outside the EU now need prior written notification and consent.
Within the EU, transitional rules allow non-hazardous e-waste to move freely without notification or consent until 31 December 2026.
During this time, two existing categories, GC010 (metal electrical assemblies) and GC020 (electronic scrap like circuit boards), will remain in force. By 2027, stricter notification and consent requirements will apply to all e-waste shipments, supported by a new online platform, the Digital Waste Shipment System (DIWASS).
These new rules are expected to have significant implications across various industries, as they restrict traditional export routes and require adjustments to existing recycling and waste management practices. The European Electronics Recyclers Association (EERA), for example, has expressed concerns about rising costs for recycling fridges and freezers.
Until now, compressors from these appliances were often sent to Pakistan for recycling, where manual processing achieved higher material value. However, these exports are no longer allowed because Pakistan lacks the licensed facilities needed to meet EU rules.
Packaging: EU proceedings against Spain over waste separation labelling
The European Commission has initiated legal proceedings against Spain over its packaging label requirements for waste separation (INFR(2024)4009).
Following similar action against France’s “Triman” logo, the Commission announced in December 2024 that Spain’s rules may disrupt trade within the EU single market.
“National labelling requirements can pose significant barriers to the single market and undermine the principle of free movement of goods,” the Commission stated.
The action targets Spain’s Royal Decree on Packaging, which from January 2025 mandates labels on household packaging indicating how it should be disposed of into one of four waste categories. Reusable packaging must also display the symbol of its return system. Although Ecoembes, an industry organisation, has created pictograms to help companies comply, businesses are not obligated to use specific symbols.
The Commission argues that Spain’s rules conflict with Articles 34 to 36 of the Treaty on the Functioning of the European Union (TFEU), which require Member States to adopt less restrictive measures when available. Brussels believes Spain has not adequately analysed whether its requirements are proportionate.
When Spain implemented its labelling rules, no harmonised EU-wide standards for packaging existed. However, the recently adopted EU Packaging and Packaging Waste Regulation (PPWR) now provides a framework for such measures.
The Commission emphasised that until the EU-wide standards take effect, national laws should not unnecessarily burden intra-EU trade, as work on the harmonised system is already underway.
Spain has two months to respond to the Commission’s letter. If its reply is deemed insufficient, the Commission may issue a formal opinion, followed by potential proceedings at the European Court of Justice (ECJ).
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