What’s the EU Packaging Directive?
Just as Germany has its German Packaging Act, other countries have their own national packaging laws. These are based on the EU Packaging Directive (Directive 94/62/EC) and its amendment, Directive (EC) 2018/852 of 4 July 2018. The Directive then had to be transposed into national law in each EU Member State. As a result, the basis of packaging legislation is the same in all EU countries, but the details and how it is implemented, vary from country to country, resulting in different rules.
This means that when you place packaged products on the market abroad (e.g., by selling them), you have to comply with national laws and regulations – and these may vary greatly.
Packaging licensing in Europe: the challenges
- Many different laws, directives, regulations, etc..
- Often only available in the local language.
- Reporting frequency and calculation models can vary.
- Different types of take-back obligations for packaging.
- Different labelling and information obligations.
- Penalties for non-compliance.
- Sometimes annual changes in the legislation in individual EU Member States.
- What’s more, new regulations have been introduced as a result of the EU’s Single Use Plastics Directive, which must be implemented in each country.
Packaging licensing in Europe: Who is affected?
Packaging licensing in Europe: One model – many options for you
Do you sell products to other European countries?
Make sure you are compliant!
Which countries does our service cover?
- Belgium
- Bulgaria
- Denmark
- Estonia
- Finland
- France
- Greece
- Ireland
- Italy
- Croatia
- Latvia
- Lithuania
- Luxembourg
- Malta
- Macedonia
- Netherlands
- Norway
- Austria
- Poland
- Portugal
- Romania
- Sweden
- Switzerland
- Serbia
- Slovakia
- Slovenia
- Spain
- Czech Republic
- UK
- Hungary
- Cyprus
Examples
France
- Different types of reporting
- Obligation to register
- Labelling obligation (Triman logo with sorting information)
- Information obligation
- Online marketplaces require registration number
Austria
- Different types of reporting
- Registration with ministry
- Appointment of authorised representative
- Information obligation
Other services
Sorting information: If you do not have your own graphic design department and need our assistance, we will be happy to design a label for that country as a separate service.
Implementing your obligations for printing paper in France: In addition to packaging, France also has regulations concerning printing paper. Producers have to register and may have to pay fees. Our EU service covers this too!
Combined strength: 1 team – 31 countries
Our packaging licensing team for Europe
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FAQs on packaging licensing in Europe
What is the EU Packaging Directive?
The EU Packaging Directive is a piece of European Union legislation. The EU Packaging Directive (Directive 94/62/EC) and its amendment, Directive (EU) 2018/852 of 4 July 2018 regulate packaging management in EU Member States.
Can you extend the licensed reporting of packaging volume to include the packaging volume that you place on the market abroad?
No, you can’t! Licensing through a dual system in Germany, such as Noventiz, only covers the packaging volume placed on the market in Germany. If you sell packaged products abroad, you must obtain a licence in the respective countries.
Do you need to register or obtain a licence even if you just sell small quantities abroad?
This depends on the laws of the country concerned. Some countries apply a de minimis limit, above which registration and licensing is mandatory. In the majority of countries, the licensing or registration obligation starts with the first gram of packaging, which means that even initial distributors of minimal quantities must register and license their packaging.
Is the price of registration the same in all countries?
No, it isn’t! This is because each country has different registration and licensing requirements. In some countries, registration is free of charge, but most countries charge a registration or administration fee, or they may even require an authorised representative, which adds to the cost. Our contract service provides full and transparent information.
Is the price by packaging volume the same in every country?
No, it isn’t! The calculation of the licence fee varies between countries, as does the price per tonne of each type of material. This is because the responsible take-back schemes are based on different calculation criteria. As in Germany, the price can vary according to the type of material and the mass. It may also depend on the design of the packaging. In some countries, there are additional costs for administration, registration and authorised representation. Our contract service provides full and transparent information.
Is there an additional fee for Noventiz in addition to the licensing fee for a country?
No, there isn’t! You only pay the service fee per country as specified in your contract. We do not charge an additional fee for invoices from foreign waste management companies – we simply forward them to you once we have checked them.
Is there a labelling obligation that applies to all European countries?
There is no universal labelling obligation for EU countries. Currently (June 2023) the following labelling obligations apply to packaging in Bulgaria, France and Italy:
France: Sorting information is mandatory; this consists of the Triman logo and the packaging and disposal pictogram to be created for the specific packaging.
Italy: The label depends on the target group of the packaging. The alphanumeric code of the respective packaging material must always be indicated. Packaging for final consumers (B2C) must be labelled with information on the separate waste collection in Italian.
Bulgaria: Similar to Italy, in Bulgaria packaging must bear an alphanumeric code. It must also bear the Möbius strip and the Tidyman pictogramme.
We will be happy to advise you on the labelling obligations that apply to you, and provide the correct sorting information as a separate service.
Is there an obligation to use the Green Dot?
No, there isn’t! As of 1 January 2023, the Green Dot is also no longer required in Spain.
What happens if a business does not meet its obligations in a country, for example, by not being able to present a registration?
Each country has its own set of sanctions, which vary in scope and nature, depending on the severity of the non-compliance. It can range from a warning letter to a five-figure fine. In the worst case, a company may be banned from continuing to sell products in that country.