What are the main EU rules on packaging design?

They also aim to remove barriers to trading between internal markets caused by EU countries adopting different rules on packaging and sustainability.

The EU Commission has been reviewing the requirements on packaging and packaging waste within the Packaging and Packaging Waste Directive, including assessing how to:

• improve packaging design to promote reuse and recycling
• increase recycled content in packaging
• tackle excessive packaging
• reduce packaging waste

Following a public consultation, which closed in January 2021, the Commission is progressing towards adoption in 2022 – stay posted for updates.

Both the European Green Deal and the Circular Economy Action Plan commit to reducing waste and making it easier for consumers to do the right thing regarding waste prevention and recycling.

It is also worth noting that a new definition of ‘recyclability’ is expected as part of the targeted revisions to the Waste Directive coming in late 2022 (for adoption in 2023), which lays down some basic waste management principles.

Standardising measurement of environmental performance

Under the Single Market for Green Products Initiative, the European Commission proposed the Product Environmental Footprint (PEF) and Organisation Environmental Footprint methods as a common way of measuring environmental performance.

This approach has been tested over many years, and the EU is looking at ways to incorporate it into policy.

PEF also considers packaging, and the first public consultation on the draft flexible packaging Product Environmental Footprint Category Rules (PCRs) and Representative Product study (PEF-RP study) closed on the 22nd February 2022.

Substantiation of environmental claims

The 2020 Circular Economy Action Plan foresees that the Commission will also propose that companies substantiate their environmental claims using the Product and Organisation Environmental Footprint methods.

These changes are part of a set of interrelated initiatives to establish a strong and coherent product policy framework that will make sustainability focused products, services and business models the norm and not the exception.

Ultimately, the intention is to completely transform our consumption patterns using design to drive out waste.

The Plastics Strategy is a key element of the Circle Economy Action Plan. It aims to transform the way plastic products are designed, produced, used and recycled. Within this is the Directive on Single Use Plastics (SUPD), which aims to prevent and reduce the impact of key single use plastic items via bans and new requirements for design and labelling.

Certain SUP must display a symbol to clearly identify that it is single use plastic to help consumers make more informed decisions.

Packaging manufacturers and brands: Companies producing or selling in the EU must comply with extensive requirements set out by the European Commission. Packaging must be the minimum amount required to ensure safe storage, which means that excessive overpackaging is not acceptable.

Product manufacturers: When developing and designing products, manufacturers must consider how to minimise impact at the end of life, design to limit waste and environmental damage, and consider reuse.

While designing for all stages of the packaging life cycle has been embedded in policy for decades, its visibility and enforcement have been missing. But that is changing fast. So, what can businesses do to prepare?

All businesses that design, specify, produce and fill packaging should have clear design and product sourcing guidelines in place to ensure the packaging they use meets legislative requirements now and in the future

Packaging producers need to ensure they’re up to speed with fast-changing policies that could affect the security of their business overnight

Governments are developing new and more holistic regulations to protect the environment and consumers. We hope they also start to factor in the social impacts of packaging, such as protecting the livelihoods of farmers growing natural materials, which has been absent to date.

We developed the Root Packaging Strategy because we recognise the importance of long-term planning to help mitigate policy risks to your business – now and in the future.

We talk about ‘getting it right from the start. If 80% of your product impact is defined at the design stage, you can draw up a robust sustainability plan that future-proofs your business for years to come.