How packaging is affected by the EU Green Deal

The European Green Deal is a comprehensive strategy to make the EU climate-neutral by 2050. Its legislation is highly relevant for packaging managers, as it has a significant impact on material choice, production processes and the entire supply chain.

Relevant legislation and guidelines

The most relevant laws for distributors of products

Packaging and Packaging Waste Regulation


The PPWR aims to reduce the environmental impact of packaging and increase recycling rates. It includes measures to reduce packaging waste, defines specific recycling targets and promotes the design of recyclable packaging. The PPWR also provides for extended producer responsibility, whereby manufacturers are responsible for the collection and recycling of their packaging. Overall, the regulation supports the creation of a circular economy, harmonises standards in the EU and raises awareness of sustainable packaging solutions.

Single-Use Plastic Directive


Single Use Plastic Directive (SUPD) The aim of the directive is to significantly reduce pollution caused by petroleum-based single-use plastics. In addition, the implementation of the SUPD is primarily intended to promote circular approaches such as recycling and sustainable reusable packaging solutions. The SUPD affects a total of 15 single-use plastic products, which are addressed by a range of measures - including bans, consumption reduction targets, labelling requirements and extended producer responsibility.

  • Implementation status: In force since 2 July 2019; transposition by member states by 3 July 2021; full application of collection and reduction targets by 2024/2025
  • Area of application: disposable plastic articles (cutlery, plates, drinking straws, cotton buds, etc.)
  • Link to the law:  https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX:32019L0904

German Packaging Act


The Packaging Act regulates the responsibilities and obligations when dealing with packaging. Manufacturers and distributors must participate in a dual system that ensures the collection and recycling of packaging. The costs for the collection, sorting and recycling of packaging waste are borne by the distributors. In accordance with Section 21, the systems are obliged to create incentives to make packaging more sustainable by promoting packaging that is as recyclable as possible, the use of recyclates and the use of renewable raw materials.

  • Implementation status: In force since 1 January 2019; current amendment (VerpackG3) since 16 May 2023
  • Scope of application: Sales, outer and shipping packaging in Germany
  • Link to the law: https://www.gesetze-im-internet.de/verpackg/

Ecodesign for Sustainable Products Regulation


The ESPR is intended to make sustainable product design the norm. The aim is to reduce the environmental footprint of products over their entire life cycle by setting binding criteria for durability, reparability, recyclability and energy efficiency. In addition, a Digital Product Passport (DPP) is to be introduced for various products to provide consumers with transparent information on environmental compatibility. The ESPR extends existing ecodesign regulations from energy-consuming appliances to almost all products in order to promote the transition to a circular economy, conserve resources and contribute to achieving the European climate targets.

  • Implementation status: In force since 18 July 2024; staggered requirements per product category
  • Scope: Durable products, including packaging machines and materials
  • Link to the law: Regulation - EU - 2024/1781 - EN - EUR-Lex

Empowering Consumers for the Green Transition Directive


The ECGT empowers consumers in the ecological transition by prescribing clear, reliable information on the durability, reparability and environmental/social characteristics of products. It complements and strengthens the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive, prohibiting greenwashing, misleading sustainability logos and practices such as planned obsolescence. Companies must substantiate environmental claims and make their guarantee more visible

  • Implementation status: In force since 27 March 2024; transposition until 27 March 2026; application from 27 September 2026 energy.ec.europa.euloc.gov
  • Scope: Consumer protection for sustainable products and packaging
  • Link to the law: Directive - EU - 2024/825 - EN - EUR-Lex

EU Deforestation Regulation


The EUDR is an initiative to combat deforestation and promote sustainable forest management. This regulation aims to ensure that raw materials and products placed on the EU market or made available for consumption or use, or exported from the EU, do not contribute to global deforestation. 

Relevant raw materials (e.g. wood, coffee, soya) and relevant products (e.g. virgin fibre, paper, folding cartons) may only be placed on the Union market or made available for consumption or use if, 

  • they are deforestation-free
  • they have been produced in accordance with the relevant legislation of the country of production, and
  • a declaration of due diligence is available. 

The EU Deforestation Regulation must also be applied to exports of the above-mentioned product groups to third countries. There should be one person in each supply chain who, as a market participant based in the Union, is responsible for compliance. 

EU Green Claims Directive - Proposal


The Green Claims Directive stipulates that companies must carry out a scientifically sound analysis of all significant environmental impacts and prove that their product fulfils the claim. An independent expert must verify the claim before a company is allowed to use it. Standardised eco-labels must be officially registered. 

  • Implementation status: The proposal was adopted in the EU in March 2023, the trilogue negotiations planned for end of June 2025 have been cancelled and the proposal is currently “on hold”.
  • Scope: Environmental and sustainability advertising for products and packaging
  • Link to the law: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023PC0166

How to avoid greenwashing?

General environmental claims
Statements such as ‘environmentally friendly’, ‘green’, ‘climate-friendly’ or ‘nature-friendly’ must be clearly explained and substantiated. For example, ‘biodegradable’ would have to be explained as meaning that packaging can be broken down in home compost within a month.

Misleading overall claim
An environmental claim for the entire product or company is misleading if it only refers to a specific aspect.

Advertising with legally binding characteristics (‘obvious facts’)
It is considered misleading if a claim presents legal requirements that apply to all products in a category as a special environmental achievement.

‘Own label’ without ’certification system’
It is forbidden to use a sustainability label that is not recognised by the state or based on an official certification system.

CO2-neutral claims based only on offsetting
CO2 neutrality claims based only on offsetting are misleading; real CO2 savings over the life cycle are required. 

Does the EUDR replace PEFC/FSC® certification?


According to Dr. Christian Foldenauer, Deputy Head of Regulatory Affairs BayPapier, PEFC/FSC® certification is a robust, effective tool to help companies fulfil EUDR due diligence obligations, in terms of risk assessment and risk mitigation. Certification or verification schemes may be used by supply chain members (e.g. operators or distributors) as part of their risk assessment, provided this certification covers the information needed to fulfil their EUDR obligations.

However, PEFC PEFC/FSC® certification alone is not sufficient. While certification can play a part in providing information on deforestation relevance (Art. 9) and risk assessment/mitigation (Art. 10/11), it does not release market participants and traders (who are not SMEs) from the obligation to submit due diligence declarations; they remain responsible for any violation.

In our view, FSC® will continue to provide a seal of environmental friendliness and sustainability for supply chain products through its (regular) certifications, which ensure customer confidence.

Request for free our: Checklist Future Ready Packaging

Where you should start now

Put your portfolio to the test

Are all your packaging and packaging components really necessary to protect products, ensure efficient logistics and communicate product characteristics?

Design for recycling is the top priority

If packaging is recyclable and its collection, sorting and recycling systems are in place, the foundation has been laid.

Data quality is decisive

Whether minimum standard, digital product passport or PPWR - every regulation is based on data that must be provided and networked by companies throughout the entire supply chain.

Standards make life easier

Whether calculating CO2 or assessing recyclability - defined methods, parameters and tolerances are required for solutions to be compared. Where these are missing, implementation is difficult.

Don't wait and see, get started!

Packaging is becoming a top priority. Not only does it embody the brand, it must also be compliant so that the products can continue to be placed on the market.

How we can support you

PERFORMANCE BASED DEVELOPMENT

Our developments are based on technical specifications and many years of experience from our development database. Technical specifications are essential for developing packaging that is as effective and efficient as possible. This applies to performance values such as BCT, ECT and Cobb value, as well as to application-specific barrier properties or recyclability.

RENEWABLE RECYCLED MATERIAL

Based on technical specifications, we determine the right material quality for the customer's requirements during the product development process. We focus on renewable raw materials, primarily wood fibres from responsible forestry (FSC© and PEFC™ certified), and we test alternative fibre sources such as grass, silphie, hemp, etc. We use paper and cardboard made from recycled fibres wherever possible and sensible.

MATERIAL EFFICIENCY | LIGHTWEIGHT

We select materials based on their technical values and save resources and CO2 with new papers and technologies. The focus is on using lightweight papers and custom flute profiles to achieve identical performance values with less material.

VOLUME OPTIMISATION

As much as necessary - as little as possible. This maxim guides us when developing custom packaging solutions. When it comes to volume optimisation, product protection and transport safety of the packaged goods are our top priorities.

DESIGN FOR RECYCLING

The aim is to maximise packaging and display recyclability and find alternatives for non-paper components or to eliminate them completely. High-quality material recycling via the recycling systems available throughout Europe is our top priority. We aim not only to use current state of the art technology but also to develop innovative solutions that extend today's possibilities.