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EU Packaging Regulations and How They Affect Coil Exports

Navigating the intricate landscape of EU packaging regulations is crucial for businesses exporting coils. The regulations surrounding packaging and packaging waste are undergoing significant changes, impacting the design, materials, and recyclability of packaging materials used for coil exports.
The European Union’s evolving packaging regulations, particularly the Packaging and Packaging Waste Regulation (PPWR), significantly impact the export of goods, including coils, to the EU market. Understanding and adapting to these regulations is essential for ensuring continued market access and compliance. This article breaks down the key aspects of the PPWR and other relevant EU legislation, highlighting their implications for coil exporters.

The EU Packaging and Packaging Waste Regulation (PPWR): A Paradigm Shift

The PPWR, formally published as Regulation (EU) 2025/40 and slated to apply broadly from August 12, 2026 (with some provisions having different timelines), marks a shift from the previous Packaging and Packaging Waste Directive (94/62/EEC). The transformation from a directive to a regulation is intended to enhance harmonization across EU Member States. Unlike directives, which allow national authorities flexibility in implementation, regulations are directly effective throughout the EU.
This means greater consistency in areas like Extended Producer Responsibility (EPR) schemes and environmental labeling, reducing the complexity for businesses operating across multiple EU countries. The overarching goals of the PPWR are ambitious: to reduce packaging waste, to boost high-quality recycling through closed-loop systems, and to curtail the usage of primary natural resources.
Key Changes Introduced by PPWR

Substances of Concern: The use of harmful substances in packaging is coming under increasing scrutiny. The PPWR restricts the use of PFAS in food packaging from August 12, 2026. Also, the regulation maintains restrictions on heavy metals such as lead, cadmium, mercury, and hexavalent chromium.
Recyclability: A core principle of the PPWR is that all packaging must be recyclable. The EC will adopt delegated acts setting design for recycling (DfR) criteria and recyclability performance grades by January 1, 2028. Packaging below a 70% recyclability grade (Grade A, B, or C as defined in the PPWR) will not be considered recyclable. EPR fees will be linked to the performance grade to incentivize better recyclability.

Recycled Content: The PPWR mandates increased recycled content, especially in plastic packaging. Contact-sensitive packaging (including food packaging) will be subject to mandatory recycled content targets with different dates.
| Material | January 1, 2030 | January 1, 2040 |\n| :————————————————————— | :————– | :————– |\n| PET food packaging (except single-use plastic beverage bottles) | 30% | 50% |\n| Food packaging – plastics other than PET | 10% | 50% |\n| Single-use Plastic beverage bottles | 30% | 65% |
Packaging Minimization: Packaging should be reduced to the minimum necessary for functionality by January 1, 2030, by optimizing the weight and volume considering the material from which the containers are made and not be increased to cause an illusion of larger perceived product volume. The ratio of empty space in grouped, transport, or e-commerce packaging must not exceed 50%.
Restrictions on Packaging Formats: The PPWR bans certain single-use packaging formats from January 1, 2030.
Re-use and Re-fill Targets: The regulations will require business operators to participate in re-use systems. By January 1, 2029, Member States must establish deposit and return schemes (DRS) for certain beverage containers.
Declaration of Conformity: Manufacturers must perform a conformity assessment and maintain technical documentation for up to 10 years.
Environmental Labeling: The PPWR will introduce mandatory labeling requirements, including material composition, reusability, and QR codes for information on substances of concern (SoC).
Extended Producer Responsibility (EPR): Harmonization of EPR schemes is a key objective, requiring producers to register in each Member State where packaging is placed on the market.

Specific Implications for Coil Exporters

Coil exporters to the EU will face several specific challenges and requirements under the PPWR:

Design for Recycling (DfR): Coil packaging designs must prioritize recyclability. This means considering the materials used, the ease of separation of components, and compatibility with existing recycling infrastructure. Packaging materials must permit collection and waste stream disposal assignment without reducing the recyclability of other waste.
Meeting Recycled Content Targets: If plastic packaging is used, exporters must ensure that it meets the recycled content targets specified in the PPWR. This may require sourcing packaging materials from suppliers using recycled plastics.
Packaging Minimization: Coil exporters must optimize their packaging to minimize weight and volume without compromising product protection. Reducing empty space within transport packaging is particularly important. Ensure that the weight and volume, regarding the packaging material, are kept to a minimum to ensure functionality.
Labeling Compliance: Accurate and informative labeling is crucial. Labels must clearly indicate the material composition of the packaging to aid in proper sorting and recycling. They may also need to include QR codes or similar technologies for accessing information about substances of concern in the packaging material. This ensures correct disposal, recycling, and reuse.
EPR Compliance: Exporters must comply with EPR obligations in each EU Member State where their coils are sold. This includes registering with national EPR schemes, paying fees based on the amount and type of packaging used, and meeting reporting requirements. Every company that ships goods to European countries must use a representative to represent extended producer responsibility.
Choosing a Representative: The EU law requires any seller that doesn’t have a branch in a European country to appoint an authorized representative in each country where they sell goods. Not complying with this rule could lead to restrictions in the EU.

Other Relevant EU Legislation

In addition to the PPWR, coil exporters should be aware of other relevant EU legislation:

Single-Use Plastics Directive (SUPD): This directive targets pollution from single-use plastics, promoting circular approaches such as recycling and reusable packaging solutions. The directive covers 15 single-use products and applies a range of bans, labeling requirements, and reduced consumption goals.
EU Deforestation Regulation (EUDR): The EUDR aims to combat deforestation by ensuring that products marketed in or exported from the EU do not contribute to global deforestation. This is particularly relevant if wood packaging materials (e.g., pallets) are used. Virgin fibre and paper must be produced in accordance with the country’s laws and declared with due diligence.
General Environmental Claims: Marketing claims such as biodegradable or environmentally friendly must be clearly explained and substantiated. Carbon neutrality claims based solely on carbon offsetting will be considered misleading.

German Packaging Act (VerpackG): This regulates packaging responsibilities, requiring manufacturers and distributors to participate in a dual system ensuring packaging collection and recycling. Section 21 systems incentivize sustainable packaging by promoting maximum recyclability and the use of recycled materials.

Meeting the Challenge

Regulation	Requirement	Impact on Coil Exports
PPWR	Prioritize recyclability and recycled content	Packaging design and material selection, sourcing of recycled content.
PPWR	Reduced packaging size	Impact on void space in packaging materials for coil products.
Re-use and Re-fill Targets	Business operators must participate in systems for re-use and re-fill	Compliance with the re-use and re-fill packaging materials within the HORECA sectors.
SUPD	Reduced consumption of Single-use plastics	Packaging for coil products has to be made of recycled products.
EUDR	Certification and regulatory standards compliance	Due diligence for wood packaging materials, supply chain transparency.

Meeting the requirements of the PPWR and other related legislation requires coil exporters to take proactive steps:

Assess Packaging: Evaluate current packaging materials and designs to identify areas for improvement in terms of recyclability, recycled content, and minimization.
Collaborate with Suppliers: Work closely with packaging suppliers to source compliant packaging materials that meet recycled content targets and design for recycling criteria.

Implement Labeling Solutions: Ensure that packaging is accurately and informatively labeled, complying with the PPWR’s requirements for material composition, reusability, and substances of concern.
Prioritize Design for Recycling: Redesign coil packaging to ensure that all materials are easily recyclable and compatible with existing recycling infrastructure.
Register with EPR Schemes: Comply with EPR obligations in all relevant EU Member States by registering with national schemes and meeting reporting requirements.
Stay Informed: Continue researching the upcoming regulations to ensure understanding of the laws and ensure the latest information.
Comply with Due Diligence: Companies must provide accurate certifications and guarantees, especially regarding conflict wood for EUDR.
Investigate Registration: Companies can determine where they have to register and what the requirements are.
Check Contracts: Companies can ensure they are able to meet all requirements when it comes to certification.
By addressing these points, coil exporters can navigate the complexities of EU packaging regulations and ensure long-term market access. Proactive adaptation benefits the environment and strengthens a company’s position within the evolving landscape of sustainable trade.