European packaging legislation and the role of the authorized representative

Die Verpackungsgesetzgebung in Europa: Wo brauche ich einen Bevollmächtigten?

The changes to the Austrian Packaging Ordinance are currently also attracting a great deal of interest among German retailers. The main reason for this is a significant innovation: since 1 January 2023, foreign retailers who ship products to Austria and do not have a branch there must appoint an official authorized representative. However, this requirement is not only valid in Austria; similar regulations also exist in other EU countries. We shed light on the countries in which the appointment of an authorized representative is required for shipping and what consequences this has for you.

As an online retailer who ships goods across German borders, you may be faced with the question of how to comply with the different packaging laws in Europe. This question is complex, as the EU Packaging Directive is implemented differently in each EU country. This leads to a variety of processes and requirements. Many of these laws have recently been revised and additional regulations have been added. An increasingly common aspect in these laws is the need to appoint an authorized representative for foreign distributors.

Definition and procurement of an authorized representative

A proxy is a person or organization authorized by an official power of attorney to perform specific tasks on behalf of another person. This power of attorney is a written document that confirms that the person or organization in question (your proxy) may act on your behalf. In most countries, any natural or legal person who is resident in the country in question, has a local address and has been appointed by means of a notarized power of attorney can act as proxy.

The search for a suitable proxy can be complicated. We offer a licensing service, through which we can take care of all of the compliance in the respective countries for you.

Requirement of an authorized representative in various countries

For shipping to certain countries, including Austria, Slovenia, Portugal, Greece and Slovakia, it is necessary to appoint an authorized representative. Let’s take a closer look at the requirements in these countries.

Austria

Since the Packaging Ordinance in Austria was updated on January 1, 2023, retailers who do not have a place of business in Austria must appoint an authorized representative for shipments to this country. This regulation affects you if you deliver packaging materials to consumers in Austria. As a foreign company, you must ensure through your authorized representative that you comply with the requirements of the Austrian Packaging Ordinance. Since January 1, 2023, it is no longer possible for companies that are not based in Austria to carry out licensing independently.

Required Measures:

  • Appointment of an authorized representative in Austria.
  • Keeping records of the packaging materials distributed in Austria.
  • Transmission of the packaging quantities to your authorized representative (annually up to 1,500 kg, quarterly up to 20,000 kg, monthly over 20,000 kg).
  • Payment of the fees for the authorized representative and for disposal.

Slovenia

In Slovenia, an important regulation based on an amendment to the Environmental Protection Act came into force on April 24, 2021. This regulation, issued by the Slovenian government, stipulates that all foreign companies that sell packaging on the Slovenian market must appoint a local authorized representative. This authorized representative is then responsible for ensuring compliance with the take-back obligations. This regulation applies regardless of the quantity of packaging put into circulation. Please note that an additional environmental levy must be paid from an annual quantity of 15 tons.

Required Measures:

  • Appointment of an authorized representative in Slovenia.
  • Keep accounts of the packaging quantities put into circulation in Slovenia.
  • Quarterly reporting of packaging quantities to the authorized representative.
  • Payment of disposal fees (licensing) and fees for the authorized representative.

Portugal

In Portugal, the environmental authority APA has tightened the regulations on packaging with effect from January 1, 2022 by introducing the mandatory appointment of an authorized representative for all packaging. This regulation particularly affects non-Portuguese manufacturers who sell their products directly to private end consumers in Portugal. In this case, all relevant obligations must be fulfilled by the authorized representative.

Required Measures:

  • Appointment of an authorized representative in Portugal.
  • Documentation and tracking of the quantities of packaging put into circulation in Portugal.
  • Annual reporting of packaging quantities to the authorized representative.
  • Payment of the fees incurred for the authorization and for the take-back system.

Greece

A new law came into force in Greece on July 1, 2021, replacing the previous regulations from 2001. Since then, non-Greek retailers who ship goods to Greece are also obliged to register with the Greek take-back system. For companies without a registered office in Greece, the appointment of an authorized representative is also required.

Required Measures:

  • Appointment of an authorized representative in Greece.
  • Documentation of the quantities of packaging put into circulation in Greece.
  • Annual transmission of the packaging quantities to the authorized representative.
  • Payment of the costs incurred by the authorized representative and for disposal.

Slovakia

As of January 1, 2022, foreign mail order companies that do not have a registered office in the Slovak Republic must process their obligations via an authorized representative. This authorized representative assumes responsibility for fulfilling all legal obligations and acts on behalf of the trader.

Required Measures:

  • Appointment of an authorized representative in Slovakia.
  • Documentation of the quantities of packaging placed on the Slovakian market.
  • Quarterly reporting of packaging quantities to the authorized representative.
  • Payment of the costs incurred by the authorized representative and for disposal.

Spain

A new law came into force in Spain on 27 December 2022, replacing the previous regulations. Since then, foreign traders without a registered office in Spain are obliged to appoint an authorised representative.

Measures required:

  • Appointment of an authorised representative in Spain.
  • Documentation of the quantities of packaging put into circulation in Spain.
  • Annual transmission of the packaging quantities to the authorised representative.
  • Payment of the costs incurred by the authorised representative and for disposal.

Summary and outlook

Packaging legislation remains an important and dynamic topic. The trend of more and more countries requiring the appointment of an authorized representative for foreign distributors is likely to continue. With the constant revision of legislation and the introduction of new control mechanisms in various countries, it remains an area where up-to-date information is crucial. We will continue to update this post to keep you up to date with the latest developments and requirements.

LIZENZERO.EU makes packaging compliance in Europe very easy.

Do you ship your products to different countries in the EU? Many different legal requirements and obligations can make the whole thing quite complicated – but don’t worry, we’ll do it for you. How do we do it? With our licensing service, we take over all obligations for you by power of attorney. Sounds good? We’ll be happy to advise you.

For shipping to Germany, you can easily fulfill your packaging obligations yourself via Lizenzero.de.

EPR systems for packaging in comparison: a country overview

EPR systems for packaging in comparison: a country overview

In the EU, retailers and manufacturers who place products on the market are subject to certain environmental responsibilities. Extended Producer Responsibility (EPR) is a way of obliging companies to take responsibility for the entire life cycle of their products. This includes not only the product itself, but also all packaging and (product) components put into circulation that are disposed of by end consumers. The exact areas covered by the EPR vary from country to country. In this article, we take a look at the EPR in the area of packaging and shed light on what exactly the requirements mean, how they are implemented in practice and how the requirements differ from country to country within the EU.

read more
When will Italy introduce the single-use plastic tax?

When will Italy introduce the single-use plastic tax?

The introduction of the single-use plastic tax in Italy was originally planned for July 2020. It has now been postponed for the sixth time and is due to come into force on 1 July 2024. The tax aims to tax single-use packaging and plastic products. In this article, we explain what legal changes retailers can expect for their shipments to Italy as a result of the introduction of the tax.

read more
EPR obligations in Poland: volume threshold and registration obligation

EPR obligations in Poland: volume threshold and registration obligation

Since 13 June 2013, the handling of packaging waste in Poland has been regulated by the Act on Packaging and Packaging Waste Management (Journal of Laws 2019.542). Among other things, it sets out requirements for packaging, the handling of packaging waste and regulations regarding recycling fees. This means that companies in Poland are subject to extended producer responsibility (EPR). The EPR regulations are intended to ensure that companies take responsibility for the disposal of their packaging and thus contribute to the promotion of the circular economy. The EPR entails obligations regarding the handling of a company’s own products and packaging. In the following article, we shed light on what you need to consider as a retailer on the Polish market.

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VAT in e-commerce and the one-stop store concept – an overview

Umsatzssteuer im E-Commerce

VAT in e-commerce and the one-stop store concept – an overview

VAT in e-commerce
VAT in e-commerce and the one-stop store concept

International deliveries play a crucial role in global economic growth, especially for the e-commerce sector. This aspect has also been recognised by the European Union, which is why it has adapted its tax regulations accordingly since July 2021. These adjustments not only entail the fulfilment of certain requirements, for example from the German Packaging Act (VerpackG) or the General Data Protection Regulation (GDPR), but also impose additional obligations on retailers who ship products to end consumers within the EU.

Would you like to find out more about what has changed since 1 July 2021? Then we have summarised all the relevant changes for you here, including a detailed explanation of the new one-stop shop procedure.

EU VAT rules for online retailers before July 2021

Before the introduction of new rules, online traders who sold their products to other European countries had to regulate VAT according to certain thresholds. These thresholds determined whether the tax was payable in the country of origin or the country of destination of the goods. Each EU member state set its own thresholds, which were usually set at an annual turnover of EUR 35,000 or EUR 100,000.

For example: A German online retailer who sold goods worth more than EUR 35,000 per year to France previously had to register with the French tax office and pay French VAT (20%). If the turnover was below this threshold, German VAT (19%, or at times 16%) was due.

In addition, imports from non-EU countries for goods under EUR 22 were exempt from tax until this date.

Since July 1, 2021, these provisions have largely been replaced by the VAT eCommerce package adopted in 2017 for all EU countries.

VAT eCommerce package: New EU VAT regulations since July 2021

Since July 1, 2021, a uniform EU sales threshold of EUR 10,000 (net) per year has replaced the delivery thresholds previously set individually by each EU country. This means that traders who exceed this threshold in an EU country must pay VAT in the respective country of destination.

In addition, traders who previously remained below the individual country turnover thresholds, but who have a total turnover of more than EUR 10,000 (net) throughout the EU, must pay tax on their products for cross-border B2C deliveries in the respective country of destination (for more information on the turnover threshold, see “Threshold regulation 2021“). A pan-European cumulative turnover threshold now applies. If a trader exceeds this threshold, they will be liable to pay tax in all EU countries in which they sell to private consumers. The previous tax exemption for goods under EUR 22 no longer applies, resulting in an increased tax liability for many retailers.

Example 1: A German retailer who sells exclusively to private customers in Spain and generates an EU-wide turnover of over EUR 10,000 must now pay Spanish VAT of 21% – previously it was 19%.

Example 2: If a German retailer sells to private customers in France, Spain and Italy and only exceeds the EUR 10,000 turnover threshold per year in Italy, they will still be liable for VAT in all three countries as the EU-wide threshold has been exceeded.

As VAT rates in EU countries vary between 17% and 27%, this change can significantly increase costs for many traders. To minimize the administrative burden caused by the need to register for VAT in each country of destination, the One-Stop-Shop (OSS) procedure has been introduced.

VAT E-Commerce Package

Regulations on the turnover threshold from 2021: Procedure until EUR 10,000 is reached

Until the EU-wide turnover threshold of EUR 10,000 per year is reached, entrepreneurs must pay tax on turnover from sales to other EU countries in the country of origin instead of in the country of destination of the goods.

Consideration of German sales in the new EU sales tax regulations

The regulations relate exclusively to sales generated outside Germany. Only cross-border sales within the EU are taken into account when reaching the EUR 10,000 threshold.

One-stop store procedure (OSS) after reaching the EUR 10,000 threshold

The Mini-One-Stop-Shop scheme (MOSS), introduced in 2015, was expanded to the more comprehensive OSS scheme for e-commerce in 2021. Online traders who exceed the EU-wide turnover threshold of EUR 10,000 can use the OSS procedure to declare their turnover in different countries. All EU-wide B2C sales of goods and services are recorded in the OSS system.

Traders can use this system to settle their entire VAT liability from different countries in a single payment. In Germany, the OSS system is administered by the Federal Central Tax Office, which then forwards the VAT paid to the relevant EU countries.

Participation in the One-Stop-Shop procedure is voluntary for traders, but offers considerable advantages and simplifications, especially for smaller traders. Without the OSS procedure, traders who exceed the turnover threshold would have to appoint a tax consultant or service provider for each destination country in order to fulfill the respective VAT obligations abroad. This would not only result in one-off registration costs, but also ongoing monthly costs. By using the OSS procedure, retailers can avoid this expense and conveniently report all sales online.

Particularities in e-commerce: Consideration of fulfillment services abroad

The current OSS procedure does not cover all online retail scenarios. Special cases, such as the use of fulfillment services abroad or sales via online marketplaces, cannot yet be fully integrated into the OSS procedure.

One example of this is the sale of a German online retailer via an Amazon program such as Pan EU or CEE. In such cases, the goods are often stored in a fulfillment center abroad, for example in Poland, and shipped to consumers from there. These processes lead to intra-Community transfers and acquisitions (B2B transactions), which cannot yet be mapped in the OSS procedure. In such cases, traders must either register for VAT directly in the destination country if they exceed the EUR 10,000 threshold, or in Germany if their total turnover in the EU is less than EUR 10,000.

Unchanged regulations for sales to non-EU third countries

The current regulations only apply to B2C sales of goods and services within the European Union. These changes do not apply to transactions with third countries outside the EU. This means that the VAT law of the country of dispatch applies to shipments from the EU to third countries. German VAT law therefore applies to shipments from Germany to non-EU third countries. Here it is particularly important to observe the obligation to provide evidence (further information is available).

LIZENZERO.EU makes packaging compliance in Europe very easy.

Do you ship your products to different countries in the EU? Many different legal requirements and obligations can make the whole thing quite complicated – but don’t worry, we’ll do it for you. How do we do it? With our licensing service, we take over all obligations for you by power of attorney. Sounds good? We’ll be happy to advise you.

For shipping to Germany, you can easily fulfill your packaging obligations yourself via Lizenzero.de.

EPR systems for packaging in comparison: a country overview

EPR systems for packaging in comparison: a country overview

In the EU, retailers and manufacturers who place products on the market are subject to certain environmental responsibilities. Extended Producer Responsibility (EPR) is a way of obliging companies to take responsibility for the entire life cycle of their products. This includes not only the product itself, but also all packaging and (product) components put into circulation that are disposed of by end consumers. The exact areas covered by the EPR vary from country to country. In this article, we take a look at the EPR in the area of packaging and shed light on what exactly the requirements mean, how they are implemented in practice and how the requirements differ from country to country within the EU.

read more
When will Italy introduce the single-use plastic tax?

When will Italy introduce the single-use plastic tax?

The introduction of the single-use plastic tax in Italy was originally planned for July 2020. It has now been postponed for the sixth time and is due to come into force on 1 July 2024. The tax aims to tax single-use packaging and plastic products. In this article, we explain what legal changes retailers can expect for their shipments to Italy as a result of the introduction of the tax.

read more
EPR obligations in Poland: volume threshold and registration obligation

EPR obligations in Poland: volume threshold and registration obligation

Since 13 June 2013, the handling of packaging waste in Poland has been regulated by the Act on Packaging and Packaging Waste Management (Journal of Laws 2019.542). Among other things, it sets out requirements for packaging, the handling of packaging waste and regulations regarding recycling fees. This means that companies in Poland are subject to extended producer responsibility (EPR). The EPR regulations are intended to ensure that companies take responsibility for the disposal of their packaging and thus contribute to the promotion of the circular economy. The EPR entails obligations regarding the handling of a company’s own products and packaging. In the following article, we shed light on what you need to consider as a retailer on the Polish market.

read more

Package labeling in Italy: A comprehensive guide

Die Kennzeichnungspflicht in Italien

Anyone shipping goods to Italy should definitely observe the labelling regulations there.

In contrast to Germany, where the Packaging Act (VerpackG) governs the handling of packaging materials, other European countries such as France and Italy have their own laws. In addition to the licensing of packaging, these often also require specific labelling tailored to the country in question.

Context of the labeling requirement in Italy

The labelling requirements in Italy are defined by Decree 116/2020. Since 1 January 2022, online retailers have been obliged to label product, shipping and transport packaging in Italy to ensure that it can be subjected to an efficient recycling process. In the Italian Packaging Act, these regulations consist of both mandatory requirements and voluntary recommendations.

The aim of the regulations is to ensure that recyclable packaging generated by Italian end consumers can be easily distinguished from other types of packaging. This enables consumers to dispose of it properly and thus promotes the recycling process. At the heart of the law is the endeavour to increase resource protection and improve the circular economy. In this way, Italy is contributing to more sustainable practices and the responsible use of packaging materials.

Requirements for the labeling of packaging

The regulations for different types of packaging have specific requirements in some cases. It is crucial to label packaging with easily recognisable disposal instructions for consumers. According to Directive 97/192/EC, the composition of the packaging materials must be indicated by an alphanumeric code. For this purpose, each component of the packaging must be labelled with a corresponding code and clearly visible disposal instructions. The consumer information should also be written in easily understandable Italian. In some cases, the required information on composition and correct disposal can also be provided via QR codes or websites. This enables flexible and modern implementation of the labelling requirements.

In order to facilitate the practical implementation of these regulations, the national packaging consortium CONAI has published a guide to the decree. For detailed steps and further information on the obligations in Italy, you can find the guide here.

The obligations at a glance:

  1. Labelling of packaging for private end users: Packaging that is disposed of by private end users must be clearly labelled with a clear disposal notice.
  2. Alphanumeric code according to 97/192/EC for packaging materials: The composition of the packaging materials is indicated by an alphanumeric code in accordance with Directive 97/192/EC.
  3. Comprehensible information in Italian: The information provided should be written in easily understandable Italian to ensure clear communication with consumers.
  4. Recommendation for individual labelling of material components: It is recommended that each individual material component of the packaging is labelled with its corresponding material code and disposal instruction.
  5. Freedom of graphic design in Italian: There are no precise specifications for the graphic design of the information, except that it must be written in Italian.
  6. Information via QR codes or websites: In some cases, information on composition and correct disposal can also be provided via QR codes or on websites.

LIZENZERO.EU makes packaging compliance in Europe very easy.

Do you ship your products to different countries in the EU? Many different legal requirements and obligations can make the whole thing quite complicated – but don’t worry, we’ll do it for you. How do we do it? With our licensing service, we take over all obligations for you by power of attorney. Sounds good? We’ll be happy to advise you.

For shipping to Germany, you can easily fulfill your packaging obligations yourself via Lizenzero.de.

EPR systems for packaging in comparison: a country overview

EPR systems for packaging in comparison: a country overview

In the EU, retailers and manufacturers who place products on the market are subject to certain environmental responsibilities. Extended Producer Responsibility (EPR) is a way of obliging companies to take responsibility for the entire life cycle of their products. This includes not only the product itself, but also all packaging and (product) components put into circulation that are disposed of by end consumers. The exact areas covered by the EPR vary from country to country. In this article, we take a look at the EPR in the area of packaging and shed light on what exactly the requirements mean, how they are implemented in practice and how the requirements differ from country to country within the EU.

read more
When will Italy introduce the single-use plastic tax?

When will Italy introduce the single-use plastic tax?

The introduction of the single-use plastic tax in Italy was originally planned for July 2020. It has now been postponed for the sixth time and is due to come into force on 1 July 2024. The tax aims to tax single-use packaging and plastic products. In this article, we explain what legal changes retailers can expect for their shipments to Italy as a result of the introduction of the tax.

read more
EPR obligations in Poland: volume threshold and registration obligation

EPR obligations in Poland: volume threshold and registration obligation

Since 13 June 2013, the handling of packaging waste in Poland has been regulated by the Act on Packaging and Packaging Waste Management (Journal of Laws 2019.542). Among other things, it sets out requirements for packaging, the handling of packaging waste and regulations regarding recycling fees. This means that companies in Poland are subject to extended producer responsibility (EPR). The EPR regulations are intended to ensure that companies take responsibility for the disposal of their packaging and thus contribute to the promotion of the circular economy. The EPR entails obligations regarding the handling of a company’s own products and packaging. In the following article, we shed light on what you need to consider as a retailer on the Polish market.

read more

Extended producer responsibility for packaging in Denmark: A new chapter begins!

Herstellerverantwortung für Verpackungen in Dänemark

Extended producer responsibility for packaging in Denmark: A new chapter begins!

Herstellerverantwortung für Verpackungen in Dänemark

From 1 July 2025, a new era in waste management will be ushered in in Denmark: extended producer responsibility (EPR) for packaging is coming. In concrete terms, this means that from this date, manufacturers will be obliged to ensure that their packaging is recycled. Denmark is the last country in the EU to implement the overarching EU Packaging Directive EU Directive 94/62/EC.

Contents of the new EPR law in Denmark

The Danish parliament has passed the EPR Directive for packaging and single-use plastic products. One major change is the redistribution of costs: what was previously borne by citizens will now be passed on to manufacturers. They will now have to bear the costs of collecting and sorting household waste and participate in programs to reduce packaging waste and promote recycling. It is estimated that around 41,000 companies will be affected by this regulation. In addition, charges will be introduced for the disposal of single-use plastic.

There is some relief for smaller manufacturers: Companies that produce less than 8 tons of packaging per year will have to provide less detailed information. This regulation will be reviewed again in 2027.

Important deadlines for companies

Companies that place packaging on the market in Denmark should take note: Registration in the manufacturer register and the quantity notification must take place between 1 April and 1 September 2024.

Implementation of producer responsibility

Manufacturers can fulfill their responsibility either individually or by participating in collective packaging systems. These systems must cover all types of packaging and operate nationally. The existing Danish system for electronic and battery waste will be extended to also monitor packaging.

 

The background to the new regulation

This policy decision aims to identify those in the value chain who have the greatest influence on packaging design. It is an important step towards improving waste management and recycling in Denmark and strengthening the circular economy.

LIZENZERO.EU makes packaging compliance in Europe very easy.

Do you ship your products to different countries in the EU? Many different legal requirements and obligations can make the whole thing quite complicated – but don’t worry, we’ll do it for you. How do we do it? With our licensing service, we take over all obligations for you by power of attorney. Sounds good? We’ll be happy to advise you.

For shipping to Germany, you can easily fulfill your packaging obligations yourself via Lizenzero.de.

EPR systems for packaging in comparison: a country overview

EPR systems for packaging in comparison: a country overview

In the EU, retailers and manufacturers who place products on the market are subject to certain environmental responsibilities. Extended Producer Responsibility (EPR) is a way of obliging companies to take responsibility for the entire life cycle of their products. This includes not only the product itself, but also all packaging and (product) components put into circulation that are disposed of by end consumers. The exact areas covered by the EPR vary from country to country. In this article, we take a look at the EPR in the area of packaging and shed light on what exactly the requirements mean, how they are implemented in practice and how the requirements differ from country to country within the EU.

read more
When will Italy introduce the single-use plastic tax?

When will Italy introduce the single-use plastic tax?

The introduction of the single-use plastic tax in Italy was originally planned for July 2020. It has now been postponed for the sixth time and is due to come into force on 1 July 2024. The tax aims to tax single-use packaging and plastic products. In this article, we explain what legal changes retailers can expect for their shipments to Italy as a result of the introduction of the tax.

read more
EPR obligations in Poland: volume threshold and registration obligation

EPR obligations in Poland: volume threshold and registration obligation

Since 13 June 2013, the handling of packaging waste in Poland has been regulated by the Act on Packaging and Packaging Waste Management (Journal of Laws 2019.542). Among other things, it sets out requirements for packaging, the handling of packaging waste and regulations regarding recycling fees. This means that companies in Poland are subject to extended producer responsibility (EPR). The EPR regulations are intended to ensure that companies take responsibility for the disposal of their packaging and thus contribute to the promotion of the circular economy. The EPR entails obligations regarding the handling of a company’s own products and packaging. In the following article, we shed light on what you need to consider as a retailer on the Polish market.

read more

The Triman logo and sorting instructions in France

Triman logo France

Initiatives such as the Green Deal and the plastic tax show that the European Union attaches great importance to environmental protection. A key element in this effort is the EU Packaging Directive, which aims to minimize the negative impact of growing packaging waste and support an effective circular economy in the member states. However, the implementation of this directive varies from country to country. In Germany, for example, this is regulated by the Packaging Act, while Austria has its own packaging ordinance. In France, one of the main requirements is the so-called labeling obligation. This obliges companies to label products and packaging that are ultimately disposed of in consumers’ households with the Triman logo. This regulation also applies to non-French online retailers who sell their goods to private customers in France. There have been changes to this labeling requirement since January 2021. What do you need to know about the French labeling obligation and what changes came into force at the beginning of 2021 and also in 2022? We have compiled all the relevant information for you below:

What is the French Triman logo?

The Triman logo is a French labeling system that aims to inform consumers about the correct disposal of products and packaging. It serves as a visual indication that the product and packaging must be disposed of separately to enable effective recycling. Producers, importers and sellers are obliged to provide additional information on proper disposal alongside the Triman logo. This makes it easier for consumers to properly separate and dispose of products and packaging, which in turn helps to promote an efficient circular economy.

The design of the Triman logo is made up of three elements:

  • A figure representing the responsible consumer.
  • Three arrows in the middle, which stand for separation and collection in the sense of improved waste recycling.
  • A fine arrow in the background symbolizing the recycling process.
Triman Logo Frankreich

The sorting information as a supplement to the Triman logo

Since 1 January 2022, it has been mandatory for distributors of household packaging on the French market to start implementing the so-called sorting information.

According to this catalogue of requirements, all sales packaging must bear the Triman logo and sorting information specially developed for the French market from 9 September 2022. In addition to the country abbreviation for France (ideally supplemented by the abbreviation “FR” for sales outside France), these separation instructions also contain information on the individual packaging components and the corresponding separation containers. The presentation of the separation instructions can be in text form (in French), as a pictogram or in a combination of both, whereby strict country-specific presentation rules must be observed.

  • In France, all non-glass packaging is usually disposed of in the “yellow bin”, while glass packaging must be disposed of in the green glass container. This simplifies labelling and separation for consumers.
  • In the case of packaging with several components, these must be listed individually and categorised accordingly.

Please also use our download offer at the end of this article.

These labelling regulations apply to all sales packaging distributed in France and affect both domestic and foreign distributors, regardless of the distribution channel. Exceptions to the new sorting information are:

Glass beverage containers

The Triman logo and the country-specific segregation information on the labelling of glass beverage containers is voluntary. If labels still have outdated markings, these must be updated by 9 March 2023 at the latest.

Small packaging units

For packaging smaller than 10 cm² without instructions for use or similar, the information about the Triman logo and the separation instructions must be available electronically (e.g. on the website, the product page in the online shop, etc.).

Packaging with a size of 10 to 20 cm² without instructions for use or similar must be labelled with the Triman logo, while the separation instructions must be available electronically (e.g. on the website, the product page in the online shop, etc.).

In the case of packaging up to 20 cm² that contains instructions for use or similar, both the Triman logo and the separation instructions must appear on this insert.

The labelling obligation is linked to a licensing obligation in France. The obligation to label and licence the sales packaging arises as soon as a single product is sold on the French market.

UPDATE: New deadlines in France for the Triman logo!
The Triman logo is already mandatory for numerous product groups. But new ones are constantly being added. These are the new deadlines for product groups:

  • Furniture: mandatory for all products since 15 June 2023
  • DIY and garden products: until 06 June 2024
  • Toys: until 06 June 2024
  • Decorative textile products (furniture EPR): until 25 August 2024
  • Building materials (for consumers): until 28 March 2025

The prevention plan

The changes to the French law on extended producer responsibility (EPR) have resulted in new requirements: By 15 October 2023, it was necessary to submit a plan to the French dual system to reduce the environmental impact of your packaging. This plan will be reviewed for effectiveness every five years and updated if necessary. You have the option of joining a collective plan or creating an individual plan.

From 2024: Merging the DPR value chains for graphic paper and household packaging!

In the pursuit of a more efficient and environmentally friendly circular economy, France has decided to merge the value chains for graphic paper and household packaging from January 2024. This decision aims to create synergies and minimise the environmental impact of production and disposal.

What does this mean in concrete terms? An improved circular system that covers the entire life cycle of graphic paper and household packaging. From production to recycling – all under one sustainable roof. Thanks to this merger, we will be able to offer you support for the entire new sector, household packaging and graphic paper, under a single contract from January 2024.

LIZENZERO.EU makes packaging compliance in Europe very easy.

Do you ship your products to different countries in the EU? Many different legal requirements and obligations can make the whole thing quite complicated – but don’t worry, we can do it for you. How do we do it? With our licensing service, we take care of all obligations for you by power of attorney. Sounds good? We’ll be happy to advise you.

Für den Versand nach Deutschland erfüllst du deine VerpackG-Pflichten übrigens ganz einfach selbst über Lizenzero.de.

Download the Triman logo

1. right click on the image

2. click on “Save as

3. save

Triman Logo Frankreich

All summarized guidelines can be found in the following guide, which was published by the French system provider CITEO (recommendation: download the manual and save it so that you always have it to hand): To the manual

EPR systems for packaging in comparison: a country overview

EPR systems for packaging in comparison: a country overview

In the EU, retailers and manufacturers who place products on the market are subject to certain environmental responsibilities. Extended Producer Responsibility (EPR) is a way of obliging companies to take responsibility for the entire life cycle of their products. This includes not only the product itself, but also all packaging and (product) components put into circulation that are disposed of by end consumers. The exact areas covered by the EPR vary from country to country. In this article, we take a look at the EPR in the area of packaging and shed light on what exactly the requirements mean, how they are implemented in practice and how the requirements differ from country to country within the EU.

read more
When will Italy introduce the single-use plastic tax?

When will Italy introduce the single-use plastic tax?

The introduction of the single-use plastic tax in Italy was originally planned for July 2020. It has now been postponed for the sixth time and is due to come into force on 1 July 2024. The tax aims to tax single-use packaging and plastic products. In this article, we explain what legal changes retailers can expect for their shipments to Italy as a result of the introduction of the tax.

read more
EPR obligations in Poland: volume threshold and registration obligation

EPR obligations in Poland: volume threshold and registration obligation

Since 13 June 2013, the handling of packaging waste in Poland has been regulated by the Act on Packaging and Packaging Waste Management (Journal of Laws 2019.542). Among other things, it sets out requirements for packaging, the handling of packaging waste and regulations regarding recycling fees. This means that companies in Poland are subject to extended producer responsibility (EPR). The EPR regulations are intended to ensure that companies take responsibility for the disposal of their packaging and thus contribute to the promotion of the circular economy. The EPR entails obligations regarding the handling of a company’s own products and packaging. In the following article, we shed light on what you need to consider as a retailer on the Polish market.

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Focus PPWR: New EU regulations for packaging?

The European Union is pursuing ambitious plans to promote the sustainability of packaging. This is particularly evident in the draft Packaging & Packaging Waste Regulation (PPWR), which was published in November 2022. This sets out binding requirements for packaging and packaging waste on the European market and goes beyond the previous EU directive. As a regulation, the PPWR will apply uniformly in all 27 EU member states, which, in contrast to previous directives, leaves less scope for national adjustments.

Update: On 4 March 2020, Parliament and the Council announced a provisional agreement on the EU Packaging Regulation in the trilogue negotiations. An important step! The law was also approved in the plenary session of the European Parliament on 24 April 2024. In order to be formally adopted, the PPWR will now be translated into the official languages of the EU before the new Parliament has to give its final approval in autumn 2024. The regulations should then take effect 18 months after the regulation comes into force.

The PPWR Regulation: overview and potential

The primary objective of the PPWR is to significantly reduce the negative environmental impact of packaging in the European Union. To this end, resource consumption and packaging waste should generally be minimized and the circular economy promoted. The PPWR sets out various measures to achieve this objective.

The PPWR plays a key role in the reduction of plastics, as packaging accounts for the majority of plastics produced in the EU. It offers the opportunity to reduce resource consumption, waste and pollution. The regulation can help to avoid unnecessary packaging and promote the use of reusable packaging.

However, it should be noted that the PPWR is associated with increased administrative and monetary costs, which could pose a challenge for small retailers in particular. Therefore, adaptation and consideration for all retail sizes is crucial.

Measures within the EU

Driven by the planned Packaging & Packaging Waste Regulation, the packaging industry and e-commerce are on the verge of a radical change. The comprehensive planned measures aim to drastically minimise the ecological footprint of packaging in the European Union.

A significant step here is the ban on the introduction of packaging without specific minimum requirements for recyclability after 2030. At the same time, the weight, volume and empty space of packaging will be reduced to the necessary minimum. Packaging that increases the perceived volume of the product through a double bottom or similar will be banned. The regulation will be binding for all companies based in the EU and for companies that import products into the EU.

The main changes:

  1. Minimum standards for the recyclability of packaging: The regulation sets minimum standards for the recyclability of packaging, whereby retailers must ensure that their packaging is suitable for recycling.
  2. Inclusion of recycled materials: One of the key requirements of the regulation is the increased use of recycled materials in certain packaging, particularly plastic packaging.
  3. Reduction of packaging waste: The PPWR sets clear targets for the reduction of packaging waste, which requires companies to take clear measures to reduce waste.
  4. Labeling and information standards: Packaging must meet certain labeling standards with the PPWR, including the labeling of recyclable packaging and the provision of information on proper disposal.
  5. Use of authorized representatives: Companies that send packaging to an EU member state and are based outside must appoint an authorized representative.
  6. Declarations of conformity: Distributors will be required to prepare comprehensive declarations of compliance at packaging level to ensure compliance with the PPWR.
  7. Measures to expand reusable systems: In order to promote the acceptance and use of reusable packaging, targeted measures will be adopted that also include incentives for manufacturers and retailers.

Outlook: When can we expect the PPWR?

The final adoption of the PPWR is still pending. The draft is currently being discussed in the European Parliament. If the PPWR is adopted, it could come into force in 2025.

Although the PPWR represents a significant step towards more sustainable packaging practices in the EU, it cannot be denied that the regulation will involve a great deal of effort and expense, especially in terms of packaging. Corresponding measures and considerations are therefore currently being discussed.

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Do you ship your products to different countries in the EU? Many different legal requirements and obligations can make the whole thing quite complicated – but don’t worry, we’ll do it for you. How do we do it? With our licensing service, we take over all obligations for you by power of attorney. Sounds good? We’ll be happy to advise you.

For shipping to Germany, you can easily fulfill your packaging obligations yourself via Lizenzero.de.

EPR systems for packaging in comparison: a country overview

EPR systems for packaging in comparison: a country overview

In the EU, retailers and manufacturers who place products on the market are subject to certain environmental responsibilities. Extended Producer Responsibility (EPR) is a way of obliging companies to take responsibility for the entire life cycle of their products. This includes not only the product itself, but also all packaging and (product) components put into circulation that are disposed of by end consumers. The exact areas covered by the EPR vary from country to country. In this article, we take a look at the EPR in the area of packaging and shed light on what exactly the requirements mean, how they are implemented in practice and how the requirements differ from country to country within the EU.

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When will Italy introduce the single-use plastic tax?

When will Italy introduce the single-use plastic tax?

The introduction of the single-use plastic tax in Italy was originally planned for July 2020. It has now been postponed for the sixth time and is due to come into force on 1 July 2024. The tax aims to tax single-use packaging and plastic products. In this article, we explain what legal changes retailers can expect for their shipments to Italy as a result of the introduction of the tax.

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EPR obligations in Poland: volume threshold and registration obligation

EPR obligations in Poland: volume threshold and registration obligation

Since 13 June 2013, the handling of packaging waste in Poland has been regulated by the Act on Packaging and Packaging Waste Management (Journal of Laws 2019.542). Among other things, it sets out requirements for packaging, the handling of packaging waste and regulations regarding recycling fees. This means that companies in Poland are subject to extended producer responsibility (EPR). The EPR regulations are intended to ensure that companies take responsibility for the disposal of their packaging and thus contribute to the promotion of the circular economy. The EPR entails obligations regarding the handling of a company’s own products and packaging. In the following article, we shed light on what you need to consider as a retailer on the Polish market.

read more