Here’s a compact, export-ready checklist and practical steps to get plastic packaging accepted for sale across the EU (suitable for a Netherlands-based supplier). I cite the most relevant EU rules and dates so you can act to comply.
Key EU rules and dates (most important)
- Packaging and Packaging Waste Regulation (PPWR) — replaces the Packaging Waste Directive; entered into force 11 Feb 2025 and its main application begins mid‑2026. It requires minimised packaging, recyclability, recycled‑content targets and new labelling/marking and reuse/return obligations. (environment.ec.europa.eu)
- New bans and restrictions — certain single‑use plastic packaging formats will be banned (various deadlines up to 2030); limits on empty space, reuse targets and deposit/collection targets are included. PFAS in food‑contact packaging is restricted (bans above thresholds). (europarl.europa.eu)
- Food contact materials framework — Regulation (EC) No 1935/2004 requires FCMs (including plastics) to be safe and not transfer harmful substances to food; specific rules for plastics and recycled plastics exist and migration testing is required for food contact. (food.ec.europa.eu)
What EU buyers/importers will expect (summary)
- Proof packaging is recyclable and meets PPWR recyclability criteria (design choices: mono‑polymers, easy-to-separate layers, minimal multilayer adhesives). (environment.ec.europa.eu)
- Declaration/labels showing material type, any recycled content percentage, and instructions for sorting/collection where relevant. (consilium.europa.eu)
- For food contact packaging: migration test reports, statement of compliance with Reg (EC) 1935/2004 and any specific plastic FCM rules; absence (or limits) of restricted substances such as PFAS above thresholds. (food.ec.europa.eu)
- Compliance with extended producer responsibility (EPR) and national packaging schemes in the destination Member State (fees, registration, reporting). (environment.ec.europa.eu)
Concrete checklist for exporters (step‑by‑step)
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Confirm product category and destination requirements
- Identify whether packaging is: primary (in direct contact with product), secondary (grouped), transport, e‑commerce, or reusable. PPWR applies to all types but has different targets/requirements. (environment.ec.europa.eu)
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Design for recyclability and reduced waste
- Use mono‑material designs where possible, avoid non‑recyclable inks/coatings, limit multi‑layer laminates or ensure separability, reduce empty space and unnecessary components (tapes, inserts). PPWR sets recyclability and minimisation rules and empty‑space limits. (europarl.europa.eu)
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Check restricted substances (PFAS and others)
- Do not use PFAS (above thresholds) in food contact packaging; review supplier chemical inventories and request material declarations. The PPWR and related agreements explicitly restrict PFAS in food contact packaging. (europarl.europa.eu)
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Prepare food contact compliance documentation (if applicable)
- Get migration tests and safety assessment reports from accredited labs and a written Declaration of Compliance referencing Regulation (EC) No 1935/2004 (and any specific plastics rules). Keep full traceability for recycled content if used. (food.ec.europa.eu)
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Meet recycled content and labelling targets
- If using recycled plastics, document sources and % recycled content. Label packaging with material identification and recycled content as required by PPWR. Expect rising minimum recycled‑content targets (2030/2040 deadlines). (consilium.europa.eu)
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Recyclability verification & testing
- Use recognised recyclability protocols or third‑party verification (accredited testing labs) showing your packaging meets recyclability criteria. Keep test reports available for EU buyers and compliance checks. (environment.ec.europa.eu)
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Register for EPR / national packaging schemes in the importer’s country
- Your EU customer or importer will normally handle local registrations, but you must supply correct data (material type, weights, recycled content). Confirm who covers EPR fees and reporting. National schemes are harmonised but still implemented locally under PPWR. (environment.ec.europa.eu)
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Update commercial documentation
- Provide SDS (if chemical agents are present), material declarations, DoC for food contact, recyclability certificate, recycled content evidence, and clear sorting/disposal instructions in the local language(s).
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Avoid formats that will be banned or face phase‑outs
- Be aware of banned single‑use formats (e.g., small portions, certain fruit/veg packaging, hospitality miniatures) with 2030‑type deadlines — redesign product packaging lines if your product falls into those categories. (europarl.europa.eu)
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Keep records & be ready for audits
- PPWR increases traceability and reporting obligations. Keep batch records, supplier attestations, test reports and EPR documentation for at least the period required by the importer/member state.
Practical next actions (what to do this week)
- Audit current packaging SKUs against the checklist (material, multi‑layers, labels, food contact status, recycled content).
- Order migration/recyclability tests from an EU‑accredited lab for any food contact or new designs. (If you want, I can list accredited labs in the Netherlands or EU.)
- Request written material declarations from your raw‑material suppliers (no PFAS, % r‑PET or recycled polymer content, adhesives/ink types).
- Agree with your EU customers who will register and pay EPR fees and where responsibility for compliance documentation lies.
Notes about national/local variations
- PPWR harmonises many rules across the EU but Member States will run their EPR schemes, deposit return systems and enforcement — so always confirm the specific importer country’s operational requirements (e.g., DRS for bottles, labelling language). (environment.ec.europa.eu)
If you’d like, I can:
- Produce a one‑page “EU compliance pack” template you can hand to buyers (list of documents to supply).
- Find accredited labs in the Netherlands for migration and recyclability testing.
- Review a specific packaging spec (material layers, weight, intended use) and give targeted redesign suggestions.
Which of those would you like next?