EU packaging regulation took effect in August

Implementation varies by country

Germany, Spain use competitive fee rates

Hungary, Croatia apply fixed rates

KOTRA's headquarters in Yangjae, Seoul [KOTRA]
KOTRA's headquarters in Yangjae, Seoul [KOTRA]

South Korean exporters are facing a growing compliance burden following the EU's introduction of new packaging regulations in August. Although a single set of rules applies across the bloc, the procedures for registering packaging materials and paying environmental levies differ from country to country, requiring companies to prepare separately for each market they enter.

The Korea Trade-Investment Promotion Agency (KOTRA) released a report Monday detailing how 21 European countries are implementing the EU Packaging and Packaging Waste Regulation, known as PPWR, and outlining what companies need to do in each market.

The EU began fully applying the PPWR on Aug. 12, replacing the previous Packaging and Packaging Waste Directive. The regulation aims to harmonize packaging rules that had been managed separately by each member state and to reduce the overall volume of packaging waste.

The rules cover not only packaging that wraps a finished product but also materials used in transport and retail distribution. They govern recyclability and the use of hazardous substances, and standards for recycled-content use will be tightened in phases going forward.

The challenge lies in how the rules are actually carried out. Even though a common regulation applies across all 27 EU member states, the extended producer responsibility, or EPR, system — which requires companies to bear the cost of collecting and recycling packaging — operates differently in each country.

Under EPR, companies that place products or packaging on a market are responsible for waste management and recycling. They must register their packaging with the relevant national authority and pay an environmental levy based on the volume of packaging they supply, among other criteria.

Germany, Austria and Spain, for example, have adopted a model in which multiple producer responsibility organizations compete with one another to set levy rates. Hungary and Croatia, by contrast, apply fixed rates through a single government-led body.

Country-specific obligations add another layer of complexity. France requires a domestic sorting label known as "Triman" on household packaging. The United Kingdom — not an EU member but a major European export destination — applies obligations on a sliding scale based on a company's sales and the volume of packaging it supplies.

Companies selling products across multiple European markets therefore cannot rely on EU-wide rules alone. They must verify, for each country where their products are sold, which packaging must be registered, what reporting procedures apply and how costs are calculated.

KOTRA's report also sets out a checklist of priorities for companies. The first step is to take stock of all packaging in use — not just finished-product packaging but also boxes, cushioning materials and other items used in logistics and transport.

Companies also need to determine their legal status within their export supply chain. The obligations they face differ depending on whether they are classified as a "manufacturer" — responsible for conformity assessments and technical documentation — or a "producer," which carries the duty to register packaging and pay environmental levies.

Companies must also prepare technical documentation and a declaration of conformity demonstrating that their products meet the applicable standards. Over the longer term, KOTRA said, companies should address packaging at the design stage — for instance by switching to recyclable materials or reducing unnecessary packaging.

In practice, the EU plans to tighten recyclability assessment criteria for packaging and mandatory recycled-content requirements for plastic packaging in phases starting in 2030. That means companies will eventually need to redesign their packaging itself, not just resolve the immediate questions of country-by-country registration and levy payments.

KOTRA published a general guide to the PPWR's main provisions last year and has since supported companies through practical Q&A materials and online briefings this year. Demand for information has been strong — more than 500 representatives from exporting companies attended a briefing held in August — prompting KOTRA to compile the additional country-by-country breakdown.

A follow-up online briefing is scheduled for Wednesday at 4 p.m. It will cover how EPR operates in Germany, Hungary, the Czech Republic and the United Kingdom, and will include a case study of how a South Korean food company has navigated the packaging regulations.

Kim Kwan-muk, KOTRA executive vice president and head of its economic security and trade cooperation division, said the report and webinar were designed to present, in a single accessible resource, the complex EPR systems that persist across major European countries even under a unified regulation. "The guide contains firsthand information gathered on the ground, along with practical experience and response strategies," he said. "We hope it becomes the first reference exporters reach for when navigating unfamiliar European regulatory requirements."


kwater@heraldcorp.com