[REVISION HISTORY]

EU packaging and greenwashing rules: Implementation and SME-

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What changed

2026-10-21 18:35 UTC → 2026-10-26 15:59 UTC · added ~~removed~~

The implementation of the EU Packaging and Packaging Waste Regulation (PPWR) and the Empowering Consumers for the Green Transition (EmpCo) Directive has entered a critical phase. As of late September 2026, new consumer protection rules are in effect to combat greenwashing by banning unfounded eco-labels. To enhance transparency, a new ‘GARAN’ label has been introduced for products offering voluntary durability guarantees exceeding the standard two-year legal requirement. Retailers must now provide clear information regarding legal guarantees via physical displays or QR codes. Under the EmpCo Directive, companies are prohibited from using vague terms like ‘environmentally friendly’, ‘green’, or ‘natural’ without verifiable evidence. Furthermore, claims of ‘climate neutrality’ or ‘carbon neutrality’ are restricted if they rely solely on carbon offsetting outside a product’s own value chain. In Italy, Legislative Decree 30/2026 enforces these standards, with potential fines reaching 10 million euros. In Poland, the Sejm has implemented these measures with an effective date of September 27, 2027. Regarding packaging, the PPWR and Germany’s VerpackDG became effective on August 12, 2026. These rules mandate strict limits on PFAS in food contact materials and govern the entire packaging lifecycle. ~~In Germany, the government has also launched an action plan to increase the use of bio-based drop-in plastics by 2029.~~ A new Design for Recycling (DfR) framework will introduce recyclability grades (A, B, or C), with packaging below 70% recyclability prohibited after 2030. However, the administrative burden on small-scale merchants remains a major point of contention. ~~Under Extended Producer Responsibility, businesses must register with systems like Germany’s LUCID, facing fines of up to 200,000 euros for non-compliance. Because the PPWR lacks a minimum threshold~~ Small e-commerce exporters report that costs for ~~small quantities, cross-border sellers must navigate individual national registration and representation requirements~~ mandatory authorized representatives in every ~~destination country.~~ member state can make certain markets unviable. In response, EU the European Parliament and member states ~~are proposing~~ have proposed a compromise where EU-based manufacturers would only need ~~to appoint~~ an authorized representative ~~in a member state~~ if they place at least one tonne of packaging on ~~that~~ a market annually. Additionally, the European Commission has delayed the adoption of standardized waste-sorting labels until the second quarter of 2027 to allow for public consultation.

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