Any business that manufactures, imports or places packaged products on the European market, or designs or purchases packaging for its products or operations is, in principle, subject to the following two sets of regulations:<\/p>\n
There will likely be a grace period before the first inspections take place, but the second half of 2026 is the ideal time to prepare. Without going into the details of the regulations, this article will explain how to proceed and how our teams can help you prepare for the start of the 2027 academic year and plan ahead to 2030.<\/p>\n
What types of packaging do they apply to?<\/em><\/strong><\/p>\n The PPWR applies to all types of packaging, regardless of the material used, as well as to all packaging waste.<\/p>\n However, the AGEC Act distinguishes between \u2018commercial packaging\u2019 and \u2018household packaging\u2019, which has been subject to an Extended Producer Responsibility (EPR) scheme since 1992. Household packaging is intended for private individuals, or \u2018households\u2019, whilst commercial packaging is designed to package and transport products used and unpacked by businesses (B2B flows, internal flows within a single business, etc.).<\/p>\n It is therefore not the type of packaging or the sector of activity that determines which EPR scheme applies, but its end use.<\/p>\n The heart of the matter: who is responsible for ensuring compliance?<\/em><\/strong><\/p>\n This is one of the main difficulties in interpreting these regulations. The PPWR and the AGEC Act do not cover exactly the same scope, but their definitions are similar.<\/p>\n In both cases, the producer\/manufacturer \u2013 that is, the party responsible for placing the packaging on the market \u2013 bears the associated obligations. This may be the manufacturer of the packaging or the packaged product, the importer or the distributor, depending on the type of packaging and the manner in which it is made available. Responsibility depends less on where the packaging is manufactured than on the country in which it is first made available and on the role played by each party in the supply chain.<\/p>\n However, these principles leave room for certain complex situations regarding individual responsibility, which will be further clarified by future European guidelines or by eco-organisations in France.<\/p>\n What are the main provisions of these regulations?<\/em><\/strong><\/p>\n These regulations do not have the same implications for businesses. The EPR framework sets out the financial and operational responsibilities for the end-of-life management of packaging in France, whilst the PPWR entails a longer-term overhaul of procurement strategy, with requirements for all packaging to be recyclable, for volumes to be minimised, and for minimum reuse rates to be achieved from 2030 onwards.<\/p>\n To meet its legal obligations, a packaging producer will, in particular, need to:<\/p>\n How can you start the compliance process right now?<\/em><\/strong><\/p>\n The first step is to analyse your packaging flows and determine for which types of packaging the company is considered a producer. In practical terms, this involves:<\/p>\n\n