EU Packaging Rules Take Effect, Small Firms in the Dark

New European Union packaging regulations came into force today, requiring businesses across all 27 member states to use more environmentally friendly packaging and demonstrate compliance with the bloc’s ambitious sustainability agenda. But as the first binding obligations of the Packaging and Packaging Waste Regulation (PPWR) take effect, many small businesses in Belgium say they are struggling to understand what is required of them.

According to VRT NWS, the regulation — part of the EU Green Deal — obliges producers and importers to present a valid EU Declaration of Conformity, while imposing significantly lower thresholds for PFAS, lead, and mercury in food-contact packaging. Extended Producer Responsibility (EPR) registration is now mandatory in every EU member state where a company places packaged products on the market.

A Regulation in the Making

The PPWR, formally Regulation (EU) 2025/40, was adopted on December 19, 2024, and entered into force on February 11, 2025. As a regulation rather than a directive, it applies directly in all EU member states without requiring national transposition. The first binding obligations became applicable on August 12, 2026, marking what Noémie Janssens of the Verbond van Belgische Ondernemingen (VBO) calls “the starting signal for a trajectory of obligations that will be rolled out in the coming years.”

“This is part of the Green Deal, a legislative framework from the European Commission to make the packaging world more sustainable,” Janssens told VRT NWS. “This regulation should lead to less packaging waste. Packaging must become reusable and recyclable.”

Small Businesses Left Confused

Despite the regulation being years in the making, many small entrepreneurs say they are only now discovering their obligations. Tom Desmedt, whose wife Amber runs a clothing webshop, told VRT NWS that “for a one-person business without a legal department, it is difficult to understand exactly what obligations they now have.”

The core concern for many small businesses is the requirement to register as producers in every EU country where they ship products. “As it stands now, a small business would have to register in every country they ship to and pay an annual amount that is often many times higher than the value of the few packages sent to that country,” Desmedt said. “Many are afraid they will have to stop their business because the costs will become too high. Others have already stopped taking foreign orders.”

Janssens confirmed the concern: “It is true that small businesses, if they place packaging on the market or transport something with it, will have to register in other countries and appoint a representative. But what the costs of such a registration will be is not yet established.”

Unpublished Rules Compound the Problem

A significant part of the problem lies in the fact that many implementing rules remain unpublished. Roughly 30 implementing acts are expected in total, but nine cost-driving acts are still pending. Steven Boussemaere of Fost Plus, Belgium’s household packaging recycling organization, said: “There are still an enormous number of things that are unclear. Companies are now tearing their hair out. The EU still has to publish many implementing decisions. Those are needed for companies to prepare.”

The lack of clarity extends beyond Belgium. As GroentenNieuws reported, Luca B. Fornaroli of Fimat/Cartonpack Group warned that “uncertainty about the rules is the biggest enemy of businesses. Without clear and unambiguous guidelines, companies don’t know how to organize their investments and compliance activities.”

Adding to the confusion, the labeling implementing act missed its August 12, 2026 deadline, meaning the harmonized EU sorting label obligation is now not expected before 2028. Thirteen member states still had not named a PPWR enforcement authority as of August 4 — just eight days before the rules applied.

Business Groups Cry Foul

Belgian business organizations have been vocal in their criticism. In a press release issued the day before the rules took effect, UNIZO, the Flemish self-employed and SME organization, called the situation “another textbook example of how Europe undermines good objectives with bad regulation.”

“No one is against more sustainable packaging, but entrepreneurs are again being saddled with extra administration, additional costs, and a tangle of national obligations,” UNIZO said. “Europe constantly talks about administrative simplification and a stronger internal market. Then you cannot force entrepreneurs to register again and again in different member states for the same activity. That is the opposite of simplification and the opposite of a single market.”

UNIZO noted that registration costs can reach several hundred euros per country per year — a disproportionate burden for small webshops with limited cross-border sales.

What Comes Next

The PPWR’s obligations will phase in over the coming years. By February 2027, restaurants must allow customers to bring their own containers. By 2029, deposit return systems must be operational in every member state for single-use plastic bottles and metal beverage containers. By 2030, all packaging must be recyclable, with minimum recycled content in plastics and a 50% empty-space cap.

For now, however, businesses face a period of uncertainty. As Pantarein, a Belgian ESG consultancy, put it: “Having a file in preparation is no longer sufficient from August 12. You have a file — or you don’t.”

Fost Plus, which describes itself as ready to guide businesses through the transition, acknowledged the scale of the challenge. “It is clear that the new European regulation will have a major impact — not only on our members, but on everyone active in the chain,” said Floriane de Kerchove, Public & Regulatory Affairs Manager at Fost Plus. “We are ready to guide them through this complex story and realize the ambitious European objectives.”

As the remaining implementing acts are published and enforcement authorities are named, businesses will gain clarity — but for now, many small entrepreneurs remain in the dark about what the new rules mean for their day-to-day operations. The coming months will be critical in determining whether the PPWR achieves its sustainability goals without crushing the small businesses it was meant to serve.