La export of packaging iThe industrial and commercial sectors face new regulatory challenges, especially in a context marked by the entry into force of the new European Packaging and Packaging Waste Regulation (Regulation 2025/40). In this scenario, experts agree on the need to anticipate regulatory changes, understand the producer's role in each destination country, and have clear information to ensure compliance with extended producer responsibility (EPR).
These have been some of the conclusions of Fourth Intracluster Dialogue of the yearOrganized by the Cluster of Innovation in Container and Packaging under the title “Selling packaging outside of Spain”, With funding from IVACE of the Valencian Government through the 'Cluster Management Entities' program. The dialogue included the participation of companies such as Heura with Arantxa Ibars and Sintac with Teresa Martínez, Director of Circular Economy Projects, who have provided different perspectives on the application of RAP in European countries such as Germany, France or Portugal, as well as on the implications of the new community regulatory framework.
A European regulation that redefines the role of the producer
From Ivy It has been explained that the new European Packaging and Packaging Waste Regulation has established its entry into force for the August 12th, 2026 It is mandatory for all member states, although it allows each country some leeway in adapting its practical application. The text defines a producer as anyone who first places packaging on the European Union market, a key issue for companies that have sold packaging outside of Spain.
In this regard, it has been noted that the regulatory situation has been different depending on the country: while Spain has been in a phase of regulatory design and reorganization of contracts, roles and data, other countries such as France already have definitive decrees and Portugal has focused on aligning its system with the new European regulation.
Participants agreed that, although many of the stricter requirements have been rolled out gradually, the market began to notice significant changes as early as 2025. The regulation has treated packaging as a regulated product, which has meant that customers have started to request increasingly detailed information about packaging to comply with their traceability and RAP obligations.
RAP in industrial and commercial packaging
From syntax The discussion delved into how extended producer responsibility (EPR) affects industrial and commercial packaging, emphasizing that European regulations have extended responsibility to both producers of packaged goods and packaging manufacturers themselves. The dialogue focused on the need to comply with sustainability, food safety, marking, and labeling requirements, as well as the proper management of reusable packaging in cross-border supply chains.
The debate addressed challenges such as the lack of recycled plastic raw materials authorized for food contact and the management of reusable packaging between member states. On this point, it was emphasized that reuse only makes sense within certain environmental and logistical limits.
Germany has been highlighted as a particularly relevant case, having had an Extended Producer Responsibility (EPR) system for packaging in place for over 30 years and with a significant presence in the European market. It was also noted that non-compliance with the regulations can lead to substantial financial penalties or even a ban on marketing products in certain markets.
Harmonization, labelling and digital passport
The dialogue also addressed the evolution of aspects such as labeling, packaging marking, and the future Digital Product Passport, which incorporates mandatory minimum information via QR codes, without requiring the inclusion of sensitive data. In this regard, it was noted that the EU has moved towards greater bureaucratic simplification for businesses, with the Omnibus Package applied to packaging regulations. Furthermore, the European Commission has already launched its proposal to exclude certain packaging, such as films and strapping, from the 100% reuse target.
Experts agree that 2026 will be a key year from a legislative standpoint, both due to the implementation of the European regulation and its delegated acts, and the publication of the new Spanish Royal Decree on Packaging. They also agree that understanding the regulations of the countries where their clients sell has become a strategic added value for packaging manufacturers. Furthermore, they themselves could be directly affected by Extended Producer Responsibility (EPR) as packaging manufacturers.
