OPINION
Packaging faces the challenges of new European labelling legislation
07/03/2025

The packaging industry has a period of adaptation ahead of it until 2028 to bring packaging labelling in line with the requirements of the European Packaging Regulation and those of Directive (EU) 2024/825 on Environmental Claims, better known as the Greenwashing Directive.
Thanks to the regulatory harmonisation provided by the European Packaging Regulation, Member States will not be able to impose restrictions on the placing on the market of packaging that complies with the sustainability and labelling requirements of the Regulation, thus ensuring the free movement of products in the single market. In this process, regulatory harmonisation is not only a challenge but also an opportunity to strengthen sustainability and transparency in labelling.
Although the European Packaging Regulation has been in force since 12 February 2024, its marking and labelling requirements will be implemented progressively. Thus, in August 2026, harmonised guidance on labelling will be published, which will tell industry exactly how it will have to act, i.e. what to put on packaging and how to put it on packaging. Already in February 2027 it will be mandatory to mark packaging covered by extended producer responsibility and in August 2028 markings on material composition, compostability, packaging subject to Deposit, Return and Refund (DRS) and separate collection will have to be incorporated. By the latter date, it will remain optional to indicate the amount of recycled and bio-based plastic contained in the packaging.
Until the effective implementation of the European regulation, in Spain, as in the rest of the European Union countries, national legislation remains in force. In our case, the Royal Decree on Packaging and Packaging Waste regulates the information that must be included on household packaging, from the fraction or container where it must be deposited to the indication of whether it is reusable or whether it is part of a Deposit, Return and Refund System (DRS). It also requires that compostable plastic packaging must indicate its certification in accordance with the applicable standard and that those suitable for domestic or industrial composting must provide information on their proper management. As a complement, there are other voluntary markings, such as the composition of the material, the percentage of recyclability, the amount of recycled material incorporated and the SCRAP symbol, including the Green Dot symbol, which is voluntary. In addition, the use of words such as ‘environmentally friendly’ or any other expression that could lead to its abandonment in the environment is prohibited.
In addition to this regulatory framework, there is the Green Claims Directive. Its aim is to protect consumers against misleading marketing practices that could mislead them as to the actual sustainability of a product. It prohibits, among other things, the use of environmental claims without verification by an expert and independent third party, as well as the use of generic terms such as ‘environmentally friendly’ if they cannot be proven with objective data. In addition, external verification may be required to ensure that companies meet the environmental commitments and targets they communicate to consumers.
The challenge for industry is clear: prepare for this new scenario and take the necessary measures in advance to ensure compliance with European requirements. With an implementation timetable already defined, the sector must act with foresight to avoid regulatory risks and consolidate a labelling model aligned with the European regulatory framework.
