Exporters scramble as EU packaging regulation takes effect

Packaging has emerged as a new regulatory hurdle for South Korean companies exporting to the European Union. As the EU's packaging rules take full effect — covering not just product performance and safety certification but also boxes, cushioning materials, labels and recycling systems — inquiries from domestic exporters have been rising sharply.

The Korea Trade-Investment Promotion Agency (KOTRA) said Monday that more than 730 people, mostly representatives of South Korean export companies, registered for its online webinar on the EU Packaging and Packaging Waste Regulation (PPWR) held Wednesday, with 501 actually attending. Some 210 questions were submitted in advance, focusing heavily on practical matters such as the scope of the regulation, required documentation, labeling requirements and extended producer responsibility (EPR) registration.

The PPWR covers all packaging and packaging waste placed on the EU market. It was introduced to reduce packaging waste and increase reuse and recycling. Key obligations include restrictions on substances of concern and heavy metals, packaging design that facilitates recycling, use of recycled plastic content, and minimization of packaging.

For exporters, the first question is whether their packaging falls under the regulation at all. The determination is based on function, not material or industry sector. Packaging that serves a sales, grouping or transport function may be subject to the rules. E-commerce packaging also qualifies as transport packaging and warrants particular attention.

Handling of existing inventory was another major concern. For imported products, the determining factor is when they are placed on the EU market. Products already on the EU market before the PPWR's Aug. 12 application date are exempt, but products released afterward must meet the regulation's requirements even if they were manufactured before that date.

No separate pre-clearance approval is required for customs. However, companies must submit technical documentation and a declaration of conformity if requested by the relevant authorities. Local buyers acting as importers are also likely to request supporting documents before a product's release, meaning Korean companies should prepare their paperwork in advance.

Labeling and identification marking is another area causing confusion. Not every individual package requires a direct marking; accompanying documents may be used when marking on the product itself is impractical. Companies must, however, maintain a traceability system recording when, where and from what materials the packaging was made.

EPR registration is not a single EU-wide process — it operates separately in each member state. A company selling products in Germany, France and Italy, for example, must register on each country's portal and obtain a separate national identification number. The administrative burden grows significantly for companies exporting to multiple countries.

The webinar also shared how EU-based companies are responding. Some are increasing the use of recycled materials at the packaging design stage and building collection and reuse systems. At the same time, concerns were raised about how consistently the regulation will be enforced across member states, given that secondary legislation and detailed guidelines are still being developed.

The EU regulatory burden extends well beyond packaging. With the Carbon Border Adjustment Mechanism (CBAM) also entering its definitive phase, companies exporting carbon-intensive goods such as steel, aluminum and cement must now prepare for emissions calculations and certificate costs as well. Regulations that scrutinize the entire lifecycle of a product — from manufacturing and packaging to disposal and carbon emissions — are fast becoming a baseline requirement for entering the EU market.

KOTRA advised exporters to secure in advance the material composition, weight and structural information for each type of packaging and to establish a documentation system that can demonstrate regulatory compliance. It noted that obligations differ depending on the role of each economic operator — manufacturer, importer or distributor — and that companies should review their supply chain structures accordingly.

The Korea Testing & Research Institute (KTR) and the Korea Conformity Laboratories (KCL) are offering support services covering testing for four heavy metals and per- and polyfluoroalkyl substances (PFAS), recyclability assessments, packaging minimization evaluations, technical documentation and declaration of conformity preparation, and document verification consulting. Both institutions are registered service providers under KOTRA's voucher program.

"In the early stages of a regulation's implementation, companies inevitably face significant practical confusion over the detailed guidelines," said Kim Yeon-jae, head of KOTRA's Europe regional headquarters. "KOTRA will continue to use its on-the-ground presence in Europe to quickly identify the latest regulatory developments and share them with industry, supporting Korean companies in establishing a stable foothold in the EU market."

KOTRA plans to publish key content from the European Commission's PPWR guidance documents and FAQ on its overseas market news website and will post the webinar recording on KOTRA TV. The agency will also hold an additional PPWR webinar Tuesday in cooperation with the Korean Agency for Technology and Standards and the Technical Barriers to Trade Comprehensive Support Center.