Packaging Materials Regulations in the European Union: An Overview

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Product compliance extends beyond the product itself, to the packaging materials used to protect and display the product. In this guide, we cover the essentials that all importers and exporters selling in the European Union must know about product packaging materials regulations.

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What is defined as a packaging material?

Packaging materials include both product packaging used for display and customer experience purposes, as well as protective packaging materials such as export cartons. However, in this guide, we primarily focus on the former category.

Product Packaging Examples

  • Watch boxes
  • Cardboard boxes
  • Plastic packaging
  • Food and beverage packaging

Packaging labeling

Note that packaging labeling requirements depend on the product, rather than the packaging material. Various packaging labels, including CE marking and WEEE marking, are covered in this guide.

Food Contact Materials

Additional regulations apply specifically to food and beverage packaging materials.

Directive 94/62/EC on Packaging and Packaging Waste

The directive 94/62/EC covered all types of packaging placed on the EU market and all packaging waste. This directive regulates the chemicals and heavy metals present in packaging.

For example, the concentration levels of lead, cadmium, mercury and hexavalent chromium are regulated as follows:

  • 600 ppm by weight two years after the date referred to in the directive
  • 250 ppm by weight three years after the date referred to in the directive
  • 100 ppm by weight five years after the date referred to in the directive

In general, the sum of concentration levels of heavy metals present in packaging or packaging components shall not exceed 100 ppm by weight.

Optional Information

The directive also encourages to include information as below for the users of packaging:

  • The return, collection and recovery systems available
  • reuse, recovery, and recycling of packaging and packaging waste
  • The meaning of markings on packaging
  • Management plans for packaging and packaging waste

In summary, the packaging shall meet the essential requirements as following:

  • Limit the weight and volume of packaging
  • Reduce the content of hazardous substances and materials
  • Reusable or recoverable packaging.
  • Biodegradable packaging is highly recommended

EU packaging materials rules


REACH is the regulation in EU that regulate substances including chemicals, heavy metal, and pollutants for all products placed on the EU market. It also applies to the material used in packaging, for example, cardboard and paper, PE and other plastics, metal cans, and plastic bottles.

Substances fulfilling at least one or more of the criteria below are identified as “substances of very high concern”(SVHC):

  • Substances classified as a carcinogenic category under Directive 67/548/EEC
  • Substances classified as a mutagenic category under Directive 67/548/EEC
  • Substances classified as toxic for reproduction category under Directive 67/548/EEC
  • Any other substances classified as toxic, persistent and bioaccumulative

REACH is applicable to packaging materials, such as the following:

  • Plastic packaging (e.g. Blister packaging)
  • Paperboard packaging (e.g. Watch gift boxes)
  • Wood (e.g. Jewelry boxes)
  • Steel (e.g. Food storage containers)

REACH lists certain substances that may be contained in packaging materials. Here are a few examples:

  • Bisphenol P (Potential use in plastics)
  • Dihexyl Phthalate (Toxic for reproduction)
  • Cadmium oxide (Carcinogenic)
  • Lead cyanamide ( Toxic for reproduction)
  • Boric oxide (Potential use in paper boxes)
  • Borate flame(Potential use in paper boxes)

If the packaging material contains excessive amounts of SVHCs, it’s not legal to be imported or sold in the EU common market. Doing so may result in a heavy fine or a force-recall. Also note that REACH applies in addition to the packaging regulations, therefore, Lab testing is the only way to verify and ensure your product’s compliance.

Food Packaging Regulations

Food and beverage packaging are subject to EU food contact materials regulations. There are two main regulations that you must comply with if you import, export or manufacture food packaging materials to the EU:

  • Regulation (EC) No 1935/2004
  • Regulation (EC) No 2023/2006

Here we summarized some requirements under these regulations:

  • Declaration of Compliance (DoC) must be provided by business operators (including importers)
  • Traceability system must be established for FCMs from production to distribution
  • Materials shall be labeled “for food contact” or any other symbol indication

Moreover, there are specific materials with special requirements for food contact substances. For examples:

  • Plastic materials
  • Active and intelligent materials
  • Recycled plastic materials
  • Ceramics
  • Regenerated cellulose film

For the above materials, the Doc is also required to ensure public safety. In order to provide a proper DoC and make sure there is no violation of your products, we always recommend lab testing to verify the compliance.

Labeling Requirements

There is no uniform labeling standard for all packaging materials and types. Instead, the specific labeling requirements depend on the product inside the packaging.

Recycling Symbols

As recommended in directive 94/62/EC, recycling symbols are now appearing on lots of products nowadays. Here are a few different types of recycling symbols:

The Green Dot

The green dot symbol indicated that the producer has made contributions to qualified national packaging recovery organization. It is not mandatory under any regulations, but to show customers that the manufacturer’s contribution to the cost of recovery and recycling.

The symbol applies to every type of products and it does not necessarily mean that the packaging is recyclable. For example, it can be applied to the packaging as below:

  • Cardboard
  • Plastic wrap
  • Paper bags
Mobius Loop

This symbol indicates that the packaging can be recycled. Sometimes you will see the Mobius loop with a percentage figure and that shows how much of the packaging has been manufactured from recycled materials.

This symbol applies to all recyclable packaging materials including:

  • Paper and cardboard
  • Bubble wrap
  • Biodegradable plastic
Plastic Resin Codes

This symbol helps to identify the type of plastic resin used in the packaging. The center of the symbol will include a number that defines the resin used as follows:

  • 1 – Poly(ethyleneterephthalate)
  • 2 – High density polyethylene
  • 3 – Poly(vinyl chloride)
  • 4 – Low density polyethylene
  • 5 – Polypropylene
  • 6 – Polystyrene
  • 7 – Other resins

These symbols apply not only on plastic products but also for the products that made of plastic resin such as:

  • Plastic bottle
  • Food foils
  • Luggage
  • Toys
  • CD
Widely Recycled Label

The widely recycled label means that the packaging is recycled by 75% or more of local authorities across the UK. Notice that the symbol often comes with the instruction above the symbol. For examples:

  • Rinse
  • Rinse, Lid on
  • Flatten, Cap on
  • Remove sleeve

The instruction can inform you how to recycle the material efficiently. For example, widely recycled symbol with flatten above the symbol suggests that to squash or flatten the packaging for more space in the recycling process.


The Forest Stewardship Council (FSC) was established to set standards on forest products, including wood and paper products such as furniture and product packaging.

There are three types of FSC on-product labels:

  • FSC 100% (Completely from FSC-certified well-managed forests)
  • FSC Recycled (all wood or paper comes from reused material)
  • FSC Mix( Mix of re-used material and FSC-certified forests)

You will the FSC’s “tick tree’ logo on some paper or wood products on the market, for example:

  • Beverage Packaging
  • Paper bag
  • Wood boxes

CE Mark

CE mark

The CE mark is essentially indicated that product compliance with the EN standards or EC directives. In general, the CE mark shall be affixed to the product unit, user instructions, and its packaging. If the CE marking cannot be visibly, legibly, and indelibly affixed on the products, the CE marking has to be affixed to the packaging and the user manual.

Here we list some products that require CE marking:

  • Electronics
  • Toys
  • Sunglasses
  • Helmets
  • Bicycles
  • Medical devices


For all electrical and electronic equipment (EEE), the WEEE symbol must be printed visibly on the product. The WEEE symbol indicated that when the end-user wishes to discard this product, it must be sent to separate collection facilities for recovery and recycling.

Here are some products are within the scope of regulation.

  • Refrigerators
  • Washing machines
  • Microwaves
  • Laptop computers
  • Phones

Food Contact Materials Symbol

EU glass and fork symbol

The general principles of safety and inertness for all Food Contact Materials (FCMs) is stated in regulation EC No 1935/2004.

The food safety symbol is mandatory for products that not obviously to be used in contact with food and it indicates that the material used in the product is considered safe for food contact. As such, you don’t need this label for drinkware, cutlery or other ‘obvious’ food contact materials.

The international symbol, which is also used in the EU, for food-safe material is a wine glass and a fork symbol that you see above.

Also, to allow consumers to identify of non-edible parts, the DO NOT EAT symbol shall be labeled with the words “Do not eat’, and always where technically possible, with the symbol reproduced in Annex I in regulation (EC) No 450/2009.

Packaging Laboratory Testing

Directive 94/62/EC lab testing

The lab test is not mandatory for all product packaging. However, for food packaging or cosmetic packaging, you will need to be able to provide the DoC as mentioned in this guide. That said, lab testing is still a recommended practice for ensuring that the packaging is compliant.

Here are some laboratories for packaging materials lab test services:

  • QIMA
  • SGS
  • Intertek
  • TUV
  • Bureau Veritas

REACH Lab testing for packaging materials

Same as the directive 94/62/EC, the third-party laboratory testing allows you to verify compliance with the requirements of REACH, but not mandatory for packaging materials. Therefore, the only way to avoid compliance issues is to get your product lab tested.

Here are some laboratory offering REACH lab testing services:

  • QIMA
  • SGS
  • Intertek
  • AGQ
  • (USA & EU)

    We Help Brands & Importers With Product Compliance (US & EU)

    • Product Requirements Lists
    • Product Certification
    • Product & Packaging Labeling
    • Lab Testing


    Disclaimer: The content on this website is provided for general information only. The content includes summaries written by our team members based on publicly available information about product safety standards, labeling, documentation, testing, processes, and other product compliance related topics. However, we don’t guarantee that we cover every single relevant regulation/standard/requirement, or that the information is free from errors, or covering every single scenario and exemption. We do make mistakes from time to time. We never provide legal advice of any sort.

    Changes/Updates: Product standards and substance restrictions are subject to frequent updates and changes. In addition, new regulations, standards, and/or requirements may also become effective at any time. We don’t update our articles whenever new standards/regulations/rules are added or changed. We recommend that you consult a lab testing company or other professional to get the latest information about mandatory standards/regulations in your market, country, or state. Lab testing companies generally stay up to date on new and updated standards and regulations.

    National/State-Level Standards/Regulations: Many articles don't cover all European national and US state standards, regulations, and requirements. We recommend that you consult a testing company or other professional to confirm all relevant (and current) national/state level standards and regulations.
  • 10 Responses to “Packaging Materials Regulations in the European Union: An Overview

    1. List of European Authorised Representative Companies 2021 at 4:57 pm

      […] assistance and solutions to customers to ensure their products comply with the WEEE Directive and Packaging Directive, which involves registration, documentation, and recycling […]

    2. Candle Safety Standards & Regulations in the European Union at 5:29 pm

      […] addition to the product itself, importers and manufacturers should also ensure the compliance of product packaging materials. The following summarized packaging materials and waste requirements in the European […]

    3. Are Cello Bags Biodegradable? - Thinking Sustainably at 3:19 pm

      […] also follows the final guidelines of the EU. The guidelines state that packaging materials originate from renewable and sustainable […]

    4. Fiona Lam at 6:40 pm

      Dear Sir,
      If I have a packaging with hot seal gold foil, which recycle logo should be printed on packaging?

      the main packaging material is PAP21
      the heat seal gold foil area is less that 5%. (only on the brand name)
      If the heat seal gold foil is less than 5% do we need to declare on packaging (any instructions)?
      Can we keep PAP21 for the recycle logo

    5. Charlie at 11:30 pm

      Hi Frederik & team

      When applying the Mobius Loop to my product packaging, am I required to sign up/register/subscribe to anything in order to use it or can I literally just apply the Mobius Loop freely to my packaging provided I’ve done the lab testing to prove it is recyclable?

      Thanks, Charlie

    6. Syrus at 8:08 am

      hi Vincent, my name is Syrus. I am writing on behalf of my company. We are a label printer in HK & China. We are supplying packaging materials – printing label for worldwide food manufacturers, mostly in EU, USA and China market . We hear that there is some testing requirement or standard referring to the food packaging safety. We are searching for these information but laboratories in HK do not have sufficient support in this way. May I ask for your assistance to advise any information relate to these testing requirement and standards?

      We are having one case of a client from Germany, they are requesting us to update our food packaging safety standards and requires us to arrange migration test on or label product (UV ink and other materials) and confirm free from ITX and 4 methilbezophenone , however we have contact many lab such as SGS, ITX etc, they claimed that we cannot do such test. May I know if you can provide any support or suggestion? thanks!

      1. Fredrik Gronkvist at 9:24 am

        Hi Syrus,

        Sounds strange. SGS, BV, Intertek, QIMA, TUV, etc should all be able to offer EU FCM testing.

        That said, sometimes the EU announces a new substance restriction. This is often done years in advance, as to give companies time to phase out certain substances. It could be that these substances must be phased out by 2021 or something and that the testing companies are yet to offer lab testing for these substances.

      2. karan vijayavargiya at 10:34 pm

        I want to start food grade paper packaging unit in India.
        can you help me????

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