If a company sells its products using laminated bags or prints “eco” labels on packaging, such a business will face changes. The upcoming EU Packaging and Packaging Waste Regulation (PPWR) will start to apply from 2026 onwards. This is the starting point from which businesses will be required to review their processes and prepare for changes. The requirements will come into force in stages: the obligation to provide scannable codes with unified sorting instructions on packaging will apply from 2028 onwards, and packaging that does not meet the established recyclability requirements will no longer be allowed to be placed on the EU market from 2030 onwards.
The sunset of laminated packaging is approaching
Laminated bags, in which paper is glued with plastic film (composite packaging), will face challenges under the new regulation. The main problem is the complex separation of different materials, which makes such packaging practically impossible to recycle in a high-quality way.
The PPWR introduces recyclability performance classes (from A to E). From 2030 onwards, all packaging placed on the market will be required to meet minimum recyclability performance requirements. Packaging that falls into the lowest categories (such as D or E) will be considered non-compliant and will no longer be allowed to be placed on the EU market. From 2038 onwards, the requirements are expected to become even stricter, further limiting lower-performing packaging formats.
Since laminate (paper with plastic) is difficult to recycle, it may fall into the lowest recyclability categories.
Packaging waste management fees will be directly linked to recyclability performance. The fee will be paid by:
- If a company in Lithuania manufactures products and packages them in its own packaging
- If a company imports packaged goods from abroad (e.g., China or the U.S.) and sells them on the EU market
- If an international e-commerce store sells goods directly to consumers in Lithuania
From symbolic labeling to digital proof
The digital passport of packaging is becoming the new standard for trading on the EU market. This will no longer be just symbolic labeling, but an official digital proof that packaging meets strict EU requirements.
Although the regulation starts applying from 2026 onwards, the obligation to provide standardized digital information on packaging—potentially via scannable elements such as QR codes—with technical data and sorting instructions will come into force from 2028 onwards. Without such information, packaging may be considered non-compliant with EU transparency and safety requirements.
A strict “no” to greenwashing
Until now, many companies have labeled packaging with abstract terms such as “environmentally friendly” or “natural”, often without any scientific substantiation. The new regulation will fundamentally change this.
Stricter requirements for environmental claims will start to apply from 2026 onwards, and from 2028 onwards, there will be an obligation to substantiate claims about packaging properties with verifiable data, including through digital information systems.
Why packaging from China may become a challenge in the EU
Some Lithuanian companies importing products or packaging from non-EU countries, such as China, still rely on suppliers’ “verbal” promises about sustainability. From 2026 onwards, legal responsibility for packaging compliance with EU requirements increasingly falls on the importer or the company placing the product on the EU market.
This means that if a supplier declares packaging as “sustainable”, but it later does not meet recyclability requirements or lacks the data required for compliance and traceability, the consequences will be borne by the EU-based business, not the manufacturer in Asia.
For businesses, it becomes important to request evidence from packaging manufacturers – data on the chemical composition of materials and the origin of raw materials. Without this information, packaging may be considered non-compliant with EU requirements.
If a business decides to take the risk and continue using packaging that does not comply with EU requirements, penalties may follow. Financial sanctions may include administrative fines for responsible persons, as well as significant financial penalties under EU consumer and environmental regulations. Companies may also be required to withdraw products from the market.
If packaging does not provide the required compliance information, it may be considered non-compliant, which can lead not only to halted sales but also to significant logistical costs related to product withdrawal and repackaging.
Homework for businesses
Although 2026 may seem far away, changing packaging supply chains and production lines takes time. To ensure that company sales do not stop, I recommend taking these three steps:
- Evaluate all used packaging according to recyclability performance criteria and identify high-risk formats that may not meet future requirements
- From 2026 onwards, ensure availability of certificates and technical documentation confirming packaging composition and compliance with safety requirements
- Start transitioning to mono-material plastic or paper packaging, which is better positioned to meet future recyclability requirements and optimize waste management costs
The digital passport is not just a sticker – it is data management. From 2028 onwards, packaging will be expected to include accessible digital information with technical data. Companies must start preparing their systems now so they can generate and provide the required data for EU compliance frameworks.
Jonas Elvikis
CEO of „Bagfactory“
