According to Indexbox, the European Union (EU) packaging materials market is projected to reach US$42.2 billion by 2035, presenting significant growth opportunities for packaging businesses looking to expand their reach. However, the EU is introducing increasingly stringent requirements for ecodesign, recyclability, and data transparency. To remain competitive, businesses must proactively adapt to these evolving regulations.
At the seminar session “Green Transformation in the Processing and Packaging Industry: From Ecodesign to High-Quality Recycling”, held as part of ProPak Hanoi 2026, Mr. Nguyễn Thi shared insights into the key regulatory changes and industry developments that businesses should prepare for when bringing their packaging products into the EU market.
ESPR Framework and the Shift to a Lifecycle Approach
According to Mr. Nguyễn Thi, one of the most notable changes is the shift from managing waste at the end of a product’s life to overseeing its entire lifecycle. Rather than focusing solely on post-consumer collection and treatment, the EU is increasingly embedding sustainability requirements at every stage, from product design and material selection to manufacturing, packaging, distribution, and recycling. This marks a broader shift in how products are expected to be designed and managed under the Ecodesign for Sustainable Products Regulation ESPR (EU) 2024/1781.
The ESPR establishes a common framework for ecodesign, extending its scope to most physical goods placed on the EU market, with certain exceptions such as food, animal feed, and medicinal products. Under this framework, the regulation introduces two complementary sets of requirements: environmental performance and product information. In practice, products must not only meet technical sustainability standards but also provide sufficient information to demonstrate compliance and support traceability when needed.
The ESPR also sits alongside two other major EU frameworks: the Carbon Border Adjustment Mechanism (CBAM) and the Corporate Sustainability Reporting Directive (CSRD). As Mr. Nguyễn Thi explained, each addresses a different layer of sustainability requirements. The ESPR focuses on product-level sustainability and technical criteria; CBAM addresses the carbon emissions from certain goods imported into the EU, while the CSRD requires companies to disclose ESG information across their value chains, including indirect emissions.
Key Ecodesign Criteria for Packaging
The ESPR works alongside the PPWR (EU) 2025/40. While the ESPR establishes the broader ecodesign framework for products, the PPWR sets more specific requirements for packaging across its lifecycle. According to Mr. Nguyễn Thi, businesses should focus on three key areas:
- Packaging-to-Product Ratio Optimization: Businesses should reduce packaging weight and volume, minimize space in both packaging and transport, and eliminate unnecessary decorative layers. Under the PPWR, empty space in grouped, transport, and e-commerce packaging must not exceed 50% by 2030. Standardizing packaging dimensions can also improve container utilization and increase logistics efficiency.
- Recyclability: Mono-material designs make packaging easier to separate and recycle. Businesses should also increase the use of post-consumer recycled (PCR) plastics and recycled paper, while limiting packaging films that may release microplastics into the environment.
- Alignment with Sector-Specific Regulations: Standardizing technical requirements across the EU enables businesses to take a more consistent approach to packaging design, material selection, and product documentation across multiple member states.
How Much Transparency Is Enough?
EU Declaration of Conformity (DoC)
Manufacturers must issue the EU Declaration of Conformity (DoC) to confirm that a product meets the applicable EU requirements. It must be supported by technical documentation covering key product information, material specifications, and compliance evidence.
Businesses should keep this documentation complete and up to date, with records accurately reflecting the product placed on the market. This provides the evidence needed for compliance review by customers, business partners, or regulatory authorities.
Understanding the Digital Product Passport (DPP)
The ESPR also digitizes product information through the Digital Product Passport (DPP). The DPP brings together standardized product data in a machine-readable format, accessible through data carriers such as QR codes, 2D barcodes, or RFID tags placed on the product or its packaging.
According to Mr. Nguyễn Thi, the DPP system relies on three key identifiers to connect product information with the businesses and facilities involved across the supply chain:
- UPI (Unique Product Identifier): Identifies a specific product model, product line, or batch, and links it to the corresponding technical specifications and environmental data.
- UOI (Unique Operator Identifier): Identifies the businesses involved in the supply chain, such as manufacturers, importers, and packaging operators.
- UFI (Unique Facility Identifier): Identifies individual manufacturing or packaging sites, allowing products to be traced back to specific facilities and production stages.
DPP information does not need to be held in a single centralized system. However, all UPI codes must be registered with and synchronized to the EU’s central Registry. This structure allows regulatory authorities to retrieve product identifiers and cross-check the associated information against the relevant businesses, production facilities, and partners across the supply chain.
The Data Bottleneck: Gaps in Supplier Information
Businesses cannot always independently verify every aspect of their products. Information on raw materials, chemical composition, and recycled content often depends on data provided by upstream suppliers. Mr. Nguyễn Thi calls this challenge a “data dark spot,” gaps in information across the supply chain.
Missing data from any part of the supply chain can make it difficult to compile environmental data and meet reporting obligations. Businesses need to establish clear expectations with their suppliers from the outset, including what data must be provided, how it should be verified, and who is responsible for keeping it up to date.
How Businesses Can Prepare
To meet ESPR and PPWR requirements, businesses should standardize data on materials, composition and technical specifications; strengthen traceability documentation to verify material sources, recycled content and recyclability; and incorporate these requirements from the packaging design stage. Responsibilities for providing, verifying, updating, and protecting data across the supply chain should be clear.
This becomes increasingly important as the DPP connects with EU regulatory and customs systems, allowing product information to be checked and cross-referenced automatically. Missing, inaccurate, or inconsistent data could therefore create direct compliance risks when products enter the EU market. Preparing data, documentation and verification processes early will help businesses reduce these risks and respond more effectively to new requirements.
Explore Solutions at ProPak Vietnam 2027
As EU requirements continue to evolve, businesses need to standardize packaging and ensure their products meet sustainability criteria. At ProPak Vietnam 2027, visitors can explore processing, packaging, and recycling technologies, stay up to date with industry trends, and converse with experts through dedicated seminar sessions.
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