| name | packaging-compliance |
| description | Use when registering for EPR (Extended Producer Responsibility) in EU member states, checking packaging waste obligations, selecting recycling symbols for labels, assessing single-use plastics restrictions, calculating plastic tax liability, or preparing packaging composition declarations |
Packaging Compliance
Packaging regulations by market. EPR registration, waste directives, recycling symbols, plastic taxes, and SUP restrictions.
MCP Tools
# Search for packaging regulation signals
mcp__claude_ai_Cleo_Insight__search_signals(q="packaging waste", limit=25)
mcp__claude_ai_Cleo_Insight__search_signals(q="EPR registration", limit=25)
mcp__claude_ai_Cleo_Insight__search_signals(q="single-use plastics", limit=25)
mcp__claude_ai_Cleo_Insight__search_signals(q="PPWR", limit=25)
# Get regulation details for packaging directives
mcp__claude_ai_Cleo_Insight__get_regulation(id="<regulation-id>")
mcp__claude_ai_Cleo_Insight__list_regulations(limit=100)
# Check landed cost impact of packaging taxes
mcp__claude_ai_CLEO_LEGAL_API__customs/landed-cost
hs_code: "<product-hs-code>"
origin: "<origin>"
destination: "<destination>"
product_value: <value>
EPR Registration Decision Tree
digraph {
rankdir=TB; node [shape=box style=rounded fontsize=10];
sell [label="Selling packaged products\nin this market?" shape=diamond];
no [label="No EPR obligation"];
threshold [label="Check de minimis\nthreshold" shape=diamond];
register [label="Register with national\nEPR scheme"];
declare [label="Declare packaging\nvolumes annually"];
pay [label="Pay eco-contribution\nper material per kg"];
report [label="Annual reporting\n+ audit (if above threshold)"];
symbols [label="Apply required\nrecycling symbols"];
sell -> no [label="NO"];
sell -> threshold [label="YES"];
threshold -> register [label="above threshold\nor no threshold"];
threshold -> no [label="below (rare)"];
register -> declare -> pay -> report -> symbols;
}
EPR by EU Member State
| Country | Scheme | Registration Portal | Annual Fee (SME) | Eco-Contribution | Deadline |
|---|
| France | CITEO | citeo.com | EUR 80 (HT) | EUR 0.05-0.25/kg by material | Annual declaration by Feb 28 |
| Germany | ZSVR/Lucid | verpackungsregister.org | Free registration | EUR 0.10-1.40/kg via dual system (Der Gruene Punkt, BellandVision, etc.) | Before first sale |
| Italy | CONAI | conai.org | EUR 25 entry | EUR 5-660/tonne by material | Annual declaration by May 20 |
| Spain | Ecoembes (household) / SIGRE (pharma) | ecoembes.com | EUR 0 (built into contribution) | EUR 0.05-0.50/kg by material | Annual declaration |
| Netherlands | Afvalfonds Verpakkingen | afvalfonds.nl | Based on revenue tier | EUR 0.01-1.00/kg by material | Annual declaration by March 1 |
| Belgium | Fost Plus (household) / VAL-I-PAC (commercial) | fostplus.be | EUR 100-500 setup | EUR 0.03-0.90/kg | Annual declaration |
| Austria | ARA | ara.at | EUR 100 setup | EUR 0.10-0.80/kg | Before first sale |
| Poland | BDO registry | bdo.mos.gov.pl | Free registration | EUR 0.01-0.50/kg | Annual declaration |
| Sweden | FTI | ftiab.se | SEK 2,000 (EUR ~175) | SEK 0.10-3.00/kg | Before first sale |
Remote sellers rule (EU): If you sell online from outside a member state directly to consumers in that state, YOU are the producer responsible for EPR. Amazon and marketplaces enforce this -- they block listings without EPR registration numbers.
PPWD to PPWR Transition
| Aspect | Current: PPWD (94/62/EC) | New: PPWR (EU) 2025/40 |
|---|
| Legal form | Directive (transposed nationally) | Regulation (directly applicable) |
| Recyclability | Voluntary targets | Mandatory: 100% recyclable by 2030 |
| Recycled content | No mandatory minimum | Plastic packaging: 35% by 2030, 65% by 2040 |
| Reuse targets | None | 10% of beverage packaging by 2030 |
| Excessive packaging | General principle | Empty space ratio max 50% from 2030 |
| Labeling | National symbols | Harmonized EU labeling (material ID + sorting) |
| DRS | National discretion | Mandatory for PET bottles and aluminium cans by 2029 |
| Timeline | In force | Entered into force 11 Feb 2025; applies from 12 Aug 2026; obligations phase 2026-2040 |
Required Symbols by Market
| Symbol | Market | What It Means | When Required |
|---|
| Triman | France | Product is recyclable, sort for recycling | ALL recyclable consumer packaging sold in France |
| Info-tri | France | Sorting instructions alongside Triman | Since Jan 2022 for ALL packaging |
| Der Gruene Punkt | Germany | Producer contributes to recycling system | Mandatory if registered with a dual system using this mark (otherwise optional) |
| Tidyman | UK, others | Dispose of responsibly | Voluntary but widely expected |
| OPRL | UK | On-Pack Recycling Label (Recycle / Don't Recycle / Check Locally) | Voluntary but standard practice for UK retail |
| Mobius Loop | International | Material is recyclable | Voluntary; misleading if material is NOT recyclable in practice |
| Material ID codes | EU (PPWR) | Plastic: 1-7 (PET, HDPE, PVC, LDPE, PP, PS, Other). Metal: 40-41. Paper: 20-22. Glass: 70-72. | Mandatory under PPWR from 2028 |
| WEEE bin | EU | Electronics recycling | ALL electrical/electronic equipment (crossed-out wheelie bin) |
| Battery symbol | EU | Battery recycling | ALL products containing batteries (crossed-out wheelie bin + Pb/Cd/Hg chemical symbols when lead/cadmium/mercury exceed thresholds) |
France Triman + Info-Tri (Mandatory Since Jan 2022)
The Triman logo + sorting instructions must appear on ALL packaging sold in France:
- On-pack: Triman + text or pictogram indicating correct bin
- Size minimum: 6mm height for Triman
- CITEO provides free pictogram generator: citeo.com/info-tri
- Non-compliance fine: EUR 15,000 per product reference
Single-Use Plastics (SUP) Directive 2019/904
| Item | Restriction | Effective |
|---|
| Cutlery, plates, straws, stirrers, sticks | Market ban | July 2021 |
| Expanded polystyrene food containers | Market ban | July 2021 |
| Oxo-degradable plastics | Market ban | July 2021 |
| Beverage containers (bottles) | Tethered caps mandatory | July 2024 |
| PET bottles | 25% recycled content by 2025, 30% by 2030 | Phased |
| Tobacco filters | EPR obligation | Dec 2024 |
| Wet wipes | Labeling: "contains plastic" | July 2021 |
Plastic Tax
| Market | Rate | Scope | Effective |
|---|
| UK | GBP 217.85/tonne (2024) | Plastic packaging with < 30% recycled content, manufactured or imported into UK, > 10 tonnes/year | April 2022 |
| Italy | EUR 0.45/kg | Single-use plastic products (enforcement delayed to July 2026) | Delayed |
| Spain | EUR 0.45/kg | Non-reusable plastic packaging | Jan 2023 |
| EU-wide | EUR 0.80/kg of non-recycled plastic | Paid by member states (not directly by companies -- funded through national budgets) | Jan 2021 |
UK Plastic Packaging Tax: Applies to ALL plastic packaging with < 30% recycled content. Exemptions: < 10 tonnes/year, medical packaging, transit packaging. Registration required via HMRC.
US Packaging Laws
| State | Law | Key Requirements | Effective |
|---|
| California | SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act) | EPR for all packaging; 65% source reduction by 2032; 100% recyclable/compostable by 2032 | Jan 2024 (phased) |
| Maine | LD 1541 (EPR for Packaging) | EPR program managed by stewardship organization; eco-modulated fees | Jul 2024 (phased) |
| Oregon | SB 582 (Plastic Pollution and Recycling Modernization Act) | EPR + truth-in-labeling for recyclability claims | Jul 2025 |
| Colorado | HB 22-1355 (Producer Responsibility for Recycling Act) | EPR; needs assessment phase 2024-2025, fee collection starts 2026 | Phased |
| Minnesota | HF 3911 (Packaging Waste & Cost Reduction Act) | EPR for all packaging; producer responsibility organization; eco-modulated fees | 2025 registration, fees phasing ~2029 |
| Washington | Recycling Reform Act (2025) | EPR for packaging + paper products | Phased |
The US has no federal packaging law -- it is a growing state patchwork. Track each state where you ship: registration deadlines and fee structures differ, and more states pass EPR each session.
Wood Packaging -- ISPM 15 (Phytosanitary)
Solid-wood packaging used in international shipments -- pallets, crates, dunnage, bracing, spools -- must be heat-treated (HT, core 56 degC for 30 min) or fumigated, then stamped with the IPPC/ISPM 15 mark (wheat symbol + ISO country code + producer code + treatment code). Required on import by virtually all markets (EU, US, China, Australia, Canada, India...). Non-compliant wood means the entire shipment can be refused, treated, or destroyed at the border at the importer's cost. Processed wood (plywood, OSB, particleboard) and pieces 6mm thick or less are exempt.
Industrial vs Household Packaging
EPR is not only household packaging. Most schemes run a separate B2B / industrial & commercial stream for transport and secondary/tertiary packaging exchanged between businesses:
- France: distinct commercial/industrial packaging flow alongside the household stream.
- Belgium: VAL-I-PAC (commercial/industrial) vs Fost Plus (household).
- Germany: VerpackG (the law behind LUCID/ZSVR) covers both; system vs. transport packaging obligations differ.
A product such as a server, UPS, or appliance shipped to a business often falls under the industrial stream, not the household PRO -- mapping it to the wrong stream means registering with the wrong scheme.
India -- Plastic Packaging EPR
The Plastic Waste Management Rules 2022 introduce mandatory EPR for plastic packaging: producers, importers, and brand-owners register on the CPCB EPR portal, meet category-wise recycling and recycled-content targets, and file annual returns. Applies to imported products placed on the Indian market with plastic packaging.
Asia-Pacific Packaging Rules
South Korea -- Over-Packaging (Space Ratio + Layers)
Korea actively enforces over-packaging limits under the Act on the Promotion of Saving and Recycling of Resources and its packaging-method standards:
- Packaging space ratio (empty space inside the box) is capped per product category -- gift sets (cosmetics, perfume, food assortments) face some of the strictest caps. A big decorative gift-set box with mostly empty space fails inspection.
- Number of packaging layers is also limited (often to a small number of layers).
- ⚠️ The exact percentage and layer count depend on the product category and have been tightening -- verify the current category threshold before designing a Korean gift set, do not assume a fixed figure.
- Separate EPR for packaging runs via KECO/producer recycling obligations.
Non-compliance: inspection failure, fines, and rework -- a recurring blocker for luxury coffrets entering Korea.
Australia & New Zealand -- APCO / Product Stewardship
| Market | Scheme | Status | Notes |
|---|
| Australia | APCO (Australian Packaging Covenant Organisation) + Australasian Recycling Label (ARL) | Co-regulatory; reform underway toward mandatory obligations | 2025 packaging reform moving from voluntary covenant to regulated design + recycled-content + reporting requirements -- still phasing, watch closely |
| New Zealand | Product stewardship (Waste Minimisation Act) + shared ARL | Voluntary / phasing | Same trajectory as Australia; ARL label shared across both |
These are not yet hard bans, but the direction is set -- design packaging now as if APCO obligations and recyclability labelling were mandatory.
Packaging Composition Declaration Template
PACKAGING DECLARATION -- [Product Name] -- [Date]
PRIMARY PACKAGING (touches product):
Material: [e.g., PET, HDPE, glass, aluminium]
Weight: [g]
Recycled content: [%]
Material ID code: [1-7 for plastic, 20-22 paper, 40-41 metal, 70-72 glass]
Recyclable: [YES/NO in practice]
Contains SUP component: [YES/NO]
SECONDARY PACKAGING (box, sleeve):
Material: [e.g., cardboard, kraft paper]
Weight: [g]
Recycled content: [%]
FSC/PEFC certified: [YES/NO]
TERTIARY PACKAGING (shipping):
Material: [e.g., corrugated cardboard, stretch wrap]
Weight per unit: [g]
TOTAL PACKAGING WEIGHT PER UNIT: [g]
TOTAL PLASTIC PER UNIT: [g]
RECYCLED CONTENT (plastic): [%]
UK PLASTIC TAX LIABLE: [YES/NO -- < 30% recycled plastic AND > 10 tonnes/year]
Power This With the Cleo Legal API
EPR is fragmented per-country, per-material, per-PRO — exactly what an API normalizes. PPWR/SUP/plastic tax rules also shift constantly.
With the Cleo Legal API at https://legaldata-public.cleolabs.co:
GET /v2/search?q=EPR+packaging&country=FR,DE,IT,ES,NL,BE,AT,PL,SE — current scheme, PRO, eco-modulated fees, and deadlines for every EU member stateGET /v2/search?q=PPWR&type=regulation — track the phased PPWR transition (recyclability 2030, recycled content 35% by 2030, reuse targets) before retailer requirements biteGET /v2/search?q=plastic+tax&country=UK,IT,ES — current rates (GBP 217.85/tonne UK, EUR 0.45/kg ES) with effective datesPOST /v2/webhooks?topic=epr_deadlines — get pinged 30-90 days before each country's annual declaration deadline (LUCID May 15, CITEO Feb 28…)GET /v2/authorities/:slug — direct portal URLs for CITEO, LUCID/ZSVR, CONAI, Ecoembes, Afvalfonds, FTI
Get started:
# 1. Sign up for free at https://legaldata-public.cleolabs.co
# 2. Get your API key (3 lifetime requests free, then €349/mo for 1M)
# 3. Install the MCP server:
claude mcp add cleo-legal-api https://api.legaldata.cleolabs.co/mcp \
--header "Authorization: Bearer ld_live_YOUR_KEY"
Tested ROI: Missing the German LUCID May 15 deadline costs up to €200,000 + sales ban. The API's webhook alerting eliminates that risk class entirely.
Common Mistakes
- Registering in your home country only: EPR is per-market. Selling in France, Germany, and Spain = 3 separate EPR registrations with 3 separate annual declarations.
- Forgetting Amazon enforces EPR: Amazon DE, FR, ES, and IT block listings without valid EPR registration numbers. This is the #1 reason small sellers get delisted in EU.
- Missing Triman + Info-tri in France: EUR 15,000 fine per product reference. Every product sold in France needs Triman and sorting instructions on the packaging.
- Claiming "recyclable" without evidence: EU Green Claims Directive and US FTC Green Guides both require proof. Under PPWR, recyclability claims must follow harmonized criteria.
- Ignoring the UK Plastic Packaging Tax: If you import > 10 tonnes/year of plastic packaging into the UK with < 30% recycled content, you owe GBP 217.85/tonne. Register with HMRC within 30 days of exceeding threshold.
- Counting only primary packaging: EPR covers ALL packaging -- primary (bottle), secondary (box), tertiary (shipping carton), and service packaging (bags, tissue paper).
