EU Design Reform Compliance Requirements for Member States

𝐓𝐡𝐞 𝐄𝐔 𝐏𝐚𝐜𝐤𝐚𝐠𝐢𝐧𝐠 𝐒𝐡𝐚𝐤𝐞-𝐔𝐩: 𝐖𝐡𝐚𝐭 𝐘𝐨𝐮 𝐀𝐜𝐭𝐮𝐚𝐥𝐥𝐲 𝐍𝐞𝐞𝐝 𝐭𝐨 𝐊𝐧𝐨𝐰🧑⚖    ❎ The Big Deadlines 🔹By 2030: All packaging placed on the EU market shall be designed for recycling (Design for Recycling criteria to be adopted for each packaging category by end of 2027) and categorized according to recyclability performance grades A, B and C. 🔹By 2035: Recycled-at-scale requirements take effect; focusing on separate collection, sorting into specific waste streams and leading to recycling at scale for defined waste streams. That means packaging must be recyclable at scale across the EU, not just in theory. 🔹By 2038: Only recyclability performance grades A and B will be allowed. ❎ Minimum Recycled Content Targets in Plastics: 🔹By 2030: 30% for PET bottles and contact sensitive packaging from PET, 10% for contact-sensitive packaging other than PET, and 35% for other plastic packaging.  🔹By 2040: Targets will be increased, eg. to 50% recycled content in contact sensitive packaging from PET. ❎ Reusable Packaging Targets: 🔹Not only for beverage distribution but also for transport packaging, which will have big impact on all stages of the value chain.          ❎ Restrictions (“bans”) from 2030: 🔹Think mini hotel toiletries, very lightweight plastic bags, single-portion condiment packs for on-site consumption. ❎ Harmonised Labelling: 🔹One EU-wide disposal label on packaging + matching bin labels from 2028 (reuse labels from 2029).      And here’s the kicker for food producers... For the first time, the compliance burden doesn’t sit with packaging suppliers - it sits with you (the brand owner/manufacturer/importer who places packaging on the market).  That means:  ✅ YOU must prove your packaging meet PPWR requirements.   ✅ YOU will need supplier data, to assess recyclability performance grades for YOUR packaging unit, and to declare achievement of recycled content targets.   ✅ Technical documentation and EU declarations of conformity are mandatory for YOU.      What this means for business?   ✨ You can’t “design pretty” first and think about recycling later.   ✨ “Recycle-ready” isn’t enough if the infrastructure doesn’t actually exist.   ✨ And for beverage and transport packaging? Reuse targets are no longer optional.  ✨ Single-use portion formats in HORECA and accommodation sector, and other formats, will get restricted.  ✨ Marketing claims must match law, not vibe.      This is the biggest packaging shake-up in decades.   If your packaging strategy isn’t already aligned with PPWR… you’re not behind schedule. You’re behind reality.      We’ll be at FACHPACK (23.-25.9.2025). Come find the Wipak stand (Hall 4, Stand 4-312) and ask us the hard questions. Bring your toughest PPWR worries - we’ll bring the answers. Don’t forget to ask about DigitalChoice. Trust me, you want to get in on this!😉 #PPWR #sustainability #plastic #circulareconomy

The EU Parliament has published its draft negotiating position on the proposed SFDR 2.0 reforms. The draft retains the Commission’s three-category structure (Transition, ESG Basics and Sustainable) but introduces material changes in several areas. Three are worth highlighting: ▸ ESG Basics (Article 8 under the new framework) carries a higher bar. The Parliament draft requires funds to remove at least 20% of their worst-performing holdings by sustainability rating or value before demonstrating ESG characteristics. The Commission’s proposal set a considerably lighter quantitative test. ▸ Benchmark alignment is no longer sufficient on its own. The Commission’s proposal allowed CTB and PAB tracking to provide a form of safe harbour. The Parliament’s draft removes this. Funds will need to demonstrate category compliance independently of their benchmark. ▸ PAI disclosures would extend to product level across all three categories. The Commission sought to reduce the overall PAI burden. The Parliament’s draft reverses that at the product level, introducing a mandatory core set of PAI disclosures for all categorised funds, plus additional indicators where material to the product strategy. So what is the main takeaway here? We believe the practical implications are particularly significant for funds currently classified as Article 8 under the existing framework. A large number are expected to seek the ESG Basics label (the ‘new’ Article 8) under SFDR 2.0. However, many currently rely on a provision that allows them to avoid reporting on any PAIs. If the EU Parliament’s position carries into the final text, the analysis and data disclosure requirements for these funds will only become more onerous. Not less - as I believe many may have been anticipating.

𝐄𝐮𝐫𝐨𝐩𝐞𝐚𝐧 𝐂𝐨𝐦𝐩𝐥𝐢𝐚𝐧𝐜𝐞 𝐅𝐫𝐚𝐦𝐞𝐰𝐨𝐫𝐤𝐬 Governance and compliance shape every decision — system design to vendor management — in EU projects. These frameworks shape how we deliver secure, resilient, and sustainable results: 1. 𝐍𝐈𝐒2 𝐃𝐢𝐫𝐞𝐜𝐭𝐢𝐯𝐞 – 𝐂𝐲𝐛𝐞𝐫𝐬𝐞𝐜𝐮𝐫𝐢𝐭𝐲 𝐚𝐧𝐝 𝐑𝐢𝐬𝐤 𝐌𝐚𝐧𝐚𝐠𝐞𝐦𝐞𝐧𝐭 Puts additional requirements on essential sectors like energy, health, and transport. Covers incident reporting, governance, and supply chain resilience. Cybersecurity and risk controls need to be designed into every project from the start. 2. 𝐃𝐎𝐑𝐀 – 𝐃𝐢𝐠𝐢𝐭𝐚𝐥 𝐎𝐩𝐞𝐫𝐚𝐭𝐢𝐨𝐧𝐚𝐥 𝐑𝐞𝐬𝐢𝐥𝐢𝐞𝐧𝐜𝐞 𝐀𝐜𝐭 Covers financial institutions and ICT providers. Ensures systems can resist and recover from disruptions through testing, incident response, and business continuity arrangements. 3. 𝐄𝐒𝐆 & 𝐂𝐒𝐑𝐃 – 𝐒𝐮𝐬𝐭𝐚𝐢𝐧𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐚𝐧𝐝 𝐓𝐫𝐚𝐧𝐬𝐩𝐚𝐫𝐞𝐧𝐜𝐲 Extend sustainability reporting along environmental, social, and governance axes. Projects must establish processes for collecting and attesting ESG data to meet EU disclosure obligations. 4. 𝐆𝐃𝐏𝐑 – 𝐃𝐚𝐭𝐚 𝐏𝐫𝐨𝐭𝐞𝐜𝐭𝐢𝐨𝐧 𝐚𝐧𝐝 𝐏𝐫𝐢𝐯𝐚𝐜𝐲 Decides how personal data is handled in organizations. Privacy-by-design principles, transparency over data usage, and lifecycle transparency need to be ensured by project managers. 5. 𝐈𝐒𝐎 𝐒𝐭𝐚𝐧𝐝𝐚𝐫𝐝𝐬 – 𝐆𝐨𝐯𝐞𝐫𝐧𝐚𝐧𝐜𝐞, 𝐒𝐞𝐜𝐮𝐫𝐢𝐭𝐲, 𝐚𝐧𝐝 𝐐𝐮𝐚𝐥𝐢𝐭𝐲 ISO 27001/27701 (information security), ISO 9001 (quality), and ISO 20000 (IT service) offer frameworks for consistency, performance, and compliance. They enable teams to show control and readiness in audits. 6. 𝐄𝐮𝐫𝐨𝐩𝐞𝐚𝐧 𝐈𝐧𝐭𝐞𝐫𝐨𝐩𝐞𝐫𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐅𝐫𝐚𝐦𝐞𝐰𝐨𝐫𝐤 (𝐄𝐈𝐅) Provides a roadmap to creating interoperable digital services across Member States. It enables public systems to exchange information securely and efficiently, in a manner that facilitates EU-wide collaboration. 7. 𝐂𝐨𝐧𝐧𝐞𝐜𝐭𝐢𝐧𝐠 𝐄𝐮𝐫𝐨𝐩𝐞 𝐅𝐚𝐜𝐢𝐥𝐢𝐭𝐲 (𝐂𝐄𝐅) Funds projects that expand digital connectivity and trusted services such as eID, eSignature, and cross-border data exchange. For project managers, this means managing multi-country standards and compliance alignment. 8. 𝐄𝐔 𝐃𝐚𝐭𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐲 – 𝐃𝐚𝐭𝐚-𝐃𝐫𝐢𝐯𝐞𝐧 𝐆𝐨𝐯𝐞𝐫𝐧𝐚𝐧𝐜𝐞 Enables a single European data space founded on fairness, privacy, and innovation. It informs how we design analytics, AI platforms, and data-sharing agreements with transparency and accountability. Compliance isn't limitation — it's building digital ecosystems people can trust.

A new era for product legislation and digital compliance in the EU is unfolding. As a standards expert and transformation leader, I want to draw your attention to a significant legislative proposal just released by the European Commission (COM(2025) 503 final). The proposal aims to modernize and harmonize 13 key EU product directives—moving towards “digital by default”, establishing common specifications, and simplifying compliance, especially for SMEs. It’s a critical milestone for all global stakeholders involved in sustainable product design, digital conformity, and technical standardization. Key highlights: -Transition from paper to digital information delivery -Alignment of technical requirements across sectors -Reduced reporting burden – while upholding safety and sustainability goals -Support for Digital Product Passports (DPP) and the “Once Only” principle This will reshape how we approach product compliance, documentation, and market access – in Europe and beyond. Let’s make sure we engage early and bring international expertise to the table. #Ecodesign #Standardization #Transformation #DigitalCompliance #Sustainability #CircularEconomy #EURegulation #CEmarking #ProductDesign #DigitalProductPassport #ENStandards #ISO #SMEs #EUClimatePact Full proposal here: https://lnkd.in/dqiX9A6N

Legally speaking, the #CSDDD enters into force today - it was officially published on 5 July and the rule is that EU legislation enters into force 20 days after publication, which is today (25 July 2024). EU Member States have until 26 July 2026 to transpose the Directive into national law. The first companies will need to comply from July 2027 onwards. This makes three years = lots of time to prepare and adjust, and also time to understand that compliance itself is just a minimum requirement; what matters is the 'spirit of the law'. Important is to keep an eye on transposition into national law, so that this transposition: ▶ goes swiftly and not lag behind as with the #CSRD (as of July 2024, only 9 out of 27 member states have fully transposed the CSRD into national law) and ▶ is ambitious - at the end of the day, the CSDDD is a Directive and there is wiggle room for national regulators to also reach beyond what has been decided. Link to the final legal text: https://lnkd.in/dRnEGqCd

While many eyes are on potential shifts in U.S. trade policy, the European Commission is staying the course - today adopting the 2025–2030 working plan under the Ecodesign for Sustainable Products Regulation (ESPR) and Energy Labelling Regulation. This is regulatory consistency at its best: a clear signal to industry that Europe remains committed to building a competitive, sustainable, and resilient industrial base - regardless of global political turbulence. One of the question I have been asked many time is: What is coming first? And now we have the answer. The Commission will set ecodesign and energy labelling requirements for: 1) Steel & aluminium. 2) Textiles (esp. apparel). 3) Furniture, mattresses & tyres. Horizontal measures will follow, including: 1) Repairability scoring. 2) Recyclability and recycled content standards for electronics and electrical equipment. 3) Digital product passports to increase transparency and traceability. Here is my five points on what this means for manufacturers: 1) Product compliance is going upstream. It’s no longer just about end-of-life recycling or energy efficiency labels. Manufacturers will need to design for circularity - ensuring durability, ease of repair, reuse, and recycled content - from the very first engineering phase. 2) Data is becoming as important as design. The Digital Product Passport (DPP) will be the primary channel to communicate product information to customers, regulators, and partners. Manufacturers should begin structuring material, component and emissions data now to avoid future bottlenecks. 3) Regulation is aligning with competitive advantage. Those who lead on sustainability will gain access to public procurement opportunities, consumer trust, and preferential positioning across the Single Market. Compliance is no longer just a cost - it is a differentiator. 4) SMEs will not be left behind. The Commission explicitly notes the need for tailored support to smaller businesses. Manufacturers should actively engage now to ensure they influence what ‘reasonable’ looks like in their sectors. 5) Timing is tight, but the direction is clear. Requirements will be rolled out progressively between 2026 and 2030 - but preparatory studies are already beginning. Being early offers a strategic edge. This initiative is a cornerstone of the Clean Industrial Deal and the EU Competitiveness Compass. It is how Europe intends to lead - not just regulate - the global transition to a circular economy. Stability, clarity and direction - while others posture, the is how Europe show it will deliver. And we at 9altitudes have all the components to help you. #Ecodesign #SustainableIndustry #CircularEconomy #EURegulation #TradePolicy #DigitalProductPassport #Manufacturing #CleanIndustrialDeal #ESPR #9altitudes

Starting 2024 with the news that the final ESPR text has been published! This is an exciting moment for the EU Regulation on Ecodesign, which aims to enhance the environmental sustainability of products circulating in the EU, including Digital Product Passports (DPP - from page 105). So what are the highlights and who should take note? 🏬 Manufacturers: - Comply with eco-design requirements to improve environmental sustainability. - Provide information on selected product parameters, such as environmental footprint and durability. - Make information available for informed consumer purchasing decisions. 🧑🏿🤝🧑🏼 Consumers: - Receive information on reparability and durability to engage in sustainable consumption. - Be provided with easily understandable reparability and durability scores for effective product comparison. - Incentivized to make sustainable choices through mechanisms like eco-vouchers and green taxation. 🇪🇺 Commission: - Prioritize certain product categories for ecodesign requirements, including iron, steel, textiles, furniture, ICT products, and others. - Analyze costs and benefits for information requirements through product passports. - Provide accessible information to SMEs on financial support and programs. - Empowered to require supply chain actors to provide information for compliance verification. 💸 Online Marketplaces, Distributors and Dealers: Cooperate with market surveillance authorities to address illegal content related to non-compliant products. 🚦 Self-regulation Measures: Align with the objectives of the Regulation when products or product groups are not included in the ecodesign working plan. 💡 Private Enforcement and Compensation: Consumers have the right to claim compensation for damage caused by non-compliance with ecodesign requirements from manufacturers, importers, authorized representatives, or fulfillment service providers. 🎯 Product Parameters for Assessment: - Durability - reliability - reusability - upgradability - reparability - maintenance - refurbishment - presence of substances of concern - energy use, water use, resource use - recycled content - remanufacturing, recycling, recovery of materials - environmental impacts - expected waste generation. 🇮🇹 🇫🇷 🇩🇪 🇩🇰 [...] Member States: Have the authority to impose penalties in case of infringements, including fines and time-limited exclusion from public procurement procedures. The overarching goal is to make sustainable products the norm, reduce overall carbon and environmental footprints, and ensure the free movement of such products within the internal market. Other highlights? #ESPR #DPP

Finished reading the MDR? Great. But does that mean you’re done? Short answer: No. The Regulation is only the starting line. 1. MDR applies directly across the EU, yet it leaves gaps on purpose → Article 1 (3) lets Member States keep or add rules on pricing, advertising, import limits, and penalties. → Article 113 asks each country to set its own fines for non-compliance. 2. Some clauses are optional—and the option lives in national law → Custom-made implantable devices (Art. 52 (8)). → Derogations for urgent public-health needs (Art. 59). → These work only when a Member State activates them in its own statute (e.g. Germany’s MPDG, France’s Code de la Santé Publique). 3. Language and labelling are always national → Annex I 23.1 and Art. 10 (11) say labels and IFUs must be in the language required by the “Member State where the device is made available.” One pack, 27 potential language sets. 4. Clinical investigation paths still follow local acts → Art. 70 gives EU-level timelines, but application portals, ethics fees, and safety-report templates remain country specific until EUDAMED is fully live. Plan for extra admin here. 5. Horizontal laws sit outside the MDR but bite just as hard → GDPR for patient data, REACH for chemicals, WEEE for end-of-life collection, national advertising codes for health claims. Bottom line: MDR compliance gets you through the EU door. National laws tell you which corridor to walk down once you’re inside. Check both before you launch. Have a regulatory question you’d like answered? Leave a comment below. ⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡⬡ MedTech regulatory challenges can be complex, but smart strategies, cutting-edge tools, and expert insights can make all the difference. I'm Tibor, passionate about leveraging AI to transform how regulatory processes are automated and managed. Let's connect and collaborate to streamline regulatory work for everyone! #automation #regulatoryaffairs #medicaldevices

𝐓𝐡𝐞 𝟐𝟎𝟐𝟓 𝐄𝐔𝐈𝐏𝐎 𝐃𝐞𝐬𝐢𝐠𝐧 𝐑𝐞𝐟𝐨𝐫𝐦: 𝐊𝐞𝐲 𝐂𝐡𝐚𝐧𝐠𝐞𝐬 𝐘𝐨𝐮 𝐍𝐞𝐞𝐝 𝐭𝐨 𝐊𝐧𝐨𝐰 The European Union Intellectual Property Office (EUIPO) has introduced one of the most significant reforms in EU design law since the establishment of the Community design system. Effective from 1 May 2025, the reform modernizes terminology, streamlines procedures, and updates the fee structure for Registered EU Designs (REUDs). What Has Changed? 1. Terminology and Legal Framework The previous Registered Community Design (RCD) is now officially called the Registered EU Design (REUD), governed under the European Union Design Regulation (EUDR). This aligns design terminology with other EU IP rights and strengthens legal clarity across jurisdictions. 2. Centralized Filing All applications must now be filed directly with the EUIPO. Submitting through national offices is no longer permitted, and the requirement to file specimens for early filing dates has been removed. This centralization enhances procedural consistency and legal certainty. 3. Multiple Designs in a Single Application The long-standing “unity-of-class” requirement has been abolished. Applicants can now include up to 50 designs in one application, regardless of their Locarno classification, reducing costs and administrative burdens for portfolios. 4. Updated Fees Basic application: €350 Each additional design (2nd–50th): €125 Renewal fees per design: Years 6–10: €150 Years 11–15: €250 Years 16–20: €400 Years 21–25: €700 These new fees replace the previous tiered structure and align maintenance costs with the commercial value of designs. These changes are more than administrative. They represent a strategic opportunity to optimize design portfolios, ensure timely renewals, and enhance EU-wide protection. Whether you manage industrial designs, user interfaces, or emerging digital products, understanding the 2025 reform is crucial for compliance and competitive advantage. Even with these reforms, focus on quality, precision, and strategic portfolio management. Filing multiple, well-differentiated designs and ensuring renewals are timely will maximize your protection under the new regime. 🔗 For the full, in-depth article with all procedural and legal details, I’ve left the link in the comments. #EUIPO #DesignLaw #RegisteredEUDesign #IntellectualProperty #IPReform #EUDesign #LegalUpdate #IPStrategy #DesignRegistration #EUIPO2025

If your packaging can't prove it belongs on the EU market by August 12, 2026, it won't be there on August 13. That is the hard reality of the EU's Packaging and Packaging Waste Regulation, known as PPWR. This is directly applicable framework across all 27 EU member states. There is no national transposition. There is no grace period. Non-compliance by a single supplier creates immediate exposure for brand owners and importers across the entire value chain. Here is what makes this a supply chain story, not just a regulatory one: only about 10% of companies currently meet PPWR requirements. For CPG and retail, the operational implications are massive. Optimized packaging under PPWR targets could unlock annual savings of roughly 20 to 50 billion euros across the EU. Yet the compliance burden is immense: PFAS restrictions on food-contact packaging take effect in August 2026, every packaging type placed on the EU market will require a signed Declaration of Conformity, and Extended Producer Responsibility registration must be active in each member state where products are sold. The question for US companies is not whether they operate in the EU but whether their packaging reaches an EU consumer. For American brands selling through importers, distributors, Amazon FBA, or direct-to-consumer e-commerce, PPWR compliance is becoming a major priority because obligations depend on how the packaged product enters the EU market, not where the company is headquartered. A large number of US-based multinationals will directly or indirectly need to comply. The supply chain implications run deep. Supplier relationships are becoming contractually data-intensive, as suppliers are now legally required to provide all documentation necessary for manufacturers to prove compliance. IT systems, master data, supplier relationships, quality management, and compliance processes must all be structured so that information can be consistently recorded, updated, and verified. This means PPWR is not a packaging redesign exercise alone. It is a governance task that touches market access, cost control, reputation, and end-to-end supply chain visibility. For brands operating across borders, the biggest risk is fragmented, reactive compliance, while the biggest opportunity is unifying packaging strategies now by using the EU's high bar as a design baseline to reduce long-term costs, complexity, and regulatory exposure. The companies that treat PPWR as a catalyst for supply chain intelligence rather than a checkbox exercise will be the ones that maintain market access, reduce EPR costs, and build competitive advantage in a world where packaging is no longer an afterthought. It is a regulated product. If you're struggling with PPWR, reach out to me! What is your organization doing to prepare? I would love to hear how supply chain, procurement, and sustainability teams are approaching this. Drop your thoughts below. 👇