Regulations on Products and Packaging – What Are the Key Legislative and Regulatory Developments in France and Europe?

Upcoming Developments in CSR under the AGEC Law in France

Assessment of the First 3R Decree (2021-2025) – Reduction, Reuse, and Recycling of Plastic Packaging

• Initial target: 20% reduction in single-use plastic packaging by the end of 2025.

Implementation of the 3R Strategy for 2025-2030

• A new 3R decree is expected in 2025, specifying reduction, reuse, and recycling targets.
• A public consultation is scheduled for the second half of 2025.
• Increase in the proportion of reused packaging placed on the market annually (7% to 8%, depending on company turnover).

Changes in Eco-Modulation Criteria

• From January 1, 2025, several Extended Producer Responsibility (EPR) schemes will see changes in eco-modulation criteria, requiring companies to contribute financially to their respective recycling sectors.

Adoption of the PPWR (Packaging and Packaging Waste Regulation) at the European Level

• The PPWR Regulation was adopted on December 19, 2024, and published in the Official Journal of the European Union (OJEU) on January 22, 2025.
• It will come into effect on August 12, 2026.

Interaction with the AGEC Law

• The PPWR incorporates measures inspired by the AGEC Law, raising debates on their implementation and complementarity.

Key Measures

• Reduction of packaging through eco-design.
• Integration of recycled materials into packaging.
• Setting reuse targets.
• Mandatory recyclability for all packaging by 2030.

Deployment of the ESPR (Ecodesign for Sustainable Products Regulation) at the European Level

• Authority: The European Commission is empowered to adopt delegated acts to complement the ESPR.
• These acts will define:
  • Eco-design requirements.
  • Requirements for Digital Product Passports (DPPs).

Implementation Timeline

• Priority products will be targeted from 2027-2028.

Eco-Design and Digital Product Passports

• Eco-design: Integrates environmental considerations into product development, aiming for the lowest possible environmental impact throughout the product lifecycle.
• Digital Product Passports: Enhance sustainability and transparency by providing consumers with clear product information.

Key Takeaways for Businesses

• These upcoming regulatory changes present opportunities for businesses.
• They serve as levers to strengthen CSR strategies and enhance competitiveness.