In our 10th newsletter of 2025, we inform you about recent regulatory developments related to Extended Producer Responsibility (EPR), new EU requirements for batteries, PET bottles, and single-use plastics, as well as important updates from France, Norway, the USA, India, and South Korea. Topics include obligations for authorized representatives in EU cross-border trade, recycled content verification, packaging registration, and take-back systems – with direct implications for manufacturers, distributors, and producers worldwide.
In this newsletter, we regularly keep you informed about the latest developments in environmental compliance.
If you have any questions, our experts will be happy to provide you with personal advice at any time.
Today's topics at a glance
EU: Battery Regulation - authorised representatives required for cross-border sales by August 2025
EU: New obligations for recycled content in PET bottles
Germany: EU launches infringement procedure over incomplete implementation of single-use plastics directive
France: Government invests €106 million in textile recycling - higher EPR fees and stricter requirements expected for producers
Norway: New packaging obligations in effect since July 2025
USA: Colorado launches EPR system for packaging
India: EPR requirements introduced for products containing non-ferrous metals
South Korea: Take-back requirements for plastic toys from 2026 onward
1. EU: Battery Regulation - authorised representatives required for cross-border sales by August 2025
The EU Battery Regulation (EU) 2023/1542 requires manufacturers and certain distributors to appoint an authorised representative for the sale of batteries and battery-powered products in other EU Member States. As of 18 August 2025, this obligation will also apply to pure distributors who sell batteries online to customers in other EU countries.
Who is affected?
Manufacturers who sell batteries or battery-powered products to other EU Member States (obligation already in effect since 18 February 2024).
Distributors who sell batteries via online shops directly to end users in other EU countries (new obligation from 18 August 2025).
German online retailers whose products are automatically listed in other EU countries via platforms like Amazon may also be affected.
Key obligations
An authorised representative must be appointed for each EU destination country
Registration is required in the respective EU Member State
👉 Tip: Review your platform sales: Check whether your products are automatically listed in other EU countries through online marketplaces (e.g. Amazon). This may trigger unintended legal obligations.
Manufacturers of single-use plastic bottles and users of recycled plastics will soon be required to comply with EU rules on calculating and verifying recycled content – including chemically recycled materials. The regulations aim to promote investment certainty and technological neutrality and may be extended to additional sectors in the future.
Who is affected?
Manufacturers of single-use plastic beverage bottles, especially PET bottles
Companies using recycled plastics, including chemically recycled materials
Recycling companies, particularly operators of chemical recycling facilities
SMEs (small and medium-sized enterprises) in the plastics or packaging sector (subject to eased requirements)
Key obligations
Calculate and report recycled content:
Companies must calculate the recycled plastic content in single-use plastic beverage bottles according to a harmonised EU-wide methodology.
The share of chemically recycled materials must also be included; energy recovery is excluded.
Ensure verification:
Annual third-party verification is required for complex processes such as chemical recycling.
For SMEs, verification is only mandatory every three years.
Check self-declarations:
Companies must verify the self-declarations provided by their business partners.
Fulfil reporting obligations:
Relevant data on recycled content must be documented and, if necessary, made available to authorities.
National authorities will conduct risk-based controls.
3. Germany:EU launches infringement procedure over incomplete implementation of single-use plastics directive
The European Commission has initiated an infringement procedure against Germany (and Estonia). Reason: The EU Single-Use Plastics Directive (SUPD, EU 2019/904) has not been fully transposed into German law, which negatively impacts the environment and the circular economy.
Identified deficiencies
Missing definitions:
For example, the definition of “port reception facilities” (facilities in ports for collecting plastic waste) is lacking, making it difficult to implement manufacturer cost obligations.
Incomplete collection obligations:
Regulations on separate collection of plastic waste and the ban on mixing waste are inadequately integrated into national law.
No awareness-raising obligations:
There are no legal requirements for information and awareness campaigns about reusable alternatives and plastic waste reduction.
Germany now has two months to respond to the Commission’s letter; otherwise, further legal action may follow.
4. France:Government invests
€106 million in textile recycling
The French government is supporting the struggling textile recycling sector with €106 million (€49 million in 2025 and €57 million in 2026). The goal is to stabilise and strengthen the collection, sorting, reuse, and recycling infrastructure across the country. This measure responds to a price drop in the export of used clothing, which is increasingly putting pressure on the industry.
Who is affected?
Textile manufacturers, importers, and retailers subject to Extended Producer Responsibility (EPR)
Actors in textile sorting and recycling, such as sorting facilities and social enterprises
The EPR system Refashion, which collects manufacturers’ contributions and channels them to the waste management infrastructure
Key obligations
Rising EPR contributions: The remuneration for sorting facilities will increase from the current €156/tonne to:
€223 /tonne in 2025
€228 /tonne in 2026 → Manufacturers should expect higher fees per textile product sold in the medium term.
Funding through the EPR system:: Support will be paid out in several instalments starting August 2025, funded by manufacturer contributions under the “polluter pays” principle.
Structural adjustments planned: At the same time, the EPR requirements catalogue for textiles will be revised to make the sector more resilient in the long term.
On 1 July 2025, a revised waste regulation came into force in Norway, affecting all companies placing packaged products on the Norwegian market—regardless of company size or country of origin.
Who is affected?
All companies supplying packaging to Norway, including importers, distributors, and online retailers
Small and micro enterprises, as the previous de minimis threshold of 1,000 kg of packaging no longer applies
Key obligations
Registration requirement: Membership in a recognised Norwegian producer responsibility scheme (e.g., Grønt Punkt Norge) is mandatory
Full cost coverage: Companies bear 100% of the costs for the collection, transport, and recycling of packaging
Reporting obligations: Introduction of a national packaging register with mandatory data reporting
Colorado is advancing the implementation of its Extended Producer Responsibility (EPR) system for packaging. The responsible organisation, Circular Action Alliance (CAA), submitted a revised implementation plan on 30 June 2025. The goal is to establish a mandatory system for financing and improving packaging recycling, which will become active in 2026. The final approval and public consultation phase will take place in late summer.
Who is affected?
Packaging manufacturers and producers placing products on the Colorado market
Responsible companies from all sectors with packaged products (exception: specifically regulated oil and lubricant packaging handled by separate Producer Responsibility Organisations)
Key obligations
Registration requirement: Since 1 July 2025, only registered producers may place packaging on the Colorado market.
Data reporting by 31 July 2025: Companies must report their 2024 packaging volumes via the Producer Portal.
Contribution payments starting in 2026: EPR fees for 2026 will be set in autumn 2025 based on reported volumes. Payments begin in January 2026.
Recycling targets by 2030: Packaging currently considered hard to recycle will be gradually integrated into the system. CAA is developing specific roadmaps and pilot projects to achieve this.
Colorado is the third US state, after Oregon and Maine, to enact an EPR law for packaging. Since then, four additional states have passed similar legislation. The program aims to distribute costs more fairly and modernise the recycling infrastructure.
7. India: EPR requirements introduced for products containing non-ferrous metals
On 2 July 2025, India introduced new EPR regulations for products containing aluminium, copper, and zinc. The “Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025” will come into effect on 1 April 2026. The aim is to promote recycling and resource conservation for non-ferrous metal products.
Who is affected?
Producers: Companies manufacturing, selling, or importing products containing non-ferrous metals under their own brand
Manufacturers:Companies producing components or products made of aluminium, copper, or zinc
Large consumers: Firms using over 1,000 tonnes of such products annually
Recycling specialists and refurbishers
Affected products range from aluminium cans, window frames, cables, motors, and household items to toys and clothing with metal content.
Key obligations
Registration requirement: Producers and manufacturers must register with the Central Pollution Control Board by 1 April 2026.
Recycling targets for producers: Gradual goals starting at 10% in 2026, increasing to 75% by 2032, based on product volumes from previous years. Certificates from recyclers or refurbishers can be used to meet targets.
Mandatory use of recycled content: From 2028, manufacturers must include minimum shares of recycled metals of Indian origin in their products (e.g., up to 25% for zinc).
Reporting obligations: Semi-annual and annual reports on volumes, recycling, and recycled content usage—specific details are yet to be defined.
8. South Korea: Take-back requirements for plastic toys from 2026 onward
From 2026, plastic toys in South Korea will fall under extended producer responsibility (EPR). Manufacturers and importers will be required to take back and recycle a specified share of their products. The aim is to ensure environmentally sound treatment of plastic toys—which have so far seen minimal recycling—and reduce plastic waste.
Who is affected?
Manufacturers and importers of plastic toys
Exempt: Companies with an annual turnover below 1 billion KRW or less than 10 tonnes of output or 3 tonnes of imports per year
Key obligations
Take-back and recycling requirement: Obligation to take back and recycle a defined proportion of marketed toys from 2026
Participation in producer organisations: Companies may join a collective take-back system and pay fees instead of managing recycling independently
Exemptions for micro-enterprises: Revenue and volume thresholds protect smaller businesses from the obligation
Broader EPR scope: Toys will be added to South Korea’s existing EPR list, which already covers packaging, electrical appliances, and other products
To ensure that you continue to receive an informative and appealing newsletter in the future, we look forward to your feedback. Feel free to send us an e-mail and let us know your opinion, comments and suggestions for topics.
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