Do you ever put something in a box, crate or parcel and send it into, or within, the EU? If so, then you need to know about the EU’s new Packaging and Packaging Waste Regulation (PPWR), which starts to come into force this year.

Under the new rules, any organisation - including art galleries, museums, studios and the rest of the visual arts world - that sends more than 1000 kg of packaging annually through any EU country will need to start measuring, reporting and improving the sustainability of their packaging, in line with increasingly strict guidelines between now and 2030. The only exemption will be for “micro-organisations” with less than 10 staff and a turnover below €2 million.

Even if you don’t send that many shipments yourself, if you’re active in the art world then you’ll probably have partners, clients, customers or suppliers who are going to be affected, which could have knock-on effects for you.

Here at GCC, we’re planning some more detailed resources to help our members prepare for the new rules. But for now, here are the headlines of what to expect:

You are now a packaging “producer”

If you as an arts organisation are paying to move packaged objects through the EU - including any crates/boxes added on your behalf by a shipper - you will be counted as the “producer” of that packaging. As a producer, you are responsible for making sure your packaging meets the new rules.

Packaging must be made to be recycled

By January 1st 2030, 70% of the packaging you use will need to be fully recyclable. This doesn’t just mean recyclable in theory - the packaging will need to be made from materials that can be accepted into real-life recycling systems in the country where they end up. Packaging will be rated on an A-E scale for ease of recycling, and anything that scores too low will be considered non-compliant. The requirements will gradually tighten up over time.

Reusable packaging must actually be reused

Reusable packaging will be encouraged by the new legislation - but only if it is actually reused. You will need to show that the packaging is part of an active reuse scheme that meets a set of minimum requirements for the number of uses, refurbishments and end-of-life recycling.

Compostable packaging must actually be composted 

You’re probably getting the idea by now. Compostable packaging can be used as an alternative to recyclable packaging, but it won’t be enough for your packaging to simply be made from biodegradable or compostable materials. You will need to show that there is a practical route for it to be responsibly composted at the end of its life.

Plastic packaging materials will need to have a minimum recycled content

For plastic packaging materials, recyclability alone won’t be enough. You’ll also need to ensure that they contain a minimum level of recycled content at the manufacturing stage. These minimum percentages will be enforced from January 1st 2030, they will vary by type of plastic, and will increase over time.

You’ll need to avoid overpackaging

There will be specific guidelines on lightweighting and avoiding empty space within packaging. Exactly how this will apply to fine art packaging is yet to be determined. 

The first step: detailed labelling

As the first step towards the new rules, by 2028 all your packaging must be labelled with its full material composition: what exactly is it made from, and in what quantities/proportions. The specific rules for this labelling will be rolled out by 2027.

The next three years are your action window

While enforcement of the recyclability and recycled content elements won’t start until January 1st 2030, you’ll need to have your packaging fully designed, registered and certified as compliant before that date. We’d strongly recommend you start talking to your shippers and packaging suppliers about this now, rather than being caught in a last-minute rush for compliance. 

There are real consequences for non-compliance

Packaging that doesn’t meet the rules may be refused entry at any EU border. This would obviously be very bad news for any shipment en route to a time-sensitive art exhibition, sale or fair. Non-compliance can also result in large fines.

This should be a positive opportunity for change

At GCC, we hope this new legislation can be a catalyst for positive change. We know that many of our members would like to improve the sustainability of their packaging but may have hit financial or practical barriers. The new rules create a strong regulatory incentive that should help you make the case to management, partners and suppliers that this change needs to happen. 

The legislation has been designed to be broad and far-reaching. As a result, there are some areas that might need fine-tuning with regard to the art world. For example, the rules around lightweighting and minimising empty space within packaging might not be appropriate for all types of fine art. If we as a sector can show we are willing to comply with the spirit and underlying aims of this legislation - accelerating the use of sustainable and regenerative packaging in the drive towards zero waste and circularity - then that will put us in a stronger position to negotiate some exemptions if and where needed.

Watch this space for more information

We are hoping to develop more detailed and tailored guidance and support for our members on this topic. If this would be useful to you, please do let us know. In the meantime, you can find more information on the EU website here.