EU Compliance & Market Access
Environmental Product Compliance
Environmental rules attached to what you sell — origin traceability, packaging obligations, and green claims law.
Regulation (EU) 2023/1115
EUDR — EU Deforestation Regulation
Requires operators and traders to ensure regulated commodities and derived products sold in the EU have not contributed to deforestation or forest degradation after 31 December 2020.
- In force
- 29 June 2023. Application date: 30 December 2025 (large operators); 30 June 2026 (SMEs).
- Regulated commodities
- Cattle, cocoa, coffee, palm oil, soya, wood, rubber — plus derived products containing or made from these commodities.
- Thailand exposure
- Palm oil (ingredient in some pet foods and treats), rubber (pet accessories, toys).
- Due diligence obligations
- Collect geolocation data of production plots, assess deforestation risk, mitigate risk, submit due diligence statements via EU information system.
- Penalties
- Minimum 4% of annual EU turnover for non-compliance.
Regulation (EU) 2025/40
Packaging & Circularity — PPWR
The Packaging and Packaging Waste Regulation replaces Directive 94/62/EC and sets binding targets for recyclability, recycled content, and packaging minimisation.
- Adopted
- January 2025. Phase-in: most requirements apply from 2030, some from 2035.
- Recyclability
- All packaging must be recyclable by 2030. Recyclability assessed against harmonised EU criteria.
- Recycled content — plastics
- 10–35% by 2030 depending on packaging type; 25–65% by 2040.
- Packaging minimisation
- Empty space in grouped and transport packaging must not exceed 50%.
- Labelling
- Mandatory QR code linking to recycling information; harmonised recyclability labelling across EU member states.
- Pet food relevance
- Pouches, trays, tins, and treat bags are all in scope. Multi-layer flexible packaging faces recyclability challenges under harmonised criteria.
Directive (EU) 2024/825 · Green Claims Directive (proposed)
Green Claims
Two instruments tackle greenwashing — the Empowering Consumers Directive bans specific misleading claims now; the Green Claims Directive will require pre-verified substantiation.
- Directive 2024/825
- Empowering Consumers Directive. In force March 2024, transposition by March 2026. Bans generic claims — "environmentally friendly", "eco", "green", "carbon neutral" — without substantiation. Bans carbon offset-based neutrality claims. Bans sustainability labels not based on approved schemes.
- Green Claims Directive
- Proposed (COM/2023/166). Requires explicit, verifiable, third-party verified environmental claims before use. Status: under negotiation as of 2024.
- Relevance for pet retail
- "Sustainable sourcing", "responsibly sourced", "ocean-friendly" claims on packaging and marketing must be substantiated.
- Substantiation requirement
- Claims must be based on recognised scientific evidence, cover the full lifecycle where relevant, and be verified by an accredited third party.
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