Südwesttextil, the business and employers’ association for the regional textile and clothing industry, has warned that the regulation’s extensive new requirements are leading to a significant rise in “bureaucratic burden” and “legal uncertainty” for companies.
The new law imposes strict obligations on textile firms regarding packaging materials, ranging from shipping cartons and product hangtags to carrier bags.
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Companies are now required to implement new labelling, conformity, and documentation processes throughout their operations.
Südwesttextil argues that instead of fulfilling political promises to reduce red tape and boost competitiveness, the regulation introduces “complex obligations and legal uncertainties.”
A particular point of contention is the intricate definition of roles and responsibilities. The association states that if a firm arranges for sales packaging carrying its brand logo to be produced by a third party, it is classified as the packaging manufacturer and bears full compliance responsibility.
In contrast, when buying generic, unbranded packaging, the compliance burden shifts to the supplier.
The German association says this differentiation is confusing and increases the practical workload for companies, especially as distinguishing roles is often not straightforward.
Regulatory clarifications arrived late, with a Q&A document published less than two weeks before the effective date.
Südwesttextil maintains that key uncertainties remain, noting that earlier guidance which appeared to require relabelling of all existing packaging was only relaxed at the last minute, offering no real relief.
The regulation also requires all packaging components, including labels, hangers, pins, films, inserts, and shipping cartons, to be marked with type, batch or serial number, and contact details.
Starting in 2028, additional rules will mandate standardised sorting instructions and information on materials. By 2030, new criteria covering recycled content, recyclability, and the minimisation of unused packaging space will come into force.
All types of packaging, regardless of the manufacturer’s precise role, must now be registered in a recycling system.
As no single EU-wide system exists, firms must register separately in every country where their packaging is distributed, posing particular burdens for small and mid-sized companies.
Südwesttextil CEO Edina Brenner said: “The implementation of the Packaging Ordinance is the latest example of excessive bureaucracy far removed from any practical application: complex role assignments, disproportionate labelling and documentation requirements, and a regulatory patchwork for registration.
“A single market that is no longer profitable, especially for smaller companies, is making a mockery of its own purpose. This has nothing to do with the political promises of reducing bureaucracy and increasing competitiveness.”
Südwesttextil has also raised objections to the requirement that all product labels be classified as packaging and enrolled in recycling systems.
The association argues that purely informational labels, which serve no protective or presentation function, should be exempt. Furthermore, it has called for a review of the rules applying to clothes hangers, many of which are reused in households instead of becoming waste.
Brenner stated: “Regulations must be based on the actual function of a product. Where labels merely provide information and clothes hangers are reused many times, additional obligations primarily lead to more bureaucracy – without any discernible added value for the environment or consumers.”
