101 EDITIONS
FEBRUARY 22 – 24, 2026 / FIERAMILANO (RHO)

Think Green-

Sustainability without compromise

 

Polluter pays

The Extended Producer Responsibility (EPR) is a European Union policy tool based on the principle of “the polluter pays”. This mechanism shifts the financial and operational cost of waste management (collection, sorting and recycling) from local authorities to producers. Every company pays a contribution for every unit placed on the market, which funds end-of-life infrastructure for the product. The fees are adjusted according to how sustainable the product is.

The EPR framework is evolving fast: the new Packaging and Packaging Waste Regulation (PPWR) became applicable from August 2026, the Battery Regulation is already in force, and EPR for the textile sector will be rolled out between 2027 and 2028. As individual Member States set their own fees and specific rules, the same product can be subject to different obligations depending on the national market.

WHO HAS EPR OBLIGATIONS IN THE EU? FOOTWEAR TOO

The obligation applies to any legal entity that first places a product on the market of a Member State, including through distance selling. This definition covers: manufacturers selling under their own brand, importers from non-EU countries, distributors selling under a private label, online platforms and distance sellers based outside the EU.

Non-EU companies must appoint a local authorised representative in each Member State to handle registration and compliance. Aside from a few national exceptions for specific flows, there is no EU-wide minimum threshold for turnover or volume: compliance and registration are mandatory before the first unit is shipped.

PACKAGING FOCUS: THE NEW PPWR REGULATION (2026)

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), in force since 11 February 2025, became operative on 12 August 2026, harmonising the rules across all 27 Member States without the need for national transposition.

If you manufacture, import or distribute footwear on the European market, cardboard boxes, internal tissue paper, protective bags and plastic or cardboard shoe supports used to keep the shoe’s shape are all considered packaging to all intents and purposes. This means a range of obligations apply immediately and progressively

The main impacts for producers include:

  • Mandatory ecodesign: all packaging will have to be recyclable by 2030. Non-compliant solutions will face financial penalties or market restrictions.
  • Fee eco-modulation: EPR contributions will be mandatorily differentiated. Packaging that is hard to recycle will pay higher fees, while sustainable packaging will get discounts.
  • Recycled content: minimum requirements for recycled plastic in packaging are being introduced, with thresholds rising in 2030 and 2040.
  • Representation for non-EU entities: in addition to national delegates, non-EU producers will need to appoint a new authorised representative at European level.

Click here for a concise overview of the new rules.

Next week we stay on the topic of packaging and look at the advantages of digital packaging.