EU Single Market Strategy: dealing with fragmented rules on packaging, labelling and waste

On 21 May 2025, the European Commission published a Single Market Strategy with a series of actions focusing on removing the 10 most harmful barriers to intra-EU trade and investments (see press release, Q&A and factsheet). 

According to the Commission, these are the 10 most harmful barriers to the free movement of goods and services at the moment (aka the “Terrible Ten”), based on feedback from stakeholder consultations:

• Complicated business establishment and operations
• Overly complex EU rules
• Lack of Single Market ownership by Member States
• Recognition of professional qualifications
• Long delays in standard-setting that weigh on innovation and competitiveness
• Fragmented rules on packaging, labelling and waste
• Outdated harmonised product rules and lack of product compliance
• Restrictive and diverging national services regulation
• Burdensome procedures for temporary posting of workers
• Territorial supply constraints

This blog post focuses on what the Strategy says the Commission plans to do to address fragmented rules on packaging, labelling and waste (i.e. the circular economy aspects) - primarily by making product labels clearer and more accessible and by simplifying extended producer responsibility (EPR) schemes for end-of-life products.

In particular, the Single Market Strategy says the Commission will:

Digital Product Passport (DPP) - 

• Harmonise labelling rules via sectoral legislation (for example, under the new Packaging and Packaging Waste Regulation) and facilitate the roll-out of the DPPs 

By way of background to DPPs, the new Ecodesign Regulation for Sustainable Products (ESPR), which was adopted in 2024, introduces DPPs, as well as sustainability requirements for almost all kinds of products placed on the EU market and new obligations for the handling of unsold products (see our previous blog post). 

The DPP will be mandatory for all products regulated under the ESPR. This digital tool will store detailed and up-to-date information about a product's environmental attributes, including its manufacturing process, materials used, energy efficiency, and disposal guidelines to boost transparency and enable consumers to make more informed purchasing decisions based on sustainability credentials. 

Individual DPP requirements will be set out in delegated acts relating to individual products or product groups. The relevant requirements will be adopted no later than 31 December 2026. Further secondary legislation will address organisational aspects relating to DPPs. The Commission is consulting on the DPP to gather views on how data should be stored and managed by service providers and on the need for a certification scheme for such service providers. The consultation closes on 1 July 2025.

Extended producer responsibility (EPR) schemes - 

• Remove unjustified authorised representative requirements in EPR schemes and reduce reporting obligations, including by limiting them to an annual frequency. This will be done via a Circular Economy Omnibus in Q4 2025. 
• Address the fragmentation created by different national EPR schemes, including through a digital one stop shop for information, registration and reporting. This will be done as part of the Circular Economy Act in Q4 2026. 

Waste - 

• Reform end-of-waste and by-product criteria.
• Provide a more harmonised framework for reaching end-of-waste and by-product status.
• Facilitate cross-border shipments of waste feedstocks for recycling. 
• This will be done as part of the Circular Economy Act in Q4 2026.