Museums and galleries urged to prepare for stricter EU packaging rules

Museums and galleries in the UK must prepare to comply with new rules around packaging and waste introduced by the European Union this month.

The Packaging and Packaging Waste Regulation came into force on 12 August and applies to organisations around the world, including museums and galleries, that send packaging through EU countries.

Under the new law, any organisation that pays to transport packaging through any EU country will be legally deemed a “packaging producer”, with requirements to start measuring, reporting and improving the sustainability of their packaging.

Exemptions will apply to organisations that send less than 1,000kg of packaging a year, and “micro-organisations” with fewer than 10 employees or a balance sheet of less than €2m.

The law will be implemented in phases, with increasingly strict requirements introduced between now and 2040.

One of the first steps is a requirement that, by 2028, all packaging must be labelled with its full material composition.

Duty bearers will need to ensure that all packaging is designed for real-world recycling by 2030, and that their plastic packaging is composed of a mandatory minimum amount of recycled content, starting at 35% in 2030 and increasing to 65% by 2040.

Operators will also need to show that reusable or compostable material is actually being reused or composted within an approved “system of reuse”.

For imports into or out of the EU, operators will need to ensure that at least 40% of their transport packaging is being reused, while the remaining 60% must meet recyclability standards.

Reuse exemptions apply to multipack objects and to cardboard, as long as it meets recycled content standards and is recycled after use.

Shipping boxes will need also to minimise empty space in order to reduce oversized packaging, while single-use plastic packaging such as shrink wrap, shopping bags and sachets are in line to be banned by 2030.

The new regulations will impact UK museums and galleries in a number of ways.

The fine art transport firm Rokbox says the law will reshape “how art moves in and round Europe”.

“For those working with fine art packaging, fine art logistic and fine art shipping, the biggest change lies in additional reporting requirements, and the move toward formal reuse systems for transport packaging,” said Rokbox in an article about the new rules earlier this year.

Businesses must register with the appropriate national authorities for Extended Producer Responsibility (EPR), which requires mandatory reporting on packaging materials, weight, and recyclability.

Rokbox advised organisations to prepare for compliance by:

• assessing their current packaging use;
• identifying the actions required and by when;
• registering for EPR in the relevant countries;
• collaborating with reuse system providers;
• and implementing tracking and reporting processes.

The Gallery Climate Coalition said the period between now and 2030 was an “action window” for the sector.

“While enforcement of the recyclability and recycled content elements won’t start until January 1 2030, you’ll need to have your packaging fully designed, registered and certified as compliant before that date," said the coalition in a blog earlier this year.

“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.”