At the same time, attention is turning to the 83 delegated acts that the European Commission is set to publish, which will specify key details of the regulation. Industry associations, including the German Rubber Industry Association, are already calling for exemptions for small quantities to ease the expected administrative burden.

In force since 11 February 2025, the regulation replaces Directive 94/62/EC and introduces extensive requirements for conformity assessment, technical documentation, and annual reporting of packaging volumes.

Implications for the coatings industry:

• Product containers: Paints and coatings are typically supplied in buckets, cans, drums or IBCs – all of which fall directly under the new regulation.

• Transport packaging: Pallets, cartons and hazardous goods containers used in logistics must also be documented.

• Packaging coatings: Metal and plastic packaging often relies on functional coatings to protect contents. These coatings also affect recyclability, meaning stricter rules are likely to accelerate demand for more sustainable and recycling-compatible coating systems.

With less than twelve months to go, coatings manufacturers and their supply chain partners should act now to ensure compliance and to assess the potential need for innovation in packaging coatings.