1. Purpose
This policy sets out Murzo Group's approach to EU extended producer responsibility, packaging, batteries, WEEE, textiles, circularity obligations, and digital product passport readiness.
The purpose is to reduce the risk of selling goods into EU or EU-aligned markets without understanding producer responsibility, registration, labelling, eco-design, take-back, recycling, product data, and reporting obligations.
2. Scope
This policy applies to packaging, packaged goods, electrical and electronic equipment, batteries, accumulators, textiles, footwear, fashion products, accessories, consumer products, products with digital identifiers, and products subject to circularity, repairability, durability, or sustainability information requirements.
3. Producer Responsibility Position
Murzo Group will consider whether it is a producer, importer, distributor, distance seller, marketplace seller, brand owner, private-label owner, packer, filler, or online seller for the relevant EU or local national scheme.
Producer responsibility varies by country and product type. A UK compliance position does not automatically satisfy EU, Spanish, or other local obligations.
4. Packaging and Waste Controls
- Check whether packaging is subject to EU or national EPR registration, reporting, fees, recyclability, marking, or reduction requirements
- Check whether food contact packaging, single-use packaging, reusable packaging, transport packaging, or online sales packaging has special rules
- Avoid packaging claims that cannot be supported, including recyclable, compostable, plastic-free, recycled content, low-carbon, or sustainable
- Consider packaging minimisation, safe materials, substances of concern, and country-specific labelling before launch
5. Batteries, WEEE, Textiles and Product Data
Where products include batteries, electrical or electronic equipment, textiles, footwear, or smart components, Murzo Group will check applicable labelling, producer registration, take-back, recycling, safety, composition, and consumer information requirements.
Digital product passport requirements are developing across product groups. Murzo Group will prepare product information proportionately where a product category is likely to become subject to digital product passport rules.
6. Design and Commercial Controls
Design, sourcing, packaging, and marketing decisions should consider end-of-life obligations early enough to avoid rushed relabelling, blocked sales, or expensive market corrections.
Where local producer responsibility obligations are material, Murzo Group may decide not to supply a product into that market until registration, representative, or compliance scheme arrangements are in place.
7. Required Evidence Only
Packaging, product, registration, scheme, supplier, and product data evidence should be limited to what is required by law, customer terms, marketplace rules, authority request, or practical compliance need.
8. Prohibited Conduct
- Selling into a country while ignoring known producer responsibility obligations
- Using recycling, circularity, repairability, durability, or sustainability claims without support
- Removing battery, WEEE, textile, or packaging labels to make products look simpler
- Assuming a supplier's compliance scheme covers Murzo Group where Murzo Group is the brand owner, importer, or distance seller
- Treating digital product passport readiness as only a marketing exercise
9. Review
This policy will be reviewed when Murzo Group enters a new EU market, changes packaging model, launches battery, electrical, electronic, textile, or footwear products, or when relevant EU product passport rules become applicable.
