The EU’s New Packaging and Packaging Waste Regulation (PPWR) will completely change the way packaging is designed, produced, used, and disposed of. Businesses that act quickly stand to realize big gains towards their circularity goals as well as secure competitive market position.
On 22 January, 2025, the Official Journal of the European Union published the Packaging and Packaging Waste Regulation (PPWR). The new Regulation came into force on February 11, 2025, with first measures applicable from August 2026. This Regulation will affect anyone doing business in the EU, regardless of where the company is headquartered in the world. All companies placing products on the EU market are directly impacted as the Regulation applies to all stakeholders in the packaging supply chain within the European Union, including manufacturers, importers, retailers, and waste management companies. The Regulation applies to all forms of packaging and packaging waste placed on the EU market, essentially impacting the entire life cycle of product packaging from production to disposal. Much more than an update of the existing Packaging and Packaging Waste Directive (PPWD) it will replace, PPWR revolutionizes the way packaging in the EU needs to be designed, manufactured, marketed, used and disposed of.
Just as the Corporate Sustainability Reporting Directive (CSRD), is the most prominent sustainability reporting scheme in the EU and highly important for corporate sustainability, PPWR is a groundbreaking Regulation in the product sustainability space.
Many directives and standards regarding sustainability focus on transparency, disclosure and reporting, however PPWR actually sets the stage for a paradigm shift at the physical and market access level. Its direct modification to the entire process of packaging, from design to recycling, paves the way towards packaging sustainability and a packaging circular economy, where resources are kept in use for as long as possible with minimum waste. PPWR now stipulates that brand owners, retailers and other economic operators putting packaging and packaged goods on the European market are directly responsible for meeting concrete packaging-compliance requirements. Previously, obligations focused on Member States’ national waste management systems.
PPWR provides harmonized requirements for all of the EU and those doing business there (including companies from all over the world), which should affect several shifts in the current packaging environment. It can also be seen as a blueprint for packaging regulation in other regions of world.
PPWR will have a wide impact. Whilst this Regulation will naturally be of particular interest to compliance and sustainability officers, it will also be essential to any company producing or using packaging, since it sets sustainability criteria such as recyclability as a condition to EU market access. In other words, packaged goods that do not align with the requirements of PPWR will not be allowed on the EU market.
It will also affect company stakeholders in procurement, R&D, packaging design and selection, operations, logistics, and sales and marketing. It will further impact the entire packaging value chain, including raw material suppliers, manufacturers, distributors, brand owners, retailers, consumers and waste collectors and/or recycling operators.
PPWR is stringent, measurable and favors innovation
PPWR directly influences an organization’s product and packaging procurement strategy (e.g., sourcing and purchasing recycled content) as well as product development, innovation and end-of-life. The Regulation’s more stringent performance requirements also present enormous opportunity for businesses to improve their strategic market position by meeting consumer demand for more sustainable packaging.
PPWR will be a game changer in driving decarbonization, influencing entire value chains, and advocating circularity through its requirements on material composition and recyclability. The new Regulation will drive businesses to compete on how best to comply by eliminating opinion-based “perceived sustainability metrics” and replacing them with fact-based “hard” requirements (such as the actual recycled content). In turn, this competition can be anticipated to drive real change in many industries as measurable targets are set, achieved and possibly exceeded. Those companies that cannot meet the requirements will be excluded from the market.
Alongside influencing innovation within organisation, PPWR can also unlock significant financial savings. Companies selling goods in the EU must ensure their packaging is assigned the correct Eco-modulated fee, a system where fees per kilogram of packaging material placed on the market vary based on their recyclability and recycled content. If they don’t, their packaging is automatically placed in the highest fee category under Extended Producer Responsibility (EPR) regulations.
ERM estimates that this default categorization could lead to companies paying 70-90%* more than necessary. Complying with PPWR requires companies to use more recyclable materials in their packaging, reducing unnecessary costs.
*Data has been sourced from publicly available information provided by producer responsibility organizations.
The PPWR harmonizes practices for all concerned economic operators and Member States. The regulation will, among other requirements:
- make recyclable packaging mandatory
- require minimum post-consumer recycled content in plastic packaging
- minimize packaging to prevent waste (including mandatory deposit return system - DRS),
- require and improve reuse and refill systems
- restrict certain Substances of Concern (SoC such as PFAS)
- ban certain packaging formats/applications
- require a new eco-system of recycling to develop
- prohibit incineration or landfilling of packaging
- require producers, users (brand owners, retailers) of packaging as well as end of life operators to document compliance with PPWR.
Major points of PPWR at a glance:
Recyclability
Under the PPWR, all packaging used on the EU market must be designed for recycling (DfR) by January 2030; and EPR (extended producer responsibility) fees must be eco-modulated based on an EU-wide recyclability performance score.
Post-Consumer Recycled Content in Packaging Plastic
Any plastic part in packaging, provided plastics make up more than 5% of the packaging by weight, must contain a minimum amount of post-consumer recycled content (e.g. 10% for contact-sensitive packaging, higher for other materials), and this must be implemented for the types of packaging and by the deadlines detailed below.
Waste prevention and minimization
By 2030, Member States will be required to tackle waste reduction by implementing measures for economic operations, with new reduction targets of 5%, 10% 15% for 2030, 2035, and 2040, respectively. However, these reduction values are based on a 2018 per capita baseline. Waste has continued to grow since so actual reduction percentages are likely to be higher.
Reuse and refill
More packaging must be reusable, and targets for reuse must be updated. Ultimately, reuse targets will include the full spectrum of the supply chain. For reuse, the current focus remains on the final distributor (e.g. retailers) instead of all economic operators.
Deposit return schemes (DRS) must be implement by Member States by January 2029, to accommodate single-use plastic and metal containers up to 3 liters.
By February of 2027, consumers in the hotels, restaurants, and catering (HORECA) sector should be able to take away food or beverages in their own containers at no additional cost. The following year, operators will need to offer reusable food containers at no additional cost to the customer.
SoC (Substances of Concern)
Beginning in August of 2026, the PPWR will prohibit food packaging from the EU market if it contains per- and polyfluorinated alkyl substances (PFAS) in concentrations above certain (extremely low) thresholds, whether intentionally added or due to other unintentional contamination.
Prohibited Packaging Formats
Several formats of single-use packaging will no longer be acceptable beginning in January 2030:
- Certain Single-Use Plastic (SUP) retailer packaging types
- Certain SUP packaging for less than 1.5 kg of fresh fruit or vegetables
- Certain packaging formats for foods and beverages filled and consumed in the HORECA sector
- Packaging for individual portions (e.g., coffee creamers, sugar) in the HORECA sector
- Single-use packaging for cosmetics, hygiene and toiletry products for the use in the accommodation sector
*According to NACE Rev. 2, the "accommodation sector" is classified under Section I, Division 55, which specifically refers to "Accommodation" activities, encompassing various types of short-stay lodging like hotels, hostels, camping grounds, and holiday apartments, essentially covering any establishment providing temporary lodging for guests
Begin a self-assessment so you can act now
If your organization deals at all in packaging or packaged goods, swift action is critical. A clear and comprehensive understanding of your packaging portfolio and inventories will be key in assessing the implications of PPWR on your obligations or those of your customers. Evaluate how your cross-functional teams work together and inform one another (Design, R&D, Procurement, Sales, Marketing, Operations, Logistics, Reporting, etc.) to help you develop a proactive approach to optimizing opportunities offered by the new regulation.
A few questions can help you consider where you might need to take action:
- What investments are you making right now in packaging innovation (e.g., moving to recyclable mono-materials, recycling technologies, getting access to recycled content, removing unnecessary packaging units) to align with future PPWR requirements?
- What strategy do you have to increase recycled content in plastic packaging that you manufacture/procure/place on the market and how would you mitigate potential supply shortages for suitable recycled plastics?
- How does your business engage and share ideas with peers, industry associations and other stakeholders to make sure you’re taking the right steps to prepare?
- How will you adjust packaging and logistics flows to enable and implement reuse systems? What measures will you take to encourage consumer participation in refill systems (e.g., allowing them to bring their own containers to takeaway outlets or refill stations?).
The year 2030 might seem a long way off, but for most PPWR requirements to be in place by then you need to start acting now. Some first steps can help your company prepare and prioritize action:
- Develop a dedicated packaging and packaging waste roadmap and action plan for integrating recyclability and/or reuse systems and circularity into your packaging strategy. Consider the entire value chain and the existing and future infrastructure for collection, sorting, and recycling or return/refill schemes.
- Gather information about your supply chain partners´ packaging so you can develop a broader supplier engagement plan that integrates responsible sourcing requirements and compliance with other product-related regulations.
- Gain an understanding of the interconnectivity of PPWR and the broader EU environmental legislation as different regulations can be relevant (e.g. in respect to the EU’s PFAS restriction proposal) and these can jointly feed into your packaging strategy. Monitor legislative developments on an ongoing basis as the EU will finetune PPWR requirements through secondary legislation.
- Be sure your marketing strategy leverages packaging as a branding component, to maximise the opportunity to amplify your efforts to grow brand reputation and achieve or maintain competitive edge.
