General PPWR impacts on all packaging

The Packaging and Packaging Waste Regulation (PPWR) is guided by several fundamental principles aimed at reducing environmental impact, promoting harmonized sustainable packaging practices, and establishing end-of-life responsibility. This new regulation will have significant and long-term effects on the European packaging market. 
 
The key ideas driving this regulation: 
 
1.    Waste Reduction: The PPWR aims to minimize waste production, regardless of the type of raw material used in packaging.

2.    Transition to a Circular Economy: The regulation encourages a shift from the historical linear economy model to a circular economy. It sets strict standards for recyclability and mandates a minimum amount of recycled content in packaging supporting the most efficient CO2e emission recycling processes and cost-competitive technologies, such as mechanical recycling. This initiative aims to decrease dependence on virgin raw materials.

3.    Replacing Single-Use Packaging: The regulation aims to promote reusable packaging over single-use, by introducing targets for reusable packaging for certain formats (beverage, transport…), restricting the use of certain plastic packaging formats (condiments, dine-in food and beverage…), and introducing an obligation to provide refillable or reusable packaging for take away food and drinks.

4.    Enhanced Control on Packaging Safety: The PPWR emphasizes packaging safety for human health. It addresses concerns related to substances in packaging to ensure innocuity.

The Regulation aims to apply to all packaging (B2C and B2B) and packaging materials introduced to European market, as well as to all packaging waste.

Article 6 - All packaging must be recyclable (2030 & 2038)

All packaging will need to comply with Design for Recycling (DfR) criteria by 2030.
DfR criteria is currently being developed by CEN and will be officially adopted by the European Commission via delegated acts by 2028. Current CEN DfR draft criteria are not final versions so assessments prior are subject to change.

These parameters will impact the recyclability of the packaging:
•    Material composition (mono or multilayers/barriers)
•    Additives (filling materials)
•    Colours (masterbatches, NIR detectable)
•    Closures and other small packaging components 
•    Sleeves
•    Adhesives and labels
•    Coatings & inks and lacquers 
•    Product residues/ease of emptying
•    Ease of dismantling/separation

When parts of the packaging separate in the recycling stream they are considered as individual components which can both lead into their own individual material stream and counted as recyclable. 
The recyclability performance will be expressed in grades, based on recyclable weight share of the entire packaging: A (>95%), B (>80%) or C (>70%). 

Packaging that is less than grade C will be banned by 2030 from the European market. By 2038, grade C will also be banned.

As of 2035, packaging will also need to be collected separately, sorted into specific waste streams and recycled at scale. For more details check the below section.

Article 7 - Minimum recycled content in plastic packaging

By 1 January 2030, any plastic part of packaging placed on the market shall contain the following minimum percentage of recycled content recovered from post-consumer plastic waste, per packaging type and format, calculated as an average per manufacturing plant and year:

Post-consumer plastic waste (PCR) is defined as waste that has been collected from the consumer after use inside or outside the EU with high-quality for separate collection and recycling. 

Exceptions are applied to packaging:
•    intended to come into contact with food where the quantity of recycled content poses a threat to human health such as baby food and medical or healthcare packaging
•    with less than 5% plastic of the total weight (e.g paper cups)

The final methodology for PCR calculation will be established by end of 2026. Current draft criteria is not the final version, so assessments prior are subject to change.

Article 6 - All packaging must be recyclable at scale (2035)

After 2035 packaging will only be allowed on the European market when 55% of the weight of the packaging is collected separately, sorted and recycled in existing infrastructures using, established processes that have proven themselves in an operational environment.

The recycling targets for 2025 and 2030, set out in the previous EU directive for all main packaging materials, will remain. Member States will be able to postpone reaching the targets by up to five years. 

Chapter VII and Article 39 - Certificate of conformity

The manufacturer or importer of packaging is required to provide a declaration of conformity covering all PPWR regulations.

Before placing packaging on the market, manufacturers shall carry out the conformity assessment procedure and have available technical documentation. Where compliance with the PPWR requirements has been demonstrated, manufacturers shall draw up a declaration of conformity. 

The technical documentation shall contain, wherever applicable, at least the following elements:

(a)    a general description of the packaging and its intended use;
(b)    conceptual design, manufacturing drawings and materials of components;
(c)    descriptions and explanations necessary for the understanding of the drawings provided under point (b) and the schemes and operation of the packaging;
(d)    a list of:
    (i)    the harmonised standards (E.g PCR content, PPWR recyclability grade) applied in full or in part;
    (ii)    the common specifications, applied in full or in part;
    (iii)    other relevant technical specifications used for measurement or calculation purposes;
    (iv)    in the event of partly applied harmonised standards or common specifications, an indication of the parts     which have been applied;
(e)    a qualitative description of how the assessments have been carried out, 
(f)    test reports.

Article 5 - Restrictions on PFAS and substances of concern

From 12 August 2026, food-contact packaging shall not be placed on the market if it contains per/poly-fluorinated alkyl substances (PFAS) in a certain concentrations.

Packaging placed on the market shall be so manufactured that the presence and concentration of substances of concern, as defined in the REACH regulation, in the packaging material or components is minimised.

Article 10 - Packaging minimisation (downgauging and empty space)

By 1 January 2030, packaging placed on the market shall be designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality, taking into account the shape and material from which the packaging is made (E.g lightweighting and minimising empty space in sales packaging).

Article 24

By 1 January 2030, economic operators who fill grouped packaging, transport packaging or e-commerce packaging shall ensure that the maximum empty space ratio, expressed as a percentage, is 50 %.

Article 29 - Reuse targets

From 2030 there are reuse targets for some packaging which aim to significantly reduce packaging waste by encouraging manufacturers to prioritise reusable packaging solutions.

Manufacturers are encouraged to develop and implement systems that facilitate the return, refill, and reuse of packaging. This includes creating infrastructure to support reusable packaging for transport, as well as collaborating with retailers and consumers.

‘Transport Packaging’ means packaging that facilitates the handling and transport of one or more sales units.

EPR fees are modulated based on the product recyclability, reusability, recycled content, and any complex material combinations that affect the environmental impact of the product. A lower environmental impact incurs lower fees, while a higher impact will incur higher fees.

Article 6
EPR fees must be ecomodulated according the recyclability performance grade of packaging (mid-2029)

Article 7
EPR fees may be ecomodulated based on the percentage of recycled content used in the packaging. Any such modulation shall take into account sustainability criteria of the recycling technologies and the environmental costs for the purposes of recycled content.

Article 12 - Harmonised labelling requirements

From 12 August 2028:

•    Packaging must include standardised labels that clearly indicate the material composition and recyclability.
•    Labels must be prominently displayed and easily readable to ensure that consumers can quickly understand the recycling instructions.
•    The use of universal symbols and terminology for recycling instructions is mandated to avoid confusion and promote consistency across all member states.
•    Manufacturers are required to provide additional information on packaging labels regarding environmental impacts and encouraging responsible consumer behaviour. Digital passports via QR codes are allowed to facilitate this. 

These harmonized labelling requirements aim to simplify the recycling process, reduce contamination in recycling streams, and support the EU's broader environmental goals. Companies that bring the final sales packaging on the market will need to adapt their labelling practices to meet these new standards. These labels will correspond to recycling bin icons.

As of 12 February 2029, reusable packaging shall bear a label informing users that the packaging is reusable. Further information on reusability, including the availability of a local, national or union-wide re-use system and information on collection points, shall be made available through a QR code. 

Packaging that is subject to deposit and return systems shall be marked with an obvious label.

Article 14 - Limits to environmental claims

Environmental claims concerning packaging properties shall only be made if said properties exceed the minimum applicable requirements set out in the PPWR Regulation. 

Environmental claims should specify whether they relate to the packaging unit, part of the packaging unit or all packaging placed on the market.

Claims must be in line with the PPWR definitions (e.g post-consumer recyclate and recyclability grade assessments)

Reuse and refill obligations in the HORECA sector

Article 32

By 12 February 2027, final distributors that conduct their business activity in the HORECA sector and make available hot or cold beverages, or ready-prepared food in take-away packaging shall provide a system for consumers to bring their own container to be filled.

Article 33 

By 12 February 2028, final distributors that conduct their business activity in the HORECA sector and that make available hot or cold beverages or ready-prepared food in take-away packaging shall give consumers the option of obtaining the products in re-useable packaging within a system for re-use.

Micro-enterprises are exempt.

Article 25 - Restrictions on single-use packaging formats

From 1 January 2030, economic operators shall not place on the market the following packaging types: 

• Single-use plastic grouped packaging. (E.g two toothpaste tubes in one carton box). This excludes grouped packaging necessary to facilitate handling. (E.g six bottles of water in shrink wrap)
• Single-use plastic packaging for less than 1.5  kg pre-packed fresh fruit and vegetables (e.g punnets of berries/mushroom tray. Exceptions can be decided upon at national level)
• Single-use plastic packaging for foods and beverages filled and consumed within the premises in the HORECA sector (e.g plastic sushi/burger tray)
• Single-use plastic packaging for condiments, preserves, sauces, coffee creamer, sugar, and seasoning in HORECA sector (e.g single serving ketchup pots)
• Single-use packaging for cosmetics, hygiene and toiletry products for the use in the accommodation sector (e.g miniature sized shampoo)
• Very lightweight plastic carrier bags (e.g exception allowed for hygiene considerations/prevention of food waste for loose food)

For further details please check Annex V (Page 102-103) of REGULATION (EU) 2025/40 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

Article 43 - Prevention of Packaging Waste

The PPWR introduces the following Member State packaging waste prevention targets to reduce the packaging waste generated per capita, as compared to the packaging waste generated per capita in 2018: 

Member States may, by 2025, request the EC to use another base year than 2018, under the condition that there is substantiated evidence justifying the request. 

2018 the EU generated 77 million tons (Packaging-Consilium) of packaging waste:
•    40% paper and cardboard
•    19% plastic – 14.63 million tons
•    18.5% glass
•    17% wood
•    5% metal

By 7 years from the EiF of PPWR (Q1 2032), the Commission shall review the targets and assess the need to include specific targets for certain packaging materials, by legislative proposal.

For further details you can check the PPWR directly here