EU Packaging and Packaging Waste Regulation (PPWR): An Overview of the Final Text

Packaging has long been viewed primarily through the lenses of cost and efficiency in transportation. But times are changing. The EU is ushering in a new era with its Packaging and Packaging Waste Regulation (PPWR), a framework aimed at reshaping how packaging is used, reused, and recycled.

Adopted by the EU Parliament on April 24, the PPWR’s final text is the subject of this special piece. Since this is such a comprehensive regulation, we will not focus on specific industries such as HORECA or food, but instead offer you a general overview d and the expected impacts for businesses across the board.

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Understanding the EU Packaging and Packaging Waste Regulation

As detailed in our analysis of the original PPWR proposal, this framework was created to reduce the environmental impact of packaging and establish clear, Union-wide standards.

In a nutshell, the regulation’s measures are aimed at preventing packaging waste, boosting high-quality recycling, and harmonising the rules regarding labelling and recycled content across Member States.

Recently approved by Parliament, the PPWR will most likely enter into force by Q4 2024, and starts applying 18 months from that entry into force date, likely in mid 2026.

Once in effect, the new rules will apply to all forms of packaging regardless of the type of material used, and to all packaging waste regardless of its origin – be it from manufacturing, distribution, retail, offices, or households.

Key Measures Within The PPWR

The current framework governing packaging is the Packaging and Packaging Waste Directive (PPWD), and the decision to go from a Directive to a Regulation demonstrates the Union’s commitment to levelling the playing field and driving waste reduction throughout the block.

So let’s have a look at a summary of the key measures introduced by the PPWR:

Waste Reduction: By 2030, EU member states must decrease packaging waste per capita by 5%, followed by reductions of 10% by 2035 and 15% by 2040, relative to 2018 levels.

Recyclable Packaging: By 2030, all packaging within the EU must be recyclable, and by 2035 recyclable packaging will need to be recycled at scale. EU businesses will also be subject to Extended Producer Responsibility (EPR) fees, determined by their packaging’s recyclability performance.

Recyclable Content: New mandatory minimum of recycled content for different types of plastic packaging to be achieved by 2030, and increased in 2040. By 2030, the targets are:

• • 30% for contact sensitive packaging made from PET and for single use plastic beverage bottles;
  • 10% for contact sensitive packaging made from other plastic materials;
  • 35% for other plastic packaging.

Reuse and Refill: New targets set for reusable packaging across various sectors, with different timelines for implementation. Notably, transport packaging used within the same business or between different businesses within the EU must be exclusively reusable. And for other transport packaging, a minimum of 40% reusable packaging is required by 2030, increasing to at least 70% by 2040.

Packaging Format Restrictions: Bans on certain packaging formats by 2030, including packaging of miniature cosmetics, plastic packaging for fresh fruits and vegetables under 1.5 kg (with exceptions), and for food and beverages consumed on hospitality premises.

Packaging Minimisation: Manufacturers and importers must minimise the weight and volume of packaging, ensuring a maximum empty space ratio of 50% in grouped, transport and e-commerce packaging, by 2030. Exceptions may apply to protected designs or trademarks if they were implemented before the PPWR’s entry into force.

Labelling: Obligatory labels on packaging, detailing material composition, sorting instructions, and reuse guidelines. This includes a mandatory QR code for reusable packaging.

Green Claims: Limitations for making “green claims” regarding packaging to guarantee more accuracy and transparency.

Expected Impacts of This New Regulation

The EU’s new sustainability requirements for packaging will challenge businesses from all industries, with an especial impact on those in the HORECA sector, e-commerce, retailers, and fulfilment service providers.

The PPWR will require reusable and refillable packaging solutions for food (e.g. beverages, take-away) and non-food products, changes in transport packaging and the creation of deposit-return schemes.

These are only some of the expected impacts and, as previously mentioned, businesses will have only 18 months after entry into force to review and adapt their operations to the new standards.

Notable Points of Concern Within the New Legislation

Although highly relevant to the EU’s sustainability goals, the new regulation might not be without its faults.

Among the other concerns, experts have pointed out that the PPWR’s reuse and refill targets seem to be almost exclusively focused at the “final distributor”, which in many cases will be the retailer.

The 100% reuse obligation for transport packaging between own sites and within the same Member State could also lead to logistic and safety issues for the companies affected.

Finally, there are worries about the availability and affordability of recycled content required to meet the minimum targets, especially when it comes to plastic.

Preparing for Change: Our Recommendations for EU Businesses

Over the next few years, many details of individual provisions within the PPWR will be established through delegated and implementing acts by the EU Commission, including the Design for Recycling criteria and recycling performance grades.

This will make planning quite challenging for EU companies, who will have to stay on the lookout for these new packaging requirements, and take fast action to adapt once they are known.

However, even if many aspects of the legislation are still to be defined, there is a lot that business can already do to avoid non-compliance penalties. For all the details on current requirements, be sure to review the PPWR’s final text in full, and connect with packaging experts such as EUROPEN for more information.

Those who are not already doing it, should also now organise themselves to monitor the changes in the EU legislative landscape and recognise the trends in upcoming legislation.

Devising a new sustainability strategy to guide the organisation’s overall efforts is essential to staying competitive in the long run, as more and more businesses will use sustainability as a differentiation point.

In this fast-changing environment, relying on the expertise of specialised consultants, such as those in the Ohana team, can make these challenges not only a lot more manageable, but also to turn them into growth opportunities.

Want someone with deep experience and connections in the EU to help guide your sustainability strategy? Get in touch!

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