Understanding the EU Packaging and Packaging Waste Regulation (PPWR)

What is PPWR?

The Packaging and Packaging Waste Regulation (PPWR) is a recently enacted legislation in the European Union (EU) that replaces the previous Packaging and Packaging Waste Directive. Legally effective as of February 2025, this seeks to reduce packaging waste, promote recyclability and reusability, and harmonize packaging rules across member states. This standardization aims for stronger environmental and circular economy outcomes.

Importance

The EU Packaging and Packaging Waste Regulation 2025 addresses the growing issue of product packaging waste, which was worsened by the inconsistent application of the 1994 Directive across member states. Standardizing these rules was the most effective way to help the region achieve its Green Deal goals for a circular economy.

Understanding the new EU packaging regulations is crucial for businesses. With its binding rules on design, recyclability, and waste reduction, manufacturing companies and their supply chain partners proactively meet the region’s sustainability goals and reduce their environmental impact. Beyond avoiding expensive fines and penalties, companies can innovate, improve resource efficiency, and maintain a competitive edge in the global market.

What’s in the Law: Waste Packaging Regulations Explained

Harmonizing the rules under the new packaging waste regulations is crucial for manufacturers, producers, and retailers operating in the EU’s member states. Aside from upholding consistent waste and standards, this reduces administrative burdens, making compliance easier. These are the key provisions to understand:

Importance of Heat Exchanger Inspections

Recyclability Requirement

Under PPWR’s Article 6, all packaging placed on the EU market must be collected, sorted, and recycled effectively, supporting waste management goals and the circular economy. Here are some specific examples:

• Composite packaging (e.g., multilayer plastic and foil) that can’t be separated isn’t allowed.

• E-commerce and takeaway food should shift to reusable packaging.

• Single-use packaging for hotel products (e.g., shampoo, soap, lotion) will be banned.

Ban on Certain Single-Use Plastic Packaging

According to Article 25 – Annex 5, specific single-use plastic packaging is banned starting January 1, 2030. The following will soon be prohibited:

• Plastic outer packaging for bundling goods at the point of sale

• Packaging for fresh, unprocessed fruit and vegetables under 1.5 kg

• Food and beverage packaging consumed on-site, like single-use condiment packages

Refill and Reuse Obligations

Article 32 of the European packaging regulations mandates refill and reuse systems, moving away from the “take-make-dispose” model. Here are some sectors that should take note of this:

• Restaurants and cafes are required to ask customers to use their own containers at no additional cost.

• Hotels and inns should use larger, refillable bottles for toiletry items in the rooms.

• Transport and sales packaging have specific targets for the reuse of packaging.

Reduction of Packaging Weight and Volume

Unnecessary packaging must be minimized through better designs, optimizing weight and volume without compromising product protection. Avoidable or excessive packaging includes:

• Double wrapping or two or more extra layers for protection or presentation

• Overly large boxes with air cushions or paper stuffing

• False bottoms or adding structural features (e.g., raised bases or hidden compartments) to create the illusion of more content

Restrictions on Hazardous Substances

Article 5 of the regulation on packaging and packaging waste places limits on substances of concern in food contact packaging. Aside from upholding environmental standards, this also aligns with good manufacturing practices for food packaging. The following are restricted:

• Per- and Polyfluoroalkyl Substances (PFAS) applied as barrier coatings for grease

• Heavy metals in inks, pigments, stabilizers, and adhesives

• Bisphenol A (BPA) in plastics and resins

Marking, Labeling, and Reporting Requirements

The old directive allowed for different interpretations and implementations, making it difficult to track packaging waste. PPWR strengthens standards for marking and data reporting to enhance transparency and traceability throughout the packaging lifecycle. Here are some examples:

• Multiple components must be marked separately (e.g., glass bottle and plastic cap).

• Labels should display clear, standardized disposal instructions (e.g., recyclable, compostable, reusable).

• Producers must submit detailed annual reports to national authorities, including packaging types and materials, recycled content percentages, and reusability data.

Extended Producer Responsibility (EPR)

Under the PPWR, producers are financially and operationally responsible for their packaging throughout its entire lifecycle. The strengthened EPR provides a strong incentive for packaging manufacturers to create sustainable items. Here are a few specific mandates:

• Deposit-return schemes for beverage containers

• E-waste recycling programs

• Eco-modulated fees for packaging

Timeline for Manufacturers and Businesses

The European packaging and packaging waste regulation will significantly affect businesses, particularly manufacturers. To better prepare for more stringent packaging manufacturing standards and mandates, familiarize yourself with the staged approach of the new regulations:

PPWR Compliance Best Practices

The PPWR introduces complex, far-reaching changes that may initially overwhelm manufacturers. Adopting strategic best practices can help businesses overcome potential challenges and turn the regulation into an opportunity for innovation and sustainability. Here are some best practices to implement:

Gain a thorough understanding of PPWR requirements.

Manufacturers who fail to fully grasp regulatory requirements risk non-compliance, resulting in severe fines, product recalls, or supply chain disruptions. A thorough understanding of the law’s intricate details is essential to mitigate these risks.

Assess the current packaging portfolio.

A comprehensive packaging audit is essential. It should evaluate recyclability criteria, identify banned materials, assess labeling readiness, and optimize size efficiency. This process prevents non-compliant or inefficient packaging from entering the production.

Establish robust documentation and reporting systems.

Inconsistent or incomplete recordkeeping hinders compliance, delays audits, and attracts penalties. Digitize and centralize compliance data to ensure the company upholds the new EU regulation.

Train and align teams and partners.

Due to the complexity of the PPWR, there’s a significant risk of misalignment across the supply chain, particularly with third parties. Continuous and comprehensive training on the new regulation is a non-negotiable requirement.

Engage in EPR programs.

Failure to participate in EPR schemes can result in blocked market access or legal consequences in EU member states. Join national EPR programs and pay fees that are adjusted based on packaging recyclability. Additionally, make sure your products are traceable throughout the entire waste management process.