PPWR in the EU: challenges and opportunities for producers

The abbreviation PPWR stands for “Packaging and Packaging Waste Regulation”, also known as the EU Packaging Regulation, which affects all EU member states.

The final version of the Packaging and Packaging Waste Regulation (PPWR) was presented orally at the plenary session of the European Parliament on 26 November 2024. In accordance with the corrigendum procedure, corrections to the version provisionally adopted in April 2024 were automatically adopted, as no objections were received within 24 hours of the announcement. The PPWR thus received the approval of the European Parliament.

The final version is then adopted by the Council and subsequently published in the Official Journal of the European Union. The regulation enters into force 20 days after this publication and becomes generally applicable 18 months later. 

What does this mean in concrete terms for producers and manufacturers who want to sell packaged products in the EU? What obligations will they face and how can they fulfil them?

PPWR replaces Directive 94/62/EC – which areas does it cover?

The PPWR is a European Union regulation that aims to create a standardised legal framework for the handling of packaging and packaging waste in all EU member states. The aim is to promote the circular economy through harmonised requirements and to strengthen the internal market.
The main topics of the regulation are recyclability, a mandatory recycled content in plastic packaging, packaging minimisation, labelling, packaging bans and reusability.

A rough overview of the main changes resulting from the PPWR:

• Recyclability: Packaging must be recyclable. Performance levels (A-C) are to be introduced for the assessment of recyclable design (recyclability below 70 % – not considered recyclable). Manufacturers’ financial contributions should be modelled according to the performance levels.
• Recyclate content: Plastic packaging must contain a minimum percentage of recycled material.
• Packaging minimisation: Packaging must be reduced to a necessary minimum in terms of weight and volume. Packaging without a packaging function and cheat packaging (e.g. double bottom) may not be placed on the market. The empty space in the packaging must be reduced to a minimum.
• Labelling: Packaging (including e-commerce packaging but excluding transport packaging) must be labelled with its material composition. The associated containers for separate collection should be labelled in the same way to facilitate correct waste separation.
• Packaging bans: A ban on certain single-use packaging is planned. This includes unnecessary plastic group packaging (e.g. shrink wrap), plastic food and beverage packaging that is filled and consumed in the catering trade (e.g. disposable plates) and single-serving packs for products such as sauces, milk, and sugar in the catering trade (except for on-the-go consumption).
• Reusability: For certain transport and sales packaging and collective packaging, mandatory reusable portions are provided for. In addition, the member states are obliged to set up deposit systems for single-use plastic drinks bottles and single-use metal containers.

Once the new regulation comes into force, many types of packaging as we know them today will no longer be permitted. It is therefore important that companies prepare for these changes at an early stage and push for more sustainable packaging solutions.

Who does the EU Packaging Regulation apply to?

Depending on the role of an economic operator (manufacturer, supplier, importer, distributor, etc.), different obligations must be met as a result of the planned regulation. The sector in which they operate is completely irrelevant, although there may be significantly more changes in some sectors than in others. Packaging manufacturers face challenges in switching to more environmentally friendly materials and designs to fulfil the requirements of the new regulation. In some cases, this also requires investment in research and development to develop new, sustainable packaging solutions while ensuring the functionality and safety of the packaged products.

Design for recycling – a model for the future or just Greenwashing?

Legal requirements can and must continue to create a framework that encourages manufacturers to develop more environmentally friendly and recyclable products if we want to boost the European circular economy. In addition to the PPWR, there are many other environmental regulations (e.g. the European Supply Chain Act, the Batteries Act, the Directive against Greenwashing, or measures to prevent microplastics, etc.) that are either already in the starting blocks or are currently being negotiated. The EU has also already proposed eco-design regulations that set minimum standards for durability, reparability, and recyclability. These regulations could help manufacturers to develop more sustainable products and thus reduce the amount of waste that ends up in landfills or incinerators. Overall, it is a combination of conscious design, material selection and regulatory frameworks that can improve the recycling of products and drive the circular economy forward.

Find out more now and get support from our experts!

To improve the recycling-friendly design of products and increase their recyclability, manufacturers should consider subsequent disposal and recycling as early as the development phase of a product. This includes, for example, taking care during production to select materials that are easy to separate and recycle. Composite materials that are difficult to separate should be avoided. Products should also be designed in such a way that different components can be easily separated and therefore optimised for recycling. The use of modular designs and standardised parts can in turn improve reparability and thus also extend the service life of the products.

It is therefore necessary for companies to obtain comprehensive information on which regulations apply to them and in which areas they will need to improve their organisation in the future. If you don’t want to deal intensively with the new regulations yourself, you are well advised to commission RecycleMe’s team of experts. Our employees are familiar with the subject matter and regularly monitor upcoming regulations and any developments relating to extended producer responsibility.