On 22 January 2025, the European Union published the final text of the new Packaging & Packaging Waste Regulation (PPWR) in the Official Journal of the EU [Download here]. This regulation replaces the Packaging & Packaging Waste Directive, the first version which came into force in 1994. The new regulation is an important part of the European strategy for a circular economy (and forms a key pillar of the Green Deal and the Circular Economy Action Plan). It sets binding requirements aimed at minimizing the environmental impact of packaging, stimulating reuse and recycling, and reducing waste generation.
The new regulation represents a major shift compared to previous directives and covers the entire lifecycle of packaging as well as packaging waste.
This article highlights a number of issues:
- A brief summary of the legislation
- What the impact will be on your operations
- Our recommended actions
1 Key points of the legislation
Reduction and minimization:
- With the PPWR, the EU has set ambitious reduction targets with 2018 as the reference year. By 2030, the amount of packaging waste per capita must be reduced by 5%, with further targets of 10% in 2035 and 15% in 2040.
- Minimization of the amount of packaging in packaging design
- Minimization of empty space in packaging
Recyclability
- All packaging must be recyclable by 2030
- From 2035 onwards, packaging must be recycled ‘at scale’
Use of recycled material
Plastic packaging must contain a minimum amount of Post-Consumer Recycled (PCR) material from
2030 onwards. The required levels depend on the application.
Safety and substances of concern
Safety requirements are tightened, with stricter thresholds for substances of very high concern (SVHCs),
including the use of PFAS.
Product bans
A wide range of product bans, including restrictions on on-site consumption in the hospitality sector and
in the accommodation sector. Additional requirements for both multipacks (grouped packaging) as well
as packaging for fruits and vegetables under 1.5 kg.
Compostable packaging
Compostable materials can only be used for tea and coffee packaging, labels on fruit and vegetables, and very thin carrier bags.
Reusable packaging
Ambitious targets are set for several applications, including:
- transport packaging
- secondary packaging
- beverage packaging
- takeaway
Labeling
Every package must display information regarding sorting and waste processing, composition and conformity (e.g., via QR code and disposal logo).
Declaration of conformity and packaging dossier
The packaging dossier has been part of legislation since 1994, but additional requirements are now being imposed. Furthermore, the Documentation must clearly demonstrate that the packaging complies with the PPWR via a declaration of conformity. The responsibility lies with the producer/importer — the entity placing the filled packaging on the market (brand owner or the party whose address appears on the packaging). This party is familiar the specific requirements of the packaged product and its content.
Producers responsible in PPWR
The regulation introduces additional responsibilities for packaging producers.
They must cover the costs for managing the packaging waste they place on the market, including collection, processing and consumer awareness campaigns to encourage proper sorting. In the Netherlands, this extended producer responsibility is already managed by Verpact (formerly Afvalfonds Verpakkingen), which already applies rate differentiation based on recyclability criteria and recycled content. More information you can find at: (LINK)
The full text is extensive. One of the key challengesis that there are many exceptions and specific rules for certain applications, which cannot be captured in a summary. Therefore, reading the legislation and consulting experts is essential. Administration of extended producer responsibility differs per country. For the Netherlands, this is governed by Verpact, which publishes the latest updates on its website.
2 Impact on your operations
The impact on the operations of the packaging industry is significant. Everyone will be affected:
- A packaging dossier for every packaging item
- A declaration of conformity for every packaging item
- Verification of recyclability or reusability, minimization and certification of sufficient recycled content in plastic packaging.
- Adjustments to extended producer responsibility (EPR)
It is therefore important to fully understand the legislation and its impact on your specific applications. Unfortunately, some aspects are still unclear. Around 30 delegated acts are still under development, which will define details such as the definition of recyclability or calculation methods for recycled content.
3 Our recommendation for action
Do not wait too long to take action. The first PPWR requirements will come into force in 2026. It is important not only to assess primary packaging, but also secondary and tertiary packaging (such as pallet wraps).
We recommend that you start by creating and completing your packaging dossiers. These could include:
- packaging specifications, including product requirements
- Documents Of Compliance (DoCs)
- reporting for EPR schemes (including documentation for rate differentiation for recyclability and recycled content)
- External certification
- Testing and validation
- Any changes made in recent years (thickness reduction, etc.)
- Reports of line tests and consumer complaints
- Comparison with compentings products on the market
OPACKGROUP offers a range of additional services. We would be happy to talk you through them. Examples include:
- mini seminar on sustainable packaging
- PPWR impact assessment / portfolio assessment workshop
- support with packaging optimization and required documentation
- continuous regulatory monitoring
- collaboration with industry associations like NRK, EFTA and Kartoflex
- collaboration with EPR organization Verpact
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