The EU Packaging and Packaging Waste Regulation: Impacts and Prospects Upon Final Adoption

The EU’s Packaging and Packaging Waste Regulation (PPWR) is a major step forward in sustainability efforts. Building on the foundation of the Packaging and Packaging Waste Directive (PPWD), the new regulation focuses on further reduction of packaging waste, increase of reuse and recycling, and establishment of stricter requirements for packaging on the EU market. These measures aim to minimize waste disposal and drive the shift towards a more resource-efficient economy.

First proposed in November 2022, the PPWR achieved a major milestone on March 4th, 2024, when the Parliament and the Council reached a provisional agreement on its text. The EU Parliament then approved the proposal on 24th April 2024, and final adoption is expected by the end of the year, waiting for formal approval by the Council. Once formally adopted, the PPWR will mark the beginning of a significant transformation for businesses, consumers, and waste management systems across Europe.

The new regulation reflects the EU’s commitment to reducing the environmental impact of packaging and ensuring a sustainable future. It is part of the EU’s Circular Economy Action Plan (CEAP), launched in March 2020 as a key element of the European Green Deal, Europe’s new strategy for sustainable growth. The CEAP aims to drive the EU’s transition toward a circular economy by reducing pressure on natural resources, cutting waste, and supporting the goal of achieving climate neutrality by 2050.

Why is the PPWR necessary?

The PPWR is an essential response to the pressing environmental and economic challenges posed by packaging waste in today’s context. Between 2011 and 2022, the volume of packaging materials increased significantly, rising by 20.6%, outpacing economic growth and intensifying its environmental footprint.

Packaging plays an important role in protecting and transporting goods and is a key driver of economic activity in the EU. However, its benefits come with significant environmental costs. Packaging is a major user of virgin materials, consuming 40% of all plastics and 50% of all paper in the EU, and it accounts for 36% of municipal solid waste. Despite these impacts, reuse and recycling rates remain low, creating a barrier to achieving a low-carbon circular economy.

At the same time, inconsistent regulations across EU Member States make it harder for the packaging market to work smoothly. Different approaches to issues like labeling, defining recyclable packaging, and producer responsibility fees create legal uncertainty and make businesses hesitant to invest in new, sustainable packaging ideas.

Scope and Goals: What the PPWR Deals With

The PPWR breaks from the gradual updates of past directives by introducing legally binding obligations directly on businesses. It brings significant new measures for packaging design, waste prevention, reuse, and recycling, alongside ambitious environmental standards. It wants to overcome packaging wasting problems and promote a more sustainable packaging market.

With this aim, the regulation addresses every stage of the packaging lifecycle: from design and production to waste management and recycling. Its scope includes all types of packaging across sectors, including sales, transport, and distribution packaging. Exemptions exist for certain categories, such as medical, veterinary, and hazardous goods packaging, to ensure compliance with safety and hygiene standards.

The regulation’s primary goals include:

1. Harmonizing EU Packaging Rules: Establishing a unified framework to eliminate barriers to trade and competition while ensuring high environmental standards.
2. Preventing Waste: Reducing packaging waste per capita by 15% by 2040 compared to 2018 levels.
3. Promoting Reuse: Mandating reusable packaging systems for transport, beverages, and other sectors, with targets starting at 10-40% in 2030 and rising thereafter.
4. Enhancing Recyclability: All packaging must be designed for recycling, with stricter standards and scoring systems introduced over time.
5. Boosting Recycled Content: Plastic packaging will need to meet minimum recycled content thresholds (e.g., 30% by 2030 for certain categories).
6. Reducing Harmful Substances: Limiting substances of concern, such as PFAS and heavy metals, to ensure safety and sustainability.

The PPWR’s Core Provisions

The regulation includes several transformative provisions that will reshape the packaging landscape:

1.Packaging Design Requirements

The PPWR introduces mandatory design-for-recycling criteria, ensuring all packaging can be processed using existing recycling technologies. From 2030, packaging must meet these criteria, and by 2035, recyclability at scale will be mandatory. Packaging will be graded from A to E based on recyclability, with E-grade packaging banned from the market by 2030.

2. Waste Prevention and Over-Packaging

To combat excessive packaging, the regulation imposes strict limits on material use. Double walls, false bottoms, and unnecessary fillers are prohibited, and empty space in transport and e-commerce packaging must be minimized (max 50%). Over-packaging will no longer be justified for aesthetic reasons.

3. Reuse and Refill Targets

PPWR sets ambitious targets for the reuse and refill of packaging to reduce environmental impact. From 2030 onwards, specific percentages of packaging used for beverages, food, household appliances, and transport must be reusable, with targets increasing significantly by 2040. For instance, 90% of large household appliances must use reusable transport packaging by 2030, and 80% of beverages sold for take-away must be in reusable containers by 2040.

Where reuse is intended, packaging has to be designed to complete certain number of cycles and adhere requirements on empting, uploading, refilling and reconditioning.

4. Recycled Content in Plastics

From 2030, all plastic packaging must contain minimum recycled content, with stricter thresholds for sensitive uses such as food and medical packaging. The recycled materials must meet EU standards, ensuring high-quality outputs.

5. Bans on Single-Use Packaging

Certain single-use formats, including very lightweight plastic bags and plastic multi-packs, are banned. Restrictions also apply to packaging for fresh produce and condiments in restaurants.

6. Compostable Packaging

The regulation limits compostable materials to specific applications like tea bags, coffee pods, and sticky labels, ensuring compatibility with bio-waste systems.

7. Labeling and Transparency

PPWR introduce mandatory labelling requirements to improve transparency and sustainability in packaging and waste management. Packaging must display labels detailing material composition, reusability, and recycled content, with some information provided via QR codes. Harmonized labeling systems and digital marking technologies will standardize information across the EU, while waste containers for packaging must also feature labels to ensure proper sorting and recycling by 2028.

In order to monitor whether the regulation is respected within the Member States, companies will have to make declarations of their packaging conformance with evidence provided by suppliers and assessed either in-house or by third parties. The PPWR requires Members to report data on packaging waste management following standardized formats and create databases tracking key metrics, including the volume, composition, and recycling performance of packaging.

Economic Impact and Industry Challenges: Conclusion

The Packaging and Packaging Waste Regulation marks a transformative shift in the EU’s approach to sustainability, but it comes with substantial economic implications. Businesses across the packaging supply chain will need to make significant investments, particularly in reuse systems and recycling technologies, with total costs expected in billions. While these changes may challenge smaller businesses and non-EU exporters, they also represent opportunities for innovation, growth, and job creation.

By setting high standards and fostering a circular economy, the PPWR pushes companies to innovate and embrace sustainability, turning it into a real competitive edge. As businesses adapt, it is an opportunity to build long-term economic strength and strengthen the EU’s role as a global leader in sustainable practices.

Is your firm ready to comply with the new Regulation? For guidance or further information, contact Axevera Consulting:  elisa.barni@axevera.com & simone.consalvi@axevera.com

Sources: https://www.linkedin.com/feed/update/urn:li:activity:7262723390942175232/

https://environment.ec.europa.eu/strategy/circular-economy-action-plan_en

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022PC0677

https://www.edelmanglobaladvisory.com/eus-game-changing-new-packaging-law

https://natlawreview.com/article/eu-proposal-regulation-packaging-and-packaging-waste-nearing-adoption-highlights

https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Packaging_waste_statistics

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