How prepared is the industry for the Packaging and Packaging Waste Regulation?

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Introduction

The European Union’s Packaging and Packaging Waste Regulation (PPWR) marks a significant shift in packaging policy, replacing Directive 94/62/EC and driving the region toward a circular economy. While the sustainability goals are clear, many companies remain underprepared for the sweeping data and reporting demands that now accompany compliance.

Key Takeaways

• Complex new reporting obligations: The PPWR introduces granular data requirements across 22 packaging categories, covering recyclability, reuse, recycled content, and harmful substances.
• Mandatory targets with progressive timelines: By 2040, packaging waste must be reduced by 15% per capita, with phased targets for recyclability (70% by 2030), reusable packaging, and recycled content in plastics.
• Data overload for retailers and brands: Major players may face millions of data points across SKUs, especially for recyclability assessments, requiring input from across the supply chain.
• Digital tools are essential: Manual processes are no longer viable. Companies must adopt digital solutions to manage compliance, automate reporting, and track sustainability KPIs.
• No exemptions for small businesses: All actors in the value chain, including smaller suppliers, must comply, which will create added pressure and possible bottlenecks.

Conclusion

The PPWR is more than a packaging directive—it’s a fundamental business transformation mandate. Companies that treat sustainability as a core strategic function, invest in digital infrastructure, and begin compliance efforts today will be best positioned to thrive under the regulation.

We recently polled our audience with the question: How well does your company understand the data implications of the new PPWR? While it was positive to see that 28% understood them ‘thoroughly’, 32% understood them either ‘a little’ or ‘not at all’. And yet these demands are unavoidable, which suggests there are going to be a lot of companies playing catch-up. We look at the huge task of data management on the horizon and where to start when it comes to tackling it.

There have been years of discussions and consultations, but the European Parliament has finally agreed on the Packaging and Packaging Waste Regulation (PPWR) which, once in full effect, will replace the Packaging Directive 94/62/EC, facilitating Europe’s transition towards a circular economy, and acting as a cornerstone to the European Green Deal and the Circular Economy Action Plan.

The overall packaging waste reduction target laid out in the regulation is 15% by 2040 per capita per Member State, in comparison to 2018 figures. The targets will be progressive, meaning a 5% packaging reduction compared to 2018 by 2030 and 10% by 2035. It is projected that this would amount to an overall EU-wide waste reduction of 37% compared to if there were no changes to existing legislation.

Key provisions to be monitored

We will look in more detail at the different elements this regulation will cover and who it will impact (the short answer: everyone in the value chain, to differing extents) but what these ambitious targets mean is that packaging producers must henceforth comply with a raft of highly complex new data reporting obligations – far more than previously (there are 22 relevant packaging categories set out in Annex II Table 1 of the regulation).

The full text can be read here, but the main targets of the PPWR that impact businesses include:

• Recyclability: A fundamental aim of the PPWR is to ensure that all packaging, whether it is reusable and whatever recycled content it contains, is recyclable (meaning with a recyclability grade of 70% or over) by 2030. But the key is that it must be recyclable in an ‘economically viable’ way, not just recyclable in theory as many materials are currently. This means sufficient infrastructure must be put in place, including a common verification system. The only exceptions to this rule are lightweight wood, cork, textiles, rubber, ceramics, porcelain and wax.
• Mandatory recycled content in plastic packaging: In order to turn plastic waste into a more valuable resource, minimum mandatory recycled content for plastic packaging by 2030 will be: 30% for contact-sensitive packaging made from PET; 10% for contact-sensitive packaging made from other plastic materials; 30% for single-use plastic beverage bottles and 35% for other plastic packaging. These figures will all increase for 2040.
• Reusable packaging: Even in cases where reusable packaging is made from materials that are heavier than standard single-use, there can still be overall environmental savings if the number of times the pack is circulated are high enough. Yet reuse and refill has not taken off on as wide a scale as many would have hoped – and this comes down in large part to a lack of mandatory targets, which the PPWR now seeks to address. By 2030, 20% of cold and hot beverages will have to be filled in a container that is part of a reuse system, and by 2040 this figure rises to 80%. For takeaway-prepared meals, the targets are 10% in 2030 and 40% in 2040. Finally, 10% of e-commerce transport packaging must be reusable by 2030 and 50% by 2040.
• Banning problematic packaging: Certain types of packaging, mainly single-use plastics such as hotel miniature shampoos and soaps; grouped packaging of beverage cans and sachets for restaurants; and very lightweight plastic bags, will be banned under the new rules.
• Reducing unnecessary packaging: Under the PPWR, unnecessary transport and e-commerce packaging would be reduced through setting a maximum empty space of 50%. Producers and importers would also be required to ensure the weight and volume of the packaging is kept to a minimum, unless the design of the pack is protected (providing the protection was already in place before the regulation comes into force).
• Stricter rules on ‘substances of concern’: The regulation is introducing a restriction on food-contact packaging containing per- and polyfluoroalkyl (PFAS, or ‘forever chemical’) substances above certain thresholds, with the potential to amend these within four years if necessary.
• Compostables: From three years after the regulation comes into force, compostable packaging will be mandatory for items such as tea/coffee bags and capsules, and sticky labels attached to fruit and vegetables.

It’s worth noting briefly that there has inevitably been some criticism of the new rules regarding treatment of certain materials, whether standards for reuse go far enough (e.g into takeaway packaging) and so on. On a related note, the Rethink Plastic Alliance feels that the Commission’s initial proposal has been “watered down by a plethora of exemptions and derogations”, including restrictions for unnecessary packaging that only focuses on single-use plastics and not single-use formats in general – so may simply increase paper waste.

But our purpose here is not to discuss the relative merits of the PPWR – there are other places readers can delve into this – so much as how companies can meet their data management requirements.

‘An immense administrative burden’

As the majority of our readers are already well aware, the above rules constitute an awful lot of information to keep track of. And while the regulations themselves are reasonably clear, what is not so clear is how to process all the data that will need to be collected, maintained and analysed in order for all members of the value chain to prove – or not, as the case may be – that they are meeting these targets.

We spoke with Alexander Reitz of PreZero International to get his expert insight into the huge task that has now opened up and discuss the key data metrics that will need to be reported on.

“It is well worth it to increase packaging sustainability, but the PPWR will put an immense administrative burden on companies in the packaging value chain,” he says. “Basically, every sustainability requirement set by the PPWR has to be measured, documented and be made available to authorities on demand in a ‘declaration of conformity’. This includes things like certificates for the origin of plastics recyclates (PCR from within the EU or with equivalent standards) or proof that the packaging does not contain harmful substances such as PFAS, etc.”

Some data metrics are going to be more challenging to report on than others: When it comes to recycled content requirements or harmful substances, says Alexander, the answer is quite straightforward (“Does it exist to specifications? Yes or no.”). However, when it comes to defining recyclability and compliance with packaging minimization requirements the task becomes more complex.

“Whether something is recyclable or not depends on many different parameters: materials used, additives, relative weights, dimensions, combinations of different packaging elements – the list goes on. Thus, recyclability is almost never a yes-or-no answer, but a complex calculation that requires a lot of different data points from different actors in the value chain.”

As to packaging minimization, we should refer to Article 9 of the PPWR, which states: “By 1 January 2030, the manufacturer or importer shall ensure that the packaging placed on the market is designed so that its weight and volume is reduced to the minimum necessary for ensuring its functionality taking account of the shape and material that the packaging is made of.”

This means, points out Alexander, that companies will have to ‘benchmark’ their packaging to an EU-approved industry standard.

Another important aspect of the revised PPWR mentioned above that we should highlight is that of ‘limiting green claims’? What does this really mean in practical terms?

“The most direct effect of the PPWR on claims will be that companies can only make claims that go beyond the minimum requirements of the PPWR. If the requirement of PPWR is 35% recycled plastic content and your packaging has said 35% recycled content, you cannot use this for a claim, because you are only meeting the legal requirements. You must go further (e.g. 40% recycled content), to make a marketing claim.

“It remains to be seen,” he adds, “if brand owners could use a label like ‘PPWR-proof’ on their packaging or not.”

The result of this is that companies can no longer see packaging sustainability as an optional extra part of their strategy, or even a marketing tool. If 70% recyclability is a mandatory requirement then packaging compliance – and therefore data management and reporting on this – must be part of a company’s very DNA rather than an afterthought, wherever they sit in the value chain.

‘Everyone will be affected’

What, then, are the specific, granular challenges facing the value chain when it comes to meeting all these new data requirements? Everyone will be affected to a different degree and in varying ways, but to give the main common areas:

• · Producing or sourcing enough recycled materials to meet regulatory and product requirements;
• · Finding recyclable solutions or hard-to-substitute materials (e.g. flexible plastics);
• · Educating consumers on the correct disposal of a package at end of life;
• · Putting in place additional resources to cope with the additional administrative work required to measure and report all this new data (particularly challenging for retailers who may have up to 100,000 SKUs to keep track or).

It’s also true that, while no members of the value chain will escape the impact of these new regulations, some are almost certain to be more directly impacted.

“Everyone will be affected,” confirms Alexander. “But brand owners and retailers most directly, because they are generally the ones that put the filled packaging on the market and have to ensure compliance with the sustainability requirements. A retailer such as Lidl, Aldi, Tesco, Carrefour can easily have up to 100,000 SKUs. Just to measure recyclability, you need to gather about 60 different data points from you suppliers (and the suppliers of your suppliers…) to make this calculation. This means these retailers need to handle 6 million points of data just to measure and report on a single sustainability requirement of the PPWR.”

Retailers can also expect challenges when it comes to their smaller FMCG suppliers. These may simply lack the packaging expertise to supply the data required, meaning considerable time and resources may be involved in sourcing this information from packaging manufacturers etc further up the chain. And we should note here that there is no general exception for small- and microscale companies.

‘You need a digital solution’

It will not, then, be news to anybody that meeting the requirements of this long-awaited PPWR amendment necessitates an entirely new approach to data management across the board. Those who have not yet embraced digitalization to monitor compliance will need to take a proactive stance, whether to a greater or lesser degree, depending on the complexity of the data points they need to keep track of.

Alexander emphasizes why he believes advanced data analytics tools are going to be so essential: “You don’t handle 6 million points of data by filling out Excel sheets or with print-outs in file folders. You need a digital solution. Digitalization helps to reduce complexity. Understanding all the different country-specific particularities on how to determine taxes, recyclability etc. is very complex and takes expert knowledge. A digital solution significantly reduces the barrier of entry: You don’t need to know and understand all details by yourself, because the digital tool shows you the consequences / results of all details for your specific product / use case. This way, it transforms data into relevant information that you can actually use in your decision-making processes.”

PreZero’s free PreZero Spot tool, in collaboration with Packaging Cockpit, is just one example of a digital solution to allow different users along the supply chain to communicate and exchange data, including sustainability key performance indicators like recycled content, carbon footprint, analysis of extended producer responsibility (EPR) fees and plastic taxes. (Although there are of course a range of other tools available on the market, and as a publication with a neutral stance we cannot recommend one over another.)

‘Start now’

The 18-month transition period given before the official adoption of the act gives companies a very short window to review and adapt their processes. How do they begin to address the challenges of data management in light of the revised PPWR?

“Start dealing with the challenges right now,” says Alexander. “Analyze the status quo in your company, consider your options, formulate a plan on where you want to go and take your first steps into that direction, even if those steps are small. If you think 2030 is still far away and you can start dealing with the packaging transformation starting in 2028, you will have significant competitive disadvantages.”

And finally, take steps to be future-proof: bear in mind that this is an evolving piece of legislation so in future it will pay to be agile. Over the coming years, the Commission will be adopting implementing acts for several different provisions of the PPWR – particularly when it comes to recycling performance. Businesses should follow the timeline as set out and keep themselves up-to-date with the inevitable adjustments.

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