The Brief: Unpacking the biggest PPWR concerns with Marius Tent

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As the EU’s Packaging and Packaging Waste Regulation (PPWR) takes effect, companies face tough questions about recyclate sourcing, reuse incentives, and compliance readiness. This interview explores the practical and strategic implications of the PPWR, with a focus on non-EU recyclates, extended producer responsibility (EPR), and how businesses can lead, not lag, through the transition.

• Not all recyclates are created equal: Recyclate from outside the EU must meet the same stringent quality, traceability, and safety standards as EU-sourced materials, especially for food contact applications.
• Inconsistent national interpretations are a risk: Vague language in the PPWR could lead to a fractured Single Market; clear technical guidance and harmonized implementation will be key to avoiding regulatory fragmentation.
• Reuse targets risk being sidelined: The ability to bypass reuse targets by meeting recycling quotas may weaken incentives for reusable systems, which are crucial for long-term waste prevention.
• Derogations must be used sparingly: Flexibility is important, especially for food and medical sectors, but too many exemptions could undermine the regulation’s core environmental goals.
• Priority access to recycled plastics may be justified: Sectors like food, cosmetics, and healthcare could benefit from prioritization due to strict safety and quality requirements.
• EPR is the backbone of success: Without well-funded and effective Extended Producer Responsibility schemes, the infrastructure needed to meet PPWR goals simply won’t materialize.

The PPWR is more than a regulatory hurdle – it’s a strategic pivot point for packaging in Europe. Businesses that move early, invest in compliance and innovation, and build collaborative ecosystems will define the future of sustainable packaging. The message is clear: don’t just follow the regulation; use it as a launchpad to lead.

Since the PPWR was finalised last year, we’ve received a number of questions from our audience on its implications. We put your questions on exemptions, specificity of language, recyclate, reuse, and more to Marius Tent – a leading PPWR expert and the founder of ViaPackaging UG and 360PackMastery.

Fears have arisen that recyclate sourced outside the EU may not adhere to the PPWR’s standards. How can we ensure we’re using the right quality of recyclate? Should waste collected outside the EU even count towards recycled content targets?

It is key to highlight that under the Packaging and Packaging Waste Regulation (PPWR) and existing EU legislation, including Regulation (EU) No 10/2011 on plastic materials intended for food contact, Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food, Commission Regulation (EU) 2022/1616 on recycled plastic materials and articles intended for food contact, and the REACH Regulation (EC) No 1907/2006, ensuring the quality of recyclates—particularly when sourced from outside the EU—is of critical importance!

Compliance requires robust traceability systems and third-party certifications to verify recyclate origin, processing, and adherence to EU standards, particularly for sensitive applications like food-contact materials.

The inclusion of recyclates from outside the EU in recycled content targets is clearly under active discussion. To ensure a level playing field, all recyclates must meet the same high standards, safeguarding environmental goals, consumer safety, and fair competition.

Last but not least, proactive businesses that align with these requirements now, not waiting, can secure a competitive advantage and lead in the transition to a sustainable circular economy.

Some have said the derogation of reuse if certain recycling quotas are met fails to incentivize reusable packaging. Would you say the current text strikes the appropriate balance between reuse and recycling? Why, or why not?

This is an excellent question. The PPWR addresses the broader goals of the waste hierarchy, prioritizing waste prevention, reuse, and recycling to foster a circular economy.

The regulation aims to balance reuse and recycling, but the option to derogate reuse targets when recycling quotas are met has raised concerns. While recycling ensures material recovery, reuse directly aligns with waste prevention, offering long-term environmental benefits by reducing waste at its source.

However, achieving the necessary scale for reuse systems is a significant challenge that will require collaboration across the supply chain, from infrastructure development to consumer adoption.

Whether the current text achieves the right balance remains part of active discussions. Stronger incentives for reuse may be needed to drive innovation and investment in reusable packaging. Striking this balance will depend on fostering collaboration and refining mechanisms to support both reuse and recycling effectively.

And how do you feel about derogations and exemptions in general? Should they be included in the PPWR?

From my point of view, derogations and exemptions can provide necessary flexibility, particularly for sectors facing unique challenges such as food safety or technical infeasibility.

However, their overuse or inconsistent application could undermine the PPWR’s objectives. To ensure they support long-term sustainability goals, they should be applied sparingly and periodically reviewed for alignment with these goals.

Should anyone have priority access to recycled plastics? If so, who?

In my opinion, priority access to recycled plastics could be beneficial for sectors with critical environmental, health, and safety needs. Examples include:

• Food-contact materials, which require compliance with stringent safety regulations.
• Medical applications, where strict standards necessitate high-quality and specialized materials.
• Cosmetics packaging, which must adhere to rigorous safety and quality standards, especially for direct-contact products.

Such an approach could help these essential sectors meet recycled content goals without compromising safety or performance, while supporting broader sustainability objectives.

The PPWR has been described by some as an “anti-plastics regulation”, allegedly scapegoating single-use plastics while disproportionately favouring paper and cardboard. What are your thoughts?

While some may perceive this focus as favouring certain materials, the PPWR is designed to address the environmental impact of all packaging types comprehensively, including single-use plastics (SUP).

A balanced approach, in my opinion, should include:

1. Driving convenience and sustainability in parallel: Packaging solutions must align with consumer wants for practicality while encouraging sustainable behaviours.
2. Life-cycle assessments: Evaluating all materials to ensure decisions are based on their overall environmental impact.
3. Last but not least, focusing on reality rather than perception: backing decisions with robust data and communicating transparently with consumers to build trust and drive informed, sustainable choices.

It is my firm belief that the PPWR provides an essential framework, but true innovation and transformation will require packaging leaders, working in collaboration with many other stakeholders (internal and external!), to drive solutions that go beyond compliance.

Sustainability is a challenge that extends beyond regulation, and only through leadership, innovation, and collective effort can we address the larger environmental challenges of our time.

Arguments have also been made that the language of the PPWR is not specific enough, which could lead to nation-specific interpretations of the text and a fractured Single Market. Is this true, in your opinion?

From my point of view, we should keep in mind that the PPWR represents a significant step forward in advancing sustainability and fostering a circular economy across the EU. However, indeed, to ensure its full potential is realized, it is important to address concerns about potential divergent national interpretations that may arise from vague language. Such fragmentation could risk undermining the regulation’s objectives, create inconsistencies across Member States, and impose challenges for businesses operating in multiple markets.

To mitigate these risks, additional measures will be crucial:

1. Clear definitions and technical guidance to ensure uniform understanding and implementation across the Single Market.

2. Secondary regulation mechanisms, such as implementing acts or supplementary guidance from the European Commission, to harmonize approaches and address practical challenges.

3. Stakeholder collaboration to provide valuable input on areas requiring further clarification and to ensure that solutions are both, practical and effective.

What do you think about the PPWR’s stance on Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is embedded within the PPWR framework but remains broad in its directives. Yet, EPR is the driving force that will determine its success! Without a robust and well-funded EPR system, the PPWR’s objectives risk falling short. Investment in infrastructure is essential to building efficient collection, sorting, and recycling systems—transforming policy into tangible impact. Businesses must view EPR not as a regulatory burden, but as a strategic investment in a circular, sustainable future.

How does the PPWR cover sustainability initiatives that are not solely environmental, e.g. reducing food waste or ensuring safe food contact? Would you say it covers these factors thoroughly enough?

The PPWR encourages innovation and efficiency in packaging, indirectly contributing to food waste reduction by supporting solutions that protect products, extend shelf life, and reduce spoilage during transport. By introducing requirements on substances of concern (SOC), it ensures materials—especially recycled content—meet strict safety standards, safeguarding food quality and safety.

However, achieving meaningful reductions in food waste requires thinking beyond compliance. For example, investing in smart and active packaging technologies can help monitor freshness and reduce spoilage, addressing challenges across the supply chain. The PPWR provides a strong framework, but tackling food waste comprehensively will demand collaboration across regulatory frameworks, industry stakeholders, and sustained innovation.

To truly make an impact, packaging leaders must think bigger than PPWR compliance—embracing this as an opportunity to lead transformative change in sustainability, consumer convenience and food waste prevention.

A poll undertaken at 2024’s Sustainable Packaging Summit indicated that the ability to meet regulatory expectations is one of the biggest concerns among businesses operating in Europe. What can companies do right now to make sure they keep up with the Regulation?

First, understand the regulation inside out. The PPWR is more than a set of rules; it’s a framework for how packaging must evolve to fit a sustainable future. Staying updated is critical—not just on the regulation itself but on the secondary legislation that will follow. This doesn’t stop here. Knowledge is your edge, and those who master it will be the ones who thrive.

Second, take a hard look at your packaging portfolio. Audit every product, every packaging format and material, and every process. Ask yourself: Are we compliant? Are we ready for the shifts this will demand?

This isn’t just an operational challenge; it’s an organizational one. Everyone in your business—from the factory floor to the executive team—must understand the magnitude of the PPWR and the opportunities it brings.

Third, think beyond compliance. The PPWR is not just a hurdle to clear; it’s a once-in-a-lifetime chance to innovate. Packaging is no longer just a necessity—it’s a differentiator. Companies that embrace this moment to create holistic, sustainable packaging innovation strategies will set themselves apart in the market.

And let’s not forget collaboration. No company can navigate this alone. The solutions we need—whether in recycling infrastructure, reuse systems, or material innovation—require partnerships across the value chain. This is a shared journey, and success will come to those who work together.

Finally, this is about people. Building expertise within your packaging teams and investing in the right talent will be the foundation of long-term success. The PPWR is reshaping what it means to lead in packaging, and the need for skilled, passionate professionals has never been greater.

To all packaging leaders: this is your moment. The PPWR is not just a regulation—it’s your chance to make a dent. It’s a call to transform how we think about packaging, sustainability, and innovation. Step up, lead boldly, and show the world that our industry can drive real change.

Disclaimer from Marius: These views are my professional perspective and do not constitute legal advice or official regulatory guidance. For specific compliance decisions, readers should refer to the official text of the PPWR or consult qualified experts.

Marius is a leader and expert in packaging innovation and sustainability, with over two decades of experience working with top global brands. In January 2024, he began a new chapter by founding ViaPackaging UG, offering tailored support to brands navigating packaging transformations and collaborating with leading industry consortiums to drive meaningful change.

At the same time, Marius realized a long-held ambition with the creation of 360PackMastery.com – an online packaging platform designed to provide valuable solutions, resources, and insights for the packaging industry. Launching as the PPWR reshapes the sector, the platform aspires to be a trusted resource for the industry.

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