Packaging and Packaging Waste Regulation
At a glance
Entering 2025, the EU Packaging and Packaging Waste Regulation (PPWR) has officially replaced the Packaging and Packaging Waste Directive (PPWD) as the centerpiece of EU legislation on packaging and packaging waste. The objectives of the Regulation are to continuously improve the environmental performance of packaging and to facilitate the correct functioning of the EU Internal Market, thereby protecting the free circulation of packaging and packaged goods in all EU Member States.
The Regulation introduces recyclability requirements for all packaging, including design for recycling criteria applicable from January 2030, and a recyclability at scale obligation taking effect from January 2035. It also contains new measures to prevent and reduce packaging waste generation, reuse and recycled content targets, and puts forth design requirements that cater to a wide range of packaging materials and packaged goods.
The new Packaging and Packaging Waste Regulation
The ambitious political goals enshrined in the European Green Deal and the Circular Economy Action Plan set the direction of travel for the revision of the Packaging and Packaging Waste Directive in 2022. Two years later, co-legislators adopted a new, which will enter into force in February 2025 introducing EU-wide requirements on packaging and paving the way to a multiplicity of secondary legislation, delegated and implementing acts.
The scope of the new Regulation has been expanded beyond the revision of the Essential Requirements to include also measures to reduce (over)packaging and packaging waste alongside measures to increase and improve packaging reuse and recycling and to drive the uptake of recycled content in packaging.
EUROPEN believes that the adoption of the PPWR represents a real milestone in the process of moving towards a sustainable packaging supply chain in Europe. Our members have already embarked on an innovation journey to ensure a sustainable future for packaging. They are developing optimal packaging solutions to prevent resource depletion, product and food waste, and packaging entering the environment. They are also driving the uptake of innovative packaging design for increased reuse and recycling, and contributing to the development of new sorting, collection, and recycling technologies.
Moving forward, for the PPWR to be successful, the ambitious policy goals must be supported by the timely adoption of evidence-based secondary legislation. The drafting of delegated and implementing acts foreseen by the Regulation must therefore rely on a factual and scientific basis to ensure greater efficiency and clarity throughout the PPWR implementation. Doing so can help drive investment in innovation while simultaneously backing the Regulation’s enforcement.
Our position
The regulatory framework must be fit for purpose to effectively prevent packaging from becoming waste and to boost recyclable and reusable solutions while preserving packaging functionalities.
Following the adoption of the PPWR, it will be crucial to provide for a swift and timely development of the secondary legislation and subsequent actions required under the Regulation. This will contribute to tackling the complexity and broad scope of the PPWR while addressing the need for industry to be prepared to meeting the Regulation’s requirements.
EUROPEN has put forward four recommendations to address the aftermath of the adoption of the PPWR:
- Ensure the timely implementation of the PPWR
The timely adoption of evidence-based secondary legislation and guidelines is critical to the undisrupted functioning of the value chains that depend on packaging for the commercialisation of products in the European market.
- Ensure policy coherence with existing and upcoming regulations
Legislators must ensure the alignment of upcoming regulations, such as the Waste Framework Directive (WFD) and the Green Claims Directive (GCD), and other regulations planned for review, including REACH and the Food Contact Materials legislation, to avoid overlaps and duplications with the PPWR.
- Build on industry technical expertise and guarantee clarity
Building on industry technical expertise, ensuring extensive stakeholder consultations, and establishing a regulatory framework that provides clarity for industry and supports sustainable growth without imposing unworkable constraints are essential to swiftly implementing the PPWR.
- Safeguard the integrity of the Single Market for packaging and packaged goods
The EU leadership must be anchored in the removal of internal barriers to trade and the sanctioning of infringements. Particularly in relation to packaging and waste policies, enforcement at the national level has been uneven, and our industry has witnessed an increase in national trade barriers in the form of divergent packaging requirements.