The Packaging and Packaging Waste Regulation has three primary pillars:

Updated definitions

 
By redefining key terms in the packaging industry, the PPWR has significantly expanded the scope of its own application. These updated definitions aim to remove ambiguities and ensure that everyone—from manufacturers to consumers—has a clear understanding of what constitutes sustainable recycling, packaging, and packaging waste.

New requirements

 
As the PPWR mandates ambitious targets for waste reduction against a 2018 baseline and stipulates that waste be recycled at scale, it also upends the previous status quo by banning non-recyclable packaging from the market. The legislation also mandates clearer labelling for disposal and recycling instructions, ensuring consumers are better informed.

Procedures

 
The PPWR outlines standardised reporting mechanisms for companies, oversight responsibilities, and penalties for non-compliance. The regulation also introduces broad methodologies including for the types of recycling which are more in line with its efficiency and sustainability targets, though much is left to upcoming implementing acts.


Introduction

 
The European Union’s Packaging and Packaging Waste Regulation (PPWR) is a comprehensive legislative overhaul aimed at transforming the way packaging is produced, used, and recycled across the EEA. Spanning approximately 300 pages and encompassing over 600 articles and sub-articles, the PPWR looks to harmonise packaging recycling by establishing strict goals and benchmarks.

At its core, the PPWR imposes stringent new requirements on industries, mandating ambitious targets for waste reduction and stipulating minimum levels of recycled content in packaging materials. It significantly disrupts the previous status quo by banning non-recyclable packaging from the market, compelling manufacturers to innovate and adopt sustainable practices in order to ensure that their packaging is recycled at scale. The regulation covers a wide array of topics, from material specifications and design requirements to labelling and reporting obligations.

This overview will provide you with a targeted breakdown of the PPWR’s amendments, providing you with a place to reference and learn about this unique legislation.


Headline articles

 

This section describes the articles behind the headline requirements which make the PPWR so impactful. Each article contains an overview of its key points, as well as the original article text supported by a simplified translation.

Definitions

Article 3 is the backbone of the PPWR, establishing the precise terminology that governs the entire regulation. It eliminates ambiguities and ensures consistent interpretation across all EU member states. Here’s a look at some of the key definitions outlined:

3.36 Design for Recycling

New requirements for meeting a minimum threshold of recyclability, supported by harmonised Design for Recycling guidelines, have shifted the status quo of packaging recyclability from a request to a requirement. These new requirements will be specified by later Delegated Acts - read on below!

‘Design for recycling’ means design of packaging, including individual components of packaging, that ensures the recyclability of the packaging with established collection, sorting and recycling processes proven in an operational environment

Creating packaging (including all its parts) in a way that ensures it can be recycled using the existing collection, sorting, and recycling systems that are already working effectively in real-life settings.

3.38 Recycled at Scale

One of the most consequential topics in the new PPWR, what constitutes whether a packaging format is recycled at scale across the European Union is not yet fully determined. However, the EU has made an overarching goal available, to be supplemented by later acts.

‘Packaging waste recycled at scale’ means packaging waste which is collected separately, sorted and recycled in installed infrastructure, using established processes proven in an operational environment which ensure, at Union level, an annual quantity of recycled material under each packaging category listed in Table 2 Annex II, equal to or greater than 30% for wood and 55% for all other materials; it includes packaging waste that is exported from the Union for the purpose of waste management and which can be considered to meet the requirements of Article 53(11);

Recycling at Scale refers to packaging waste that is separately collected, sorted, and recycled using existing facilities and proven methods. This process ensures that, across the European Union, at least 30% of wood packaging and 55% of packaging made from other materials are recycled each year. It also includes packaging waste exported from the EU for recycling, provided it meets specific requirements.

3.24 Composite Packaging

The specifics of what constitutes a composite packaging format has significant implications on the requirements its components need to meet under the new PPWR. Generally speaking, a component which makes up less than 5% of the total mass of the packaging is excluded from targeted requirements, like plastic taxes.

‘Composite packaging’ means a unit of packaging made of two or more different materials, which are part of the weight of the main packaging material and cannot be separated manually and therefore form a single integral unit, unless a given material constitutes an insignificant part of the packaging unit and in no case more than 5% of the total mass of the packaging unit and excluding labels, varnishes, paints, inks, adhesives, lacquers; this is without prejudice to Directive (EU) 2019/904;

Packaging units made from two or more different materials that are combined together and cannot be separated by hand, forming a single, unified item. This doesn’t include materials that make up an insignificant part of the packaging (no more than 5% of its total weight) and excludes labels, varnishes, paints, inks, adhesives, and lacquers.

3.8 Innovative Packaging

Innovative packaging has become an important concept under the PPWR as these formats are largely exempt from meeting the same recyclability requirements as more standard packaging formats. The EU has allowed this in order to ensure that innovation remains commonplace in Europe.

‘Innovative packaging’ means a form of packaging that is manufactured using new materials resulting in a significant improvement in one or more packaging functions of the packaging, such as containment, protection, handling or the delivery of products, and in overall demonstrable environmental benefits, but excludes packaging that is the result of modifications to existing packaging the main purpose of which is to improve the presentation of the products and marketing;

Packaging made from new materials that significantly improve one or more of its functions—like holding, protecting, handling, or delivering products—and also provide clear environmental benefits. It does not include packaging that is simply modified from existing designs primarily to enhance product appearance or marketing.

Innovative packaging is mostly exempt from PPWR requirements

3.1 Packaging - Tea & Coffee Units

The definition of packaging has been zeroed in on by the PPWR. As a result, many more formats are considered to be packaging, and therefore subject to the PPWR. This includes coffee capsules, which were previously exempt.

‘Packaging’ means an item, irrespective of the materials from which it is made, that is intended to be used by an economic operator for the containment, protection, handling, delivery or presentation of products to another economic operator or to an end-user, and that can be differentiated by packaging format based on its function, material and design, including:

  • permeable tea, coffee or other beverage bags, or soft after-use system single- serve units that contain tea, coffee or another beverage, and which are intended to be used and disposed of together with the product, as well as
  • non-permeable tea, coffee or other beverage system single-serve unit intended for use in a machine and which is used and disposed of together with the product.

“Packaging” means any item—no matter what it’s made of—that a business uses to contain, protect, handle, deliver, or present products to another business or to the end-user. Packaging can vary in format based on its function, material, and design.

This includes:

  • Permeable tea, coffee, or other beverage bags, or soft single-serve units that hold tea, coffee, or other drinks, which are intended to be used and thrown away along with the product inside.
  • Non-permeable single-serve units for tea, coffee, or other beverages designed for use in a machine, which are also used and disposed of together with the product.

3.47/48 Compostable Packaging

The PPWR looks to formalise the waste streams for compostable materials while ensuring that they do not negatively impact more common and effective material recycling streams.

‘Compostable packaging’ means packaging that biodegrades only in industrially controlled conditions or that is capable of undergoing biological decomposition in such conditions, including, if necessary, with physical treatment, anaerobic digestion, resulting ultimately in conversion of the packaging into carbon dioxide or, in the absence of oxygen, methane, and mineral salts, biomass and water, and does not hinder or jeopardise the separate collection and the composting and anaerobic digestion process;

‘Home compostable packaging’ means packaging that can biodegrade in non- controlled conditions that are not industrial scale composting facilities and the composting process of which is performed by private individuals with the aim of producing compost for their own use.

“Compostable packaging” means packaging materials that can only break down (biodegrade) under controlled industrial conditions. The packaging might need additional treatments, like physical processing or anaerobic digestion (decomposition without oxygen), to fully break down. Ultimately, it turns into carbon dioxide (or methane if no oxygen is present), mineral salts, biomass, and water.

“Home compostable packaging” refers to packaging that can biodegrade in regular, uncontrolled environments—like a backyard compost heap. Private individuals can compost this packaging at home to produce compost for their own use, without needing any special industrial facilities or conditions.

Compostable packaging should not interfere with separate waste collection or the composting and anaerobic digestion processes.


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Requirements

As the PPWR mandates ambitious targets for waste reduction against a 2018 baseline and stipulates that waste be recycled at scale, it also upends the previous status quo by banning non-recyclable packaging from the market. The legislation also mandates clearer labelling for disposal and recycling instructions, ensuring consumers are better informed.

Article 6: Recyclable Packaging

Perhaps the most consequential article in the EU’s PPWR, Article 6 establishes requirements relating to Recycling Performance Grades and Recycing at Scale. It includes considerations for the development of related methodologies, data gathering, and the implication of performance grades on EPR fees.

 
Visit our detailed breakdown of Recycling Performance Grades and Recyclability at Scale to learn more.

Key dates:

2 years from entry into force: Recyclability Performance Grade requirements kick in, with a compliance deadline in 2030.
5 years from entry into force: Recyclability at Scale requirements kick in, with a deadline in 2035.
01/01/2028: Deadline for various Delegated Acts which establish the Recyclability Performance Grade methodology.
01/01/2030: Deadline for various Implementing Acts which establish the Recyclability at Scale methodology.

Article 7: Minimum recycled content in plastic packaging

Building on the previous targeted requirements laid out by the Single Use Plastics Directive, Article 7 expands minimum recycled content requirements to four primary plastic packaging categories.

 
The requirements outlined by the Article are as follows:

  • 30% (50%) for contact-sensitive PET packaging, excluding single-use beverage bottles.
  • 10% (25%) for contact-sensitive packaging made from other plastics, excluding single-use beverage bottles.
  • 30% (65%) for single-use plastic beverage bottles.
  • 35% (65%) for other types of plastic packaging.
    Numbers in (parenthesis) are requirements in 2040.

While provisions are included which allow for chemical recycling to contribute to these requirements, a large variety of processes and methodologies must first be established at various levels of EU lawmaking.

Key dates:

01/01/2030: Compliance deadline for the first minimum recycled content targets for packaging.
01/01/2040: Compliance deadline for the second, higher minimum recycled content targets for packaging.

Article 9: Compostable packaging

The PPWR targets compostable packaging more directly than ever before, with an eye to formalise the waste streams for compostable materials while ensuring that they do not negatively impact more established material recycling streams.

Key dates:

1 year from entry into force: The development of new harmonised compostability standards will begin.
3 years from entry into force: Compostable packaging formats placed on the market must meet requirements relating to collection, sorting, and reprocessing. Member states may also make some compostable formats obligatory.

Article 10: Packaging minimisation

In line with broader requirements to reduce the volume of packaging waste being placed on the market, the PPWR is targeting excessive packaging. These are formats which use excessive materials not necessary for their function, or those which are designed to increase perceived volume in ways which are not consumer friendly.

Key dates:

2 years from entry into force: The development of new harmonised minimisation standards will begin.
01/01/2030: Packaging must be designed to reduce weight and volume to the minimum necessary, considering the shape and material used.

Article 11: Reusable packaging

In order to establish the strict targets seen in Article 29, Article 10 sets a foundation of standard requirements to be met by reusable packaging. These include hygiene, designing for long time re-use, and by establishing that such formats are eventually recyclable.

 
Article 10 directly targets the following characteristics of reusable packaging:

  • Ensuring that packaging is designed with a long life-span in mind
  • Setting standards so that packaging withstands many rotations in normal use conditions.
  • Guaranteeing health, safety, and hygiene compliance, while offloading some hygiene burdens onto consumers
  • Ensuring that formats can be emptied or unloaded without damaging the packaging.
  • Ensuring that formats are capable of being refilled or reloaded while meeting existing safety and hygiene requirements.
  • Ensuring that these formats can be reconditioned.
  • Ensuring that reusable packaging is recyclable when eventually disposed of.

Key dates:

Effective immediately upon entrance into force: Reusable packaging must be designed for repeated use, maintain health and safety standards, and be capable of being reconditioned without losing functionality.

Article 12: Labelling of packaging

Following the thread of harmonisation which goes throughout the PPWR, the European Commission is seeking to standaridse recycling labels for packaging identification and disposal across all Member States. The EU also leaves space for the development of advanced digital labels.

Key dates:

1.5 years from entry into force: The Commision will begin to create a standardised European label design for different packaging formats, while establishing standards for digital labelling.
2 years from entry into force: Packaging participating in EPR schemes will need to bear a QR code validating its participation in the countries where it is sold.
3.5 years from entry into force: Labels/QR codes containing info on share of recycled content and/or bio-based plastic content will follow the methodology determined above.
4 years from entry into force: Reusable packaging must be labelled as such and include a QR code which allows consumers to access useful information.

Article 13: Labelling of waste bins

Again on the topic of harmonisation, the European Commission is seeking to standaridse recycling labels for waste bins and recepticals across all Member States. Currently, each Member State has its own color scheme for different material categories - these will be harmonised and standardised.

Key dates:

Effective immediately upon entrance into force: Waste receptacles used for collecting packaging waste must use harmonised labels within their own countries.
1.5 years from entry into force: The Commission will adopt implementing acts to establish European harmonised labels and formats for waste receptacles.
3.5 years from entry into force: Waste receptacles used for collecting packaging waste must use harmonised labels which are the same across the EU.

Article 29: Re-use Targets

The PPWR attempts to target the complicated topic of resuable packaging formats in a way which is alinged with its broder sustainability objectives. It does this in two ways: by establishing long term requirements on complex consumer reusable packaging streams, and setting immediate requirements on more linear B2B packaging streams.

Building on the methodologies and baseline requirements of Article 10, Article 29 establishes re-use targets on the following targeted packaging categories:

Consumer packaging (B2C)

By 2030 and (2040), distributors placing alcoholic and non-alcoholic beverages in sales packaging on the market shall ensure that at least 10% (40%) of those products are made available in reusable packaging within a system for re-use.

In addition, at least 10% (40%) of packaging used to group a certain number of products to create a stock-keeping or distribution unit must but made available within a system for re-use.

A stipulation exists which includes that the final distributor shall contribute in a fair proportion to the achievement of the targets by packaged products manufactured under its own brand.

Exemptions:

  • Wine and wine products, including similar fermented products originating from fruits other than grapes
  • Some alcohol-based spirituous beverages listed in Annex I of Council Regulation (EEC) No 2658/87
  • Most highly perishable beverages, including milk products and dairy alternatives
  • Flexible packaging formats in direct contact with food and feed

Industrial packaging (B2B)

By 2030 and (2040), economic operators using transport packaging or sales packaging within the territory of the Union, including via E-commerce, must ensure that at least 40% (70%) of the below packaging used is reusable packaging within a system for re-use:

  • Pallets,
  • foldable-plastic boxes, boxes, trays, and plastic crates,
  • intermediate bulk containers, pails, drums and canisters of all sizes and materials,
  • flexible formats or pallet wrappings,
  • and straps for stabilisation and protection of products put on pallets during transport

In addition, economic operators that use packaging to transport products between their own locations or those of their associated or partner companies, or to other operators within the same European country, must ensure that all such packaging must be reusable, with the exception of pallet wrappings.

An ongoing assessment will determine the specific requirements for plastic wrappings by 2026

Exemptions:

  • Packaging used for the transportation of dangerous goods
  • Packaging used for transportation for the large-scale machinery, equipment and
    Commodities, or otherwise highly customised.
  • Flexible packaging formats in direct contact with food and feed
  • In the form of cardboard boxes

The legislation also leaves significant room for so-called ’pooling arrangements’ and broad exemptions for both SMEs and specific packaging formats.

Key dates:

Effective immediately upon entrance into force: B2B packaging used between sites of the same operator or linked enterprises, or for transportation to another economic operator within the same country, must be reusable.
01/01/2030: Compliance deadline to ensure that at least 40% of targeted transport and sales packaging is reusable.
01/01/2040: Compliance deadline to ensure that at least 70% of targeted packaging is reusable.

Article 43: Reduction of packaging waste

Sitting above all other requirements in the PPWR is an expansion of the requirements for Member States to reduce the volume of packaging which is being placed on the market. The Commission has established a comparative baseline of 2018 to compare against.

 
The specific requirements put in place require reductions of 5% against 2018 in 2030, 10% in 2035, and 15% in 2040.

Key dates:

01/01/2030: First packaging waste reduction targets must be met at the country level.
01/01/2035: Second, higher, packaging waste reduction targets must be met at the country level.
01/01/2040: Third, higher, packaging waste reduction targets must be met at the country level.
7 years from entry into force: The Commission is mandated to review the reduction targets to ensure that they are fair and reflect the goals of the EU.

Article 52: Recycling targets

Attacking from two fronts, the PPWR reestablishes recycling targets put in place under the previous PPWD, including for targeted material categories. By approaching the topic upstream with reduction targets and downstream with recycling targets, the Commission is taking a holistic approach to a very involved discussion.

 
Material-specific requirements put in place by the Regulation are as follows:

2025
  • 50% of plastic
  • 70% of ferrous metals
  • 50% of aluminium
  • 70% of glass
  • 75% of paper and cardboard
  • 25% of wood
2030
  • 50% of plastic
  • 70% of ferrous metals
  • 50% of aluminium
  • 70% of glass
  • 75% of paper and cardboard
  • 25% of wood

Key dates:

31/12/2025: A minimum of 65% by weight of all packaging waste generated must be recycled, alongside material-specific targets.
31/12/2030: A minimum of 70% by weight of all packaging waste generated must be recycled, alongside material-specific targets.

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