Navigating the New EU Packaging and Packaging Waste Regulation

In a bid to revolutionise strong packaging practices and streamline existing legislative initiatives across the European Union (EU) single market, the EU has introduced the Packaging and Packaging Waste Regulation (PPWR).  This new regulation, set to enter into force in late 2024, aims to address the pressing issues of packaging waste and its environmental impact while promoting a harmonised internal market for packaging. Let’s dive into what this means for businesses and the everyday consumer and how it will shape our approach to packaging in the EU.

What is the EU PPWR?

The PPWR replaces the existing Directive on Packaging and Packaging Waste (94/62/EC), transitioning from a directive to a regulation to ensure uniformity across all EU Member States. This change means the PPWR will have direct application in all member countries, eliminating the discrepancies that arose under the directive, which allowed for national variations.

At its core, the PPWR targets all packaging and packaging waste within the EU, including transport and consumer (e.g. e-commerce) packaging. It establishes stringent sustainability and information requirements to reduce packaging waste and enhance recycling and reuse efforts. This regulation is a crucial component of the EU's broader strategy to promote a circular economy and reduce the environmental footprint of packaging materials.

Deep Dive: Key Elements of the Legal Text 

1. Environmental Impact  and Design Requirements 

One of the central pillars of the PPWR is its focus on the environmental impact of packaging. The regulation mandates that all packaging on the EU market must be designed to minimise environmental impact throughout its lifecycle. Specifically, this includes:

  • Minimising Hazardous Substances: Packaging materials must limit the presence of substances of concern (SoC). Specific restrictions are imposed on per- and polyfluoroalkyl substances (PFAS), with food contact packaging facing strict limits on PFAS concentrations from 2026​​.

  • Design for Recycling: The regulation introduces "Design for Recycling" (D4R) criteria to ensure that packaging can be easily recycled. This aligns with the EU's goal of achieving high recycling rates and reducing waste​​.

  • Reuse Targets: Member States are encouraged to adopt higher reuse targets, particularly in the beverage sector. This initiative aims to promote reusable packaging systems and reduce the dependency on single-use packaging​​.

2. Information and Labelling Requirements

Moreover, to facilitate better consumer understanding and improve recycling practices, the PPWR sets out comprehensive labelling requirements:

  • Material Composition Labels: Packaging must be marked with labels indicating its material composition, which will help consumers sort and dispose of packaging correctly​​.

  • Reusability and Recycled Content: Labels must also inform users about the packaging's reusability and the percentage of recycled content. Digital information, such as QR codes, can complement these labels and provide additional details​​.

  • Standardised Waste Receptacle Labels: Harmonised labels on waste receptacles across the EU will be mandatory, simplifying the sorting process and improving recycling rates​​.

3. Extended Producer Responsibility (EPR)

Furthermore, the regulation expands the scope of Extended Producer Responsibility (EPR) schemes. Producers will be responsible for the entire lifecycle of their packaging, including collection, recycling, and disposal. EPR schemes must be designed to cover the costs associated with these activities, incentivising producers to minimise waste and use sustainable materials​​.

4. Waste Prevention and Reduction

Lastly, the PPWR sets ambitious targets for packaging waste prevention and reduction. By 2030, Member States are required to achieve significant reductions in packaging waste compared to 2018 levels. This includes mandatory reductions for specific types of packaging, such as lightweight plastic carrier bags and single-use food containers​​.

When will the PPWR Apply? 

The PPWR is expected to enter force in the fourth quarter of 2024. Following its entry into force, there will be an 18-month period before the regulation's application begins, giving businesses and Member States until mid-2026 to comply with the initial requirements​​.

Key deadlines include:

  • 2026: Compliance with initial sustainability and labelling requirements, including restrictions on hazardous substances and the introduction of material composition labels.

  • 2028: Implement further labelling requirements for reusable packaging and packaging containing recycled content.

  • 2030: Full implementation of labelling for substances of concern and harmonised waste receptacle labels​​.

What’s next for Businesses?

The PPWR represents a significant shift in the EU's regulatory landscape for packaging. Businesses will need to adapt to a range of new requirements, from redesigning packaging to meet sustainability criteria to updating labels to comply with new information requirements. Here are some key considerations for businesses:

  • Product Design and Material Choices: Companies will need to rethink their packaging designs and material choices to comply with the D4R criteria and minimise the presence of hazardous substances.

  • Supply Chain Adjustments: Businesses will need to work closely with suppliers to ensure that all packaging components meet the new regulatory standards.

  • Investment in Recycling Infrastructure: Producers may need to invest in or support recycling infrastructure to fulfil their EPR obligations and meet waste reduction targets.

  • Consumer Communication: Clear and accurate labelling will be crucial in helping consumers understand how to dispose of packaging correctly and the benefits of choosing sustainable packaging options.

Next Steps for the PPWR 

The EU's new Packaging and Packaging Waste Regulation marks a significant step towards a more sustainable future. By imposing stringent requirements on packaging design, material use, and waste management, the PPWR aims to reduce the environmental impact of packaging and promote a circular economy. While the regulation presents challenges for businesses, it also offers opportunities to innovate and lead in sustainable packaging solutions.

Do you wonder how to comply with the Packaging and Packaging Waste Regulation, or how it relates with parallel initiatives by EU Member States (e.g. TRIMAN logo)? 2B Policy can empower you to navigate the new packaging requirements and set concrete goals and timelines for compliance. We are looking forward to hearing from you! 

AUTHOR

Vasilis Triantafyllidis

Born and raised in Athens, Vasilis holds degrees in Slavic Studies and Political Science. Prior to joining 2B Policy as Public Affairs Analyst, he worked as a Public Affairs Intern at Randstad Global. He is supporting 2B Policy in analysing and monitoring relevant EU legislative files.

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