The Packaging and Packaging Waste Regulation (PPWR) is an EU regulation that sets strict rules for packaging design, waste reduction, and recycling to ensure greater sustainability across the EU. Published in the EU Official Journal on January 22, 2025, it takes effect 18 months later, although some requirements will be phased in over longer timelines. The PPWR applies to all packaging in commercial, household, and industrial sectors and supports the EU’s transition to a circular economy. It sets clear targets for waste reduction and higher recycled content, aiming to minimize the environmental impact of packaging.

• Reducing packaging waste.
• Increasing the use of recycled materials in packaging.
• Promoting sustainability and a circular economy.
• Ensuring uniform regulations across all EU member states.
• Encouraging companies to adopt eco-friendly packaging solutions.

Under the PPWR, recyclability is defined as the compatibility of packaging with waste management and recycling processes, including separate collection, sorting, large-scale recycling, and using recycled materials instead of primary raw materials. By 2030, all packaging placed on the market must be recyclable.

Key requirements include:

• By 2030: All packaging must be recyclable; specific targets for recyclability will be clarified by 2027.
• By 2035: Each type of packaging must be recycled at least 55% in the EU (with wood packaging at 30%).
• For plastic packaging: Recycled plastic content will be mandatory from 2030, with details to follow in 2026.
• Post-consumer recyclate (PCR) requirements for plastic packaging:
  
  • PET for food and beverage bottles: 30% by 2030 (already 25% target by 2025 under the Single-Use Plastics legislation).
  • Other plastic food packaging: 10% by 2030.
  • Other plastic packaging: 35% by 2030.

These measures support a circular economy by ensuring packaging is designed for recycling and incorporates recycled content.

Recycling design criteria for packaging classification will consider:

• caps, closures, and other small parts
• ease of disassembly
• colors
• material composition
• adhesives
• coatings
• labels/wrapping
• ease of emptying
• innovation and environmental sustainability of packaging

Specific criteria are set to be confirmed by January 1, 2028.

By early 2028, the European Commission will publish guidelines for Design for Recycling, including Recycling Performance Assessments (RPGs). RPGs will assess recyclability as a percentage of packaging weight that can be recycled, with these assessments to be applied starting in 2030.

22 types of packaging (with some exceptions) will be distinguished, and specific conditions for calculating RPGs will be set for each type.

RPGs will be categorized into three classes:

• Class A: 95% recyclable or more
• Class B: 80% recyclable or more
• Class C: 70% recyclable or more

From 2030 onwards, only packaging classified as Class A, B, or C may be placed on the market. Packaging with less than 70% recyclability will be prohibited, and tariffs will align with RPG classifications.

Further development of RPGs will occur in 2027 through secondary legislation.

The PPWR is officially published, and while some details may still require clarification, it’s important to start taking the following preparatory steps:

1. Stay Informed: At Kaligraf, we provide the latest data and insights to ensure your packaging aligns with the newly published PPWR.

2. Review Packaging Information: Check what information you already have about your packaging and what your suppliers can provide.

3. Assess and Plan: Analyze the current status of your packaging and create a plan to comply with PPWR. Evaluate its recyclability and look for opportunities to improve its sustainability.

4. Consider Future Developments: If you are acquiring a new packaging line, launching a new product, or exploring innovations, be sure to incorporate the upcoming regulations. PPWR mandates minimizing packaging weight and volume across all sectors.

1. Read the Regulation Carefully
   PPWR spans 320 pages with multiple chapters and sections. While interpreting the regulation can be complex, it’s vital that all companies understand it. Agencies like Kaligraf help facilitate access.
   Ensure all teams within your organization understand the PPWR, including reporting obligations and compliance deadlines. Attend webinars and training sessions to stay informed.

2. Conduct an Internal Review and Audit
   Companies should document packaging materials and quantities immediately. Perform an internal audit to analyze materials and processes. Identify non-recyclable items and needed changes. Gather data on packaging types, quantities, and recyclability, which is key for future compliance.

3. Develop an Action Plan
   SMEs without sustainability managers should focus on creating an action plan. Set specific goals and deadlines for recyclable packaging and other PPWR requirements. Assign clear responsibilities for execution.

4. Design for Recyclability
   Focus on sustainability and explore recyclable packaging materials. Collaborate with designers and suppliers to ensure packaging is optimized for recycling.

5. Collaborate with Suppliers
   Engage suppliers to ensure they meet new PPWR requirements. Revise contracts and agreements to share responsibility for compliance.

6. Administrative Preparations
   Implement systems to collect, manage, and report packaging data. Consider compliance software to prepare mandatory statements and track deadlines.

7. Communication
   Regularly update employees on progress and new procedures. Communicate changes to stakeholders, including clients and suppliers.

8. Monitor and Improve
   Establish KPIs to track progress. Conduct regular audits to verify compliance and find areas for improvement.

PPWR Assistant
Kaligraf’s recycling verification tool helps evaluate packaging material specifications. Check your packaging status with Kaligraf’s PPWR Assistant.

Compliance starts in 2027 and will evolve with further regulatory updates.

All manufacturers and importers are required to demonstrate that their packaging complies with PPWR rules through a Declaration of Compliance.

Manufacturers are responsible for assessing packaging compliance and preparing a Declaration of Compliance. This statement, including an assessment of packaging materials (e.g., weight), must be available to the competent authority upon request. Suppliers must provide relevant data to support this.

Distributors and retailers are obligated to verify that the packaging they import or purchase has a valid Declaration of Compliance.

Compliance assessment rules include, but are not limited to:

• Description of packaging and intended use
• Design drawings
• Materials used (including weight)
• Applicable standards/norms (if relevant)
• How the packaging meets specific requirements for sustainability, recyclability, and other environmental criteria outlined in the regulation

Manufacturers must retain these documents for at least 10 years from the date the packaging was placed on the market. They must also ensure the Declaration of Compliance is updated regularly.

If the manufacturer is located outside the EU, the importer assumes responsibility for ensuring compliance.

2025

• PPWR comes into force
• All EU member states must establish an Extended Producer Responsibility (EPR) system.
• Compostability standards will be standardized

2026

• Countries achieving an 80% collection rate may apply for an exemption from mandatory Deposit Return Schemes (DRS)
• Guidelines for eco-design will be published

2027

• The calculation method for reuse targets will be published

2028

• Criteria for Design for Recycling (D4R) guidelines will be established.
• A fee modulation system will be introduced

2029

• Deposit Return Schemes (DRS) must be implemented across all EU member states for specific packaging types
• Delegated acts will be adopted for the calculation and verification of recycled content

From 2030 onwards, packaging must be designed with a focus on environmental aspects. This includes using sustainable materials, increasing recyclability, reducing the use of harmful chemicals, and overall improving the ecological footprint of packaging.

2030

• Basic recyclability grades (A, B, C) will be introduced, without RaS (Recycled at Scale) scores
• A methodology for RaS assessments will be developed
• Minimum standards for packaging dimensions and empty space ratio will take effect.
• Initial recycled content requirements will be enforced for various packaging types
• Reuse targets for alcoholic and non-alcoholic beverages, as well as other reusable packaging systems, will apply
• On-pack pictograms and digital labels will become mandatory
• Single-serve coffee and tea packaging must comply with D4R guidelines
• Member states must reduce packaging waste by 5%

2031

• Packaging waste reduction targets will be reassessed

2035

• RaS scores will be introduced for recyclability grades A, B, and C
• Member states must reduce packaging waste by 10%

2038

• Packaging classified as Grade C will be banned from the market due to stricter recyclability standards

2040

• Higher reuse targets for beverage containers, transport, and sales packaging will be enforced
• Member states must reduce packaging waste by 15%
• Stricter recycled content requirements will be applied to relevant packaging types