PPWR is the Packaging and Packaging Waste Regulation. This EU regulation will replace the EU Packaging Directive and is expected to be published by the end of 2024.

PPWR will officially take effect 20 days after its publication.

The deadline for the first obligations is 18 months later, in the second quarter of 2026.

For certain issues, measures will come into effect later due to longer implementation periods or the need for additional rules.

• 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.

First navigate through a 141-paragraph introduction on 70 pages. Following this are 11 chapters and 12 important annexes:

• Chapter 1: General provisions including subject, scope, definitions, and free movement of goods (Articles 1-4)
• Chapter 2: Sustainability requirements such as recycled content levels in packaging, minimization, and reuse (Articles 5-10)
• Chapter 3: Labeling, marking, and information requirements (Articles 11-12b)
• Chapter 4 and 4a: Obligations for economic operators, which unfortunately make the PWWR text challenging due to its dense paragraphs. Nevertheless, thorough familiarity with its contents is crucial. Fortunately, many experts assist in interpreting these requirements, including manufacturers, importers, distributors, and compliance firms (Articles 13-28b)
• Chapter 5: Regulations concerning carrier bags (Article 29)
• Chapter 6: Requirements for packaging compliance (Articles 30-34)
• Chapter 7: Management of packaging and packaging waste, organized into 7 parts (Articles 35-51). This chapter mandates that each member have an organization responsible for extended producer responsibility (EPR) and compliance registers. It also includes targets for waste reduction by 2030, 2035, and 2040, along with specific requirements for collection, recycling, deposits, reuse, and recycling capabilities categorized by material groups.
• Chapters 8-11: Cover protective measures, “green public tenders,” delegated powers, committee procedures, and amendments related to the Packaging Waste Directive and packaging waste. In summary, PWWR aims to reduce packaging waste compared to 2018, enforce sustainability standards, set mandatory recycling and reuse targets, specify minimum recycled content in packaging, require compliance statements, and ban certain packaging form

All packaging placed on the market must be recyclable by 2030. 

Takes effect in 2030, more details in 2027.

By 2035, each individual type of packaging placed on the market anywhere in the EU must be recycled at least 55% (except for wood, which is 30%). Further development will follow in 2030, also through secondary legislation.

The use of recycled plastic for all packaging manufacturers and importers takes effect in 2030, more details in 2026.

For plastic packaging materials (including laminates when they constitute more than 5% of the weight), they must contain a portion of post-consumer recyclate (PCR) – recycled material obtained from plastic that has been placed on the market, collected, and recycled (i.e., not production waste).

PPWR sets minimum percentages to be achieved by 2030, per “producer,” per production site:

PET for food and beverage bottles: 30%

(Note: There is already a target of 25% for PET beverage bottles by 2025 due to Single-Use Plastics legislation.)

Other plastic packaging for food: 10%

Other plastic packaging: 35%

By early 2028, the European Commission will publish guidelines for design for recycling, including Recycling Performance Assessments (RPG). These are recyclability assessments expressed as a percentage of the packaging weight that can be recycled, to be applied from 2030.

There will be 22 types of packaging (with some exceptions) distinguished. Conditions for calculating RPGs will be set for each type of packaging.

RPGs will have 3 classes:

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

From 2030 onwards, only Class A, B, and C packaging may be placed on the market. Packaging that is recyclable less than 70% will not be allowed. Tariffs will be aligned with RPGs.

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

Although PPWR has not yet been published in all language versions and some details remain unclear, it is necessary to take preparatory steps:

• Stay informed. At Kaligraf, we always have the latest data and information crucial for aligning packaging with PPWR.
• Check what information you already have about your packaging and what information your supplier can share with you.
• Analyze the status of your packaging and create a plan to adapt to PPWR. Assess how recyclable your packaging is. You can also start thinking about how to further improve the sustainability of your packaging.
• If you are in the process of acquiring a new packaging line, launching a new product, or considering innovations, take the upcoming regulations into account. PPWR mandates minimizing all packaging by weight and volume.

1. Read the Regulation Carefully 

PPWR spans 320 pages with chapters and paragraphs, each paragraph containing multiple sections. While complex to interpret, every company must understand the Regulation. Fortunately, agencies like Kaligraf facilitate access to the text.

Ensure teams within your organization fully grasp PPWR, including administrative requirements, reporting obligations, and compliance deadlines. Attend webinars, seminars, and training sessions to enhance awareness and knowledge of the Regulation.

2. Conduct Internal Review and Audit
Companies placing packaged products on the market should immediately document packaging materials and quantities. Conduct an internal audit to analyze current materials and packaging processes. Identify non-recyclable materials and necessary changes. Gather data on packaging quantities, material types, and recyclability. This is crucial for future obligations.

3. Develop an Action Plan
Small and medium-sized enterprises without sustainability managers or packaging departments heavily rely on crafting an action plan. Set specific goals and timelines for implementing recyclable packaging and other PPWR requirements. Assign clear responsibilities to team members for action plan execution.

4. Design for Recyclability
Focus on sustainability and new materials is crucial. Explore and implement fully recyclable packaging materials. Seek advice and collaborate with packaging designers and suppliers to create products that are easier to recycle.

5. Collaborate with Suppliers
Involve suppliers in the process and collaborate to ensure compliance with new requirements. Adjust contracts and agreements to share responsibility for compliance.

6. Administrative Preparations
Implement systems for collecting, managing, and reporting packaging data. Consider using compliance software to prepare mandatory compliance statements and track requirements and deadlines.

7. Communication
Regularly organize informative sessions for employees to update them on progress and new procedures. Communicate with stakeholders, including clients and suppliers, about changes and what they can expect.

8. Monitor and Improve
Establish key performance indicators (KPIs) to measure progress. Conduct regular internal audits to verify compliance and identify opportunities for improvement.

PPWR Assistant
Kaligraf has developed a recycling verification method based on evaluating packaging material specifications. Check the status of your packaging with Kaligraf PPWR Assistant

Compliance begins in 2027 and will evolve with subsequent regulatory data.

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

Manufacturers assess packaging compliance and compile a Declaration of Compliance. This statement, including a review of packaging materials (including weight), must be available to the competent authority upon request. Suppliers are obligated to provide data.

Distributors and retailers are required to verify if the packaging they import/purchase has a Declaration of Compliance.

Compliance assessment rules include, among other things:

• Description of the packaging and its intended use.
• Design drawings.
• Materials used (including weight).
• Standards/norms applied (if applicable).
• Description of how requirements of Articles 6, 7, 8, and 9 of the PPWR are met.
• Manufacturers must retain documents for at least 10 years from the date the packaging was placed on the market.
• Manufacturers must update the Declaration of Compliance.

In cases where the manufacturer is not in the European Union, responsibility falls on the importer of the packaging.

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. Further guidelines for eco-design will be developed by 2027.