Packaging and Packaging Waste Regulation (PPWR) – an overview

One of the most important and ambitious elements of the PPWR are the waste prevention targets. Each Member State must reduce packaging waste generated by 5% by 2030, 10% by 2035 and 15% by 2040, compared to 2018. It is important to note that these targets apply per Member States and not for the Union as a whole. Each Member State will have to proactively reduce its own packaging waste.

The bans, reuse and refill targets,  packaging reduction and minimization targets put forward by the regulation are an essential first step to reach those prevention targets. However, given the current yearly increase of packaging waste in many Member States, it is to be expected that additional measures will be needed. 

The PPWR leaves room for – and encourages – MS to go beyond the requirements it sets (recital 149). They can introduce extra bans and use economic and fiscal incentives, as long as this doesn’t impede the single EU-market. Some of those additional measures include broadening the scope of DRS to include other types of single-use packaging such as drink cartons and single-use glass (art. 50) or DRS for reusable packaging (art. 51). But also the use of fiscal and economic incentives such as with extra taxes or levies for single-use packaging paid by distributors, extra communication requirements or measures at the local level. The set up of more ambitious reuse targets and the use of EPR and DRS budgets to finance reduction and prevention actions are also additional measures left to Member States’s discretion.

Although severely weakened throughout the legislative process and through industry lobby such as McDonald No Silver Bullet campaign, the introduction of binding reuse targets are crucial for the scale-up of reuse systems for packaging in all Member States. 

• The B2B sector is particularly targeted, as 40% of transport packaging within Europe will have to be reusable within a re-use system by 2030, including e-commerce and 70% by 2040 (non-binding). Within a closed environment (e.g. a business location), the sites of an economic operator or between partners of a same economic operator, 100% of the transport packaging will have to be reusable. It is worth noting that cardboard boxes are excluded from the mandatory reuse targets which creates risks of an undesirable shift towards more cardboard packaging waste. 
• Final distributors will have to ensure a reuse of 10% for sales packaging of alcoholic and nonalcoholic beverages and boxes to group sales packages (art 29(5)) by 2030 and endeavour to reach 25% reuse by 2040. They will also have to thrive to provide refill stations for 10% of their products on offer.
• The HORECA sector will also have to contribute by allowing consumers to bring their own containers to be refilled from February 2027 (art. 32) and offer takeaway in reusable packaging for hot and cold beverages as well as ready-made food from February 2028 (art. 33). 

Many exemptions were added on specific economic operators (micro-entreprises, smaller final distributors). Those exemptions risk making the reuse systems less uniform and the communication to consumers less clear. Besides, small businesses are the ones that often pioneer with offering reusable solutions for consumers. 

Opportunities to go beyond the PPWR: The PPWR does allow Member States to set higher reuse targets to meet the prevention targets (art. 29(15 and 16). They can also require manufacturers and final distributors to make reusable packaging available for  other formats than the ones listed in the regulation (art. 51(2)(c)).

The PPWR builds upon the Single-Use Plastic Directive (SUPD) by introducing new bans of single-use plastic items from January 2030 (article 25 and annex V). 

Compared to the SUPD, the bans will be introduced more harmoniously within the Union as they directly apply to all Member States. The bans will cover : 

1. Single-use plastic grouped packaging (shrink wrap, collation film);
2. Single-use plastic packaging for unprocessed fresh fruit and vegetables;
3. Single-use plastic packaging for food and beverages consumed for consumption in the HORECA;
4. Single-use plastic packaging for condiments, preserves, sauces, coffee creamer, sugar and seasoning in HORECA store;
5. Single-use accommodation sector packaging intended for individual booking;
6. Very lightweight plastic carrier bag;

Following strong push-back from industry lobbies – and largely the paper industry – the bans only concern single-use plastic packaging. Similarly to the bans of the SUPD, this creates a risk of a shift from one single-use material to the other, rather than an overall reduction of single-use packaging.

More details on the formats and exemptions will be given by February 2027 in consultation with the EFSA and other stakeholders. This will be essential also to confirm the interplay with the SUPD and the status of the bans that it enabled Member States to set. 

Opportunities to go beyond the PPWR: It must be noted that Member States can maintain bans of those items adopted before 1st January 2025 and bans made from other materials.

Design for recycling

The PPWR strives for all packaging to be recyclable. As of 2030, a grading system for the recyclability at scale of materials will be introduced (art. 6) with grades from A to C (see figure X). This to ensure a maximum recyclability of packaging. A definition of design for recycling criteria for the whole of Europe will be defined by 1st Jan 2028 by the European Commission. By 2030, packaging should be designed for recycling and by 2035 it should be recyclable at scale (Implementing act defining “recyclable at scale” by 1st January 2030). If packaging does not meet the 70% recyclability threshold, it cannot be put on the EU market from 2030 onwards. In 2038, the recyclability threshold will be moved to 80%. 

Several elements will be taken into account by the commission to define recyclability criteria, such as sustainability, and a geography principle, to foster proximity of recycling. The health and safety dimensions will also be taken into account, to ensure that substance of concerns are excluded.

While an essential step in the right direction, it will also be crucial that the Commission plans a sound way of controlling recycled feedstock coming from outside the union. This is what is referred to as the “mirroring clause” to ensure the safety and quality of recycled plastic coming from outside of Europe, and protect the competitiveness of European recycling companies. 

Recycled Content 

By January 2030, each plastic packaging placed on the Union market will have to contain a minimum amount of recycled material. For PET and plastic beverage bottles, this will be 30%, for other contact-sensitive packaging 10% and 35% for all other plastic packaging. 

This could be a game changer as it could drive more closed-loop recycling (vs open-loop recycling that is currently happening with e.g. PET bottles being downcycled into clothing ).

As mentioned above, this also brings challenges, especially with the issue of controlling the quality of recycled feedstock from outside of Europe and the risk of developing recycling processes which could be environmentally harmful.

The PPWR introduces EPR requirements that build on the Waste Framework Directive. From August 2028 onwards, packaging producers will have to be registered in a national register to be allowed to place packaging on national markets. This will also apply to online marketplaces (art. 45(4), which will need to register on behalf of producers.

EPR systems will have to cover additional costs for labelling waste receptacles for the collection of packaging waste and the costs for carrying out surveys of collected mixed municipal waste (in case of such obligation). Besides, EPR fees will have to be modulated according to recyclability performance grades (18 months after the establishment of the grading system). 

Member States will have to ensure that their national EPR schemes and deposit systems dedicate a share of their budget to financing reduction and prevention actions (art. 51(3)). 

Opportunities to go beyond the PPWR: Member States will have the opportunity to include the cost of cleaning up litter into EPR fees when this is undertaken by public authorities or on producers’ behalf.

The PPWR (art. 50) makes deposit and return systems (DRS) as the collection system of choice to reach a separate collection of plastic bottles and cans of 90% by 2029. Member States could only be exempted on strict conditions which no country – without a deposit – qualifies for at the moment. This ambitious target of collection opens the door to high-quality recycling and eases transition towards reuse (through higher capture rates and potential ) as well as litter reduction. The suggestion within the PPWR to also include single-use glass and beverage cartons (article 50(6)) is in line with the idea of introducing an ambitious DRS legislation on the EU level. The PPWR allows for the exclusion of certain packaging based on content (alcohol, dairies). Those content types do however fall under the 90% separate collection target. 

The delegated act on the measurement of a separate collection for plastic bottles and cans (in line with implementing decision 2021/1752 from the SUP) will be key to enable a good monitoring of the effectiveness of DRS. This secondary legislation is expected for February 2027. 

Opportunities to go beyond the PPWR: the PPWR encourages Member States to also include a deposit for other single-use packaging (single-use glass, drink cartons) and reusable packaging (Article 51(2)(a)).