There are only months remaining now until the EU’s new Packaging and Packaging Waste Regulation (PPWR) rules take effect. As PPWR looms, how can food and drink prepare?
When August 12 rolls around later this year, it will bring with it the implementation of new packaging regulation PPWR and a sweeping set of harmonised requirements. Set to be applied across the 27 member states in a bid to slash packaging waste, boost recycling, promote reuse and mandate recycled content, the ambition is to make all packaging on the EU market recyclable by 2030.
The update is set to spell significant change for retailers, manufacturers and foodservice businesses and – with the end to the 18-month transition period fast approaching – it’s critical that teams understand how their own value chain will be affected.
What is the Packaging and Packaging Waste Regulation?
Created in response to rising concern at volumes of packaging waste, the regulation aims to tighten up processes around the design, distribution and disposal of packaging entering into the EU market, in order to foster a more circular economy – one in which the focus is reuse and regeneration.
After years in discussion the regulation first received unanimous support from Ambassadors of the EU Council on March 15, 2024.
Its rules were adopted by the European Parliament a month later, before entering into force on January 22, 2025, and triggering an 18-month transition period within which affected businesses must ready themselves for compliance ahead of the August 12 deadline.
How can businesses best use the next six months to ensure they don’t fall foul of PPWR?
1. Map out your current packaging portfolio
Many food and drink businesses are reliant on a vast, interconnected web of packaging providers, so embedding greater transparency across your operations is a critical first step.
- Identify every stakeholder involved. This includes raw material suppliers but also printers, converters, manufacturers and distributors.
- Document each material flow. Create a visual map that highlights the movement of all physical packaging, as well as the flow of information (orders, invoices etc).
- Break down each piece of packaging. To comply with PPWR, understand what materials are used, in what volume, and for what reason. Metrics like weight, recyclability and reusability are key.
2. Begin keeping detailed records
Each piece of packaging placed on the EU market will ultimately need to be accompanied by a PPWR declaration of conformity.
These records will need to include information related to safety, recyclability, minimum recycled content, and reusability – and held on file for a number of years, five for single-use packaging and 10 in the case of reusable packaging.
Beyond compliance, accurate datasets supplied by proactive firms may also be used as an advocacy tool, i.e., to inform secondary legislation related to PPWR and ensure its commensurate with industry’s impact.
3. Uunderstand risk areas
Without all secondary legislation relevant to PPWR in place, there will inevitably be some unknowns here.
However, it’s likely that from August, some core measures related to the design and materials used in packaging take effect.
- Thresholds will be imposed on the use certain substances such as lead, cadmium, mercury and hexavalent chromium, as well as PFAS or “forever chemicals.”
- Plans to specify maximum adequate limits for weight, volume, wall thickness and empty space for the most common packaging types and formats
Identify now where current packaging is likely to fall short and take proactive steps to source alternative materials and minimise weight.
4. Map out the key PPWR implementation dates
Look further ahead too, with many future requirements coming into effect on a staggered timeline.
These include:
February 12, 2027: Foodservice outlets must allow consumers to bring their own contains for takeaway food and drinks
Feb 12, 2028: Foodservice outlets must provide an option for consumers to purchase readymade hot and cold food in reusable takeaway packaging
August 12, 2028: Labels on all packaging with information on material composition (excluding DRS and transport packaging)
January 1, 2030: All packaging must be designed for recycling
Use these dates as fair warning and begin to initiate steps toward compliance now.
5. Consider how to manage your compliance
As this is an ongoing process, with complex regulation involved, it’s also worth appointing a compliance lead tasked with remaining up-to-date as national laws come into effect, and pre-emptively understanding how the business is likely to be affected.
Understanding who PPWR applies to
Whether fully compliant or not, all businesses classed as “producers” under the terms of PPWR fall subject to the concept of Extended Producer Responsibility or EPR, i.e., bear the cost of the packaging’s entire lifecycle rather than it falling to local authorities to, say, dispose of household packaging waste.
In the PPWR, “producers” are classified as those that first make packaging available on the EU market, and could potentially encompass retailers, manufacturers, importers and distributors dependent on their role.
The financial impact of EPR has already been laid bare by its implementation in some individual European countries.
In the UK, for example, the first set of fees under a national EPR scheme were applied from January 2025, with even small to medium food businesses reporting costs of hundreds of thousands of pounds per month.
This has triggered significant backlash from industry, even driving some to move away from more sustainable materials, such as glass, and opt for plastic instead in a bid to reduce weight. Trade body British Glass called the move by firms “short-sighted” insisting that future planned policy changes are likely to tip the scales back in favour of glass in the longer-term.
What are the consequences of not being PPWR compliant?
While the EU regulation itself doesn’t prescribe penalties, it does require all Member States to “introduce effective, proportionate, and dissuasive enforcement measures” to ensure compliance.
In short, businesses that fall short will face consequences – and central to compliance will be injecting full transparency into the packaging ecosystem, with comprehensive record-keeping critical to staying on track.
There are supply chain software solutions available that can help retailers, manufacturers and foodservice operators navigate these challenges. These platforms can help standardise the collection and management of all data related to packaging to ensure information is available, centrally, at a glance. They can audit and optimise complex value chains to check that all boxes are ticked, reporting and analysing insights across an entire range of products.
The bottom line is that, with only a few months left until the PPWR takes effect, the race is on for all European food and drink firms to get their ducks in a row, understanding how they’re affected, what changes are required and where are the gaps in their knowledge.
Greer McNally
Greer has over 15 years’ experience writing about trends in the food and retail sectors. She lives in a little village by the sea in Northern Ireland and loves creating content that informs how people think about the food industry. A recent career highlight was interviewing the legend that is Dr Temple Grandin.
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