The Packaging and Packaging Waste Regulation (PPWR) is the European Union’s latest initiative to combat packaging pollution and foster a circular economy for packaging materials, to achieve the climate neutrality objective by 2050.
Published in the European Parliament’s Official Journal on January 22, 2025, and entering into force on February 11, 2025, this regulation replaces the existing Packaging and Packaging Waste Directive.
It introduces innovative standards and ambitious targets designed to revolutionise the production, use, and recycling of packaging materials across Europe.
For businesses involved in logistics or supply chain operations, the impact of these changes cannot be understated. However, with over 120 pages of technical and legal details, the regulation can feel overwhelming to navigate. That’s why we’ve created this comprehensive guide.
As a leader in eco-friendly transport packaging solutions, Corplex is here to help businesses like yours understand and adapt to this transformative regulation.
This guide will break down the most critical aspects of the PPWR, focusing on its implications for transport packaging.
Whether you manage logistics, supply chain strategies, or sustainability initiatives, this guide is packed to provide you with practical insights so you can prepare for the future.
By the end of this guide, you should have a clear understanding of:
Let’s explore how the new regulation is set to reshape transport packaging and how your business can lead the way in sustainable practices!
PPWR, short for Packaging and Packaging Waste Regulation, is a comprehensive legislative reform designed to address packaging waste at its source.
The PPWR introduces robust new standards to enhance packaging design, maximise recyclability, promote reusability, and increase waste management efficiency.
It applies to all types of packaging within the EU, including primary (product packaging), secondary (grouping packaging), and tertiary/transport packaging (used during transportation and storage of products).
This new regulation underscores the EU’s dedication to minimising environmental harm while fostering a sustainable circular economy for packaging materials.
Packaging is crucial in safeguarding and transporting products; however, its environmental toll is substantial. That is why it is necessary to shift from the take-use-dispose model.
The Packaging and Packaging Waste Regulation (PPWR) represents a pivotal shift in the European Union’s approach to sustainable packaging and waste management. Among its key focus areas is the article 6 about recyclability, a cornerstone of the EU’s broader efforts to transition to a circular economy.
First paragraph of the article 6 makes it clear.
All packaging placed on the market shall be recyclable.
All packaging on the market has to be recyclable in practice. This means that all packaging must be designed and manufactured in such a way that it can be recycled, and its materials are fit for reuse and repurposing.
The new regulations also introduces the concept of “packaging waste recycled at scale”, concepts defined in Article 3. (32) :
Packaging waste recycled at scale’ means packaging waste which is collected separately, sorted and recycled in installed infrastructure, using established processes proven in an operational environment which ensure, at Union level, an annual quantity of recycled material under each packaging category listed in Table 2 of Annex II equal to or greater than 30 % for wood and 55 % for all other materials; it includes packaging waste that is exported from the Union for the purpose of waste management and which can be considered to meet the requirements of Article 53. (11)
Long story short, packaging must be capable of being separately collected and sorted into specific waste streams without affecting the recyclability of other materials. This ensures that new recycled materials remain uncontaminated and of high quality. These secondary raw materials should be capable of substituting primary raw materials.
Article 6 of the PPWR also introduces a classification system for packaging recyclability, assigning grades from A (highly recyclable) to C (minimum recyclability).
Packaging that falls below these grades (e.g., D or E) will no longer be allowed on the market from 1 January 2030.
By promoting design-for-recycling principles, the regulation seeks to reduce packaging waste, enhance resource efficiency, and foster the creation of high-quality secondary raw materials.
Complying with Article 6 means rethinking packaging design from the ground up. This involves not only selecting materials that are recyclable but also ensuring that the packaging can be easily processed by existing recycling infrastructure.
The European Union’s Packaging and Packaging Waste Regulation (PPWR) establishes a groundbreaking framework to reduce environmental impact and promote circularity in packaging. This includes strict guidelines on raw materials, recycled content, and the use of hazardous substances in packaging.
Article 7 of the PPWR sets ambitious targets for incorporating recycled content into plastic packaging to minimise reliance on virgin materials:
Certain types of packaging, such as medicinal product packaging, medical device packaging, compostable plastics, and transport packaging for dangerous goods, are exempt from these requirements. These targets aim to foster innovation in recycling technologies and ensure uniform standards across the EU market.
To enhance sustainability and safety, the PPWR also addresses the composition of raw materials used in packaging.
Packaging placed on the market shall be so manufactured that the presence and concentration of substances of concern as constituents of the packaging material or of any of the packaging components is minimised, including with regard to their presence in emissions and any outcomes of waste management, such as secondary raw materials, ashes or other material for final disposal, and to the adverse impact on the environment due to microplastics.
To support these measures:
By integrating recycled content and minimizing hazardous substances, the PPWR paves the way for a packaging industry that is both sustainable and aligned with the principles of a circular economy.
The PPWR introduces stricter regulations on packaging minimisation through Article 10 and Article 24, setting new benchmarks for reducing packaging weight, volume, and empty space in transport and e-commerce packaging. These measures ensure that packaging is as compact as possible while maintaining product protection, usability, and safety.
Excessive packaging depletes resources and generates unnecessary waste. By optimising packaging, businesses not only comply with regulatory standards but also lower costs, enhance sustainability credentials, and improve their brand’s environmental reputation. For consumers, less packaging means reduced waste, promoting more sustainable consumption habits.
By January 1, 2030, all packaging must be designed to minimise weight and volume while preserving functionality.
Certain packaging formats are exempt if they are:
To curb unnecessary packaging, Article 24 mandates strict limits on empty space within transport, grouped, and e-commerce packaging.
By 1 January 2030 or 3 years from the entry into force of the implementing acts adopted pursuant to paragraph 2, whichever is the latest, economic operators who fill grouped packaging, transport packaging or e-commerce packaging shall ensure that the maximum empty space ratio, expressed as a percentage, is 50 %.
Additional Considerations:
Minimising packaging is more than just regulatory compliance—it’s a strategic move toward sustainability and cost efficiency. Companies that adopt these principles will reduce waste, contribute to a circular economy, and strengthen their environmental commitments.
The most effective way to manage waste is to prevent its creation in the first place. That’s why reusability is a core principle of the Packaging and Packaging Waste Regulation (PPWR).
Article 29 introduces ambitious reuse targets to significantly reduce reliance on single-use packaging and promote sustainable alternatives across industries.
Transport packaging plays a crucial role in this transition, with specific targets set for 2030 and 2040:
Transport packaging includes a variety of formats used for shipping and logistics, such as:
While PPWR sets clear reuse targets, Article 29 allows exemptions for specific cases:
To support the transition to reusable packaging, the European Commission will take key steps:
Additionally, Member States may grant exemptions from reuse obligations for up to five years, depending on their national waste reduction performance. The European Commission also has the authority to introduce further exemptions as needed.
This regulatory framework represents a paradigm shift towards circularity, ensuring that transport packaging aligns with sustainable, long-term environmental goals.
Article 12 of the Packaging and Packaging Waste Regulation (PPWR) establishes standardised requirements for labelling packaging to enhance waste sorting, recyclability, and consumer awareness.
It outlines mandatory labelling requirements, harmonised pictograms, and digital marking technologies, ensuring clear communication on packaging disposal and environmental impact.
The European Commission is tasked with adopting implementing acts by the 12 August 26 that define the details of harmonised packaging labels. These acts will establish:
Packaging manufactured before the compliance deadlines (August 12, 2028, and February 12, 2029) may continue to be sold for up to three years after the labelling requirements come into effect.
Extended Producer Responsibility (EPR) is a key principle in the Packaging and Packaging Waste Regulation (PPWR), ensuring that producers are accountable for the environmental impact of their packaging throughout its lifecycle.
This policy follows the polluter pays principle (Article 191(2) TFEU), shifting the financial and operational burden of waste management from consumers and municipalities to producers and importers.
Under EPR, producers must prevent waste generation, improve recyclability, and finance waste collection and treatment, aligning with the EU’s broader circular economy and sustainability goals.
All businesses that introduce packaging or packaged products into the EU market must comply with EPR regulations. These obligations include:
Producers can delegate their EPR obligations to Producer Responsibility Organizations (PROs), which manage collection and recycling efforts on behalf of multiple producers.
Non-EU producers selling online to EU consumers must appoint an authorised representative in each Member State where their products are sold.
If a logistics company unpacks, repackages, or modifies products imported into the EU, it may be classified as the “producer” for the new packaging it introduces.
Companies offering warehousing and shipping must ensure their clients comply with EPR obligations. If a producer fails to comply, the fulfillment service provider must suspend their services.
To ensure adherence to EPR regulations, the PPWR mandates strict enforcement, including:
The conformity assessment process ensures that packaging aligns with the standards outlined in the Packaging and Packaging Waste Regulation (PPWR), safeguarding compliance with sustainability and safety requirements.
This procedure, detailed in Annex VII, Module A, relies on internal production control, a streamlined approach where manufacturers take full responsibility for verifying compliance with Articles 5 to 12 of the PPWR.
Manufacturers must prepare comprehensive technical documentation to evaluate packaging conformity. This documentation includes:
The manufacturer is required to implement robust measures to ensure that the manufacturing process consistently produces packaging compliant with technical documentation and regulatory requirements. This includes ongoing monitoring and quality assurance practices.
For each packaging type, manufacturers must draft a written Declaration of Conformity. This declaration serves as a formal attestation that the product adheres to PPWR standards. Importantly:
Manufacturers can delegate the responsibility for maintaining technical documentation to an authorised representative. This delegation must be formally defined and documented, ensuring full accountability and traceability.
Disclaimer:
Please note that this information is not intended to be legal advice. It provides a general overview of the PPWR based on accessible data. Readers are encouraged to consult publicly available information from relevant EU authorities and seek advice tailored to their specific circumstances if required.
This page was updated on January 2025, based on the Packaging and Packaging Waste Regulation published in the EU Official Journal on 22/01/2025.
Source website: www.eur-lex.europa.eu
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