Packaging and Packaging Waste Regulation (PPWR)

In February 2025, the European Union adopted the Packaging and Packaging Waste Regulation (PPWR), an ambitious framework targeting Packaging and Packaging waste. Its goal: to reverse the rising trend of waste production (186.5 kg of packaging discarded annually per capita in 2022 across Europe, including 36 kg of plastic) through a circular economy approach. PPWR replaces the 1994 directive, now imposing uniform and binding rules on all Member States. Below are the key points of this regulation and their impact on packaging professionals and decision-makers.

 

Main objectives of the PPWR: Zero Waste

The European Regulation 2025/40 aims to achieve several major objectives by 2030-2040:

• Reduce packaging waste at its source, targeting a reduction of 15% per capita by 2040 (compared to 2018), by eliminating over-packaging and unnecessary uses.
• 100% recyclable packaging by 2030, through strict eco-design criteria (mono-materials, easy sorting, etc.).
• Incorporate recycled materials: minimum levels of recycled content will be mandated by packaging type from 2030, increasing by 2040 (e.g., 65% recycled plastic in disposable bottles by 2040).
• Limit overpackaging: manufacturers must minimize packaging weight and volume and avoid any « unnecessary » packaging.
• Promote reuse: encourage reusable or refillable packaging, with reuse targets set for 2030 (and indicative targets for 2040) based on industry sectors.
• Harmonize labeling: starting in August 2028, uniform markings will be required to clearly inform consumers about the composition and appropriate sorting channel for each package.
• Eliminate harmful substances (e.g., banning PFAS in food packaging).
• Ban certain single-use applications (e.g., small disposable sachets and bottles, fruit trays < 1.5 kg, condiment pods, disposable tableware for on-site dining, etc.)

All measures aimed at reducing waste at the source.

Who is concerned?

All players in the packaging chain are impacted: packaging manufacturers, packers, brands (food, cosmetics, e-commerce, etc.), distributors, importers… Any company placing packaging or packaged products on the European market must comply with the new regulations.

The regulation covers:

• All types of packaging: commercial, household, industrial, logistical.
• All materials:
  • Plastics (PET, HDPE, PP, PS, multilayer films),
  • Metals (steel, aluminum),
  • Glass,
  • Cardboard,
  • Composites (e.g., food cartons).

No sector is exempt from the new requirements for eco-design and end-of-life management: for instance, every packaging product on the EU market must be practically and economically recyclable by 2030. Additionally, each material will need to incorporate a percentage of recycled content starting in 2030 (targets per material: plastics, glass, metal, paper).

From flexible pouches to industrial pallets, all packaging falls under the scope of the PPWR.

Implementation Timeline (2025 → 2040)

The PPWR came into force on February 11, 2025, and will be applicable 18 months later (August 2026). Its rollout extends until 2040, with key milestones:

Indicative Timeline for the PPWR 2025-2040:

• 2025: Official adoption of the regulation (published in the OJEU on January 22, 2025, effective February 11, 2025).
• 2026: August 12, 2026 – General application of the text across the EU (end of the initial transition period).
• 2027: February 12, 2027 – Restaurants and takeaway vendors must allow consumers to use their reusable containers (cups, boxes brought by the customer) with no additional charges. (NB: Micro-businesses <10 employees are exempt.)
• 2028: February 2028 – Certain categories of packaging must meet composting requirements (e.g., tea bags, coffee pods, stickers on fruits). By February 12, 2028, takeaway services must also provide reusable packaging for their products (as an alternative to disposables).
• August 2028 – Implementation of the new mandatory harmonized labeling on all packaging (common logo/symbol indicating sorting).
• 2030: Target date to achieve multiple goals: all packaging must be recyclable (generalization of the « Design for Recycling » concept); minimum recycled content thresholds come into force for plastic packaging (e.g., 30% recycled for single-use plastic bottles) and other materials (50% glass, 25% metal, 70% cardboard); initial mandatory reuse targets are reached (e.g., 40% of transport and sales packaging reusable by 2030).
• 2035: Mid-term evaluation (potential revision of the regulation planned) and ramp-up of recycling/reuse infrastructures within Member States. (Technical adjustments or additional deadlines may be introduced based on technological and economic progress.)
• 2040: Final horizon for strengthened objectives: minimum recycled content thresholds will be raised (e.g., 50% recycled for plastics subject to food contact, 65% for other plastics), and indicative 2040 reuse targets could become mandatory depending on the 2035 evaluation. By 2040, packaging waste volume is expected to have significantly decreased (≥15% less than in 2018), with most packaging in circulation being reusable or recycled, thus embedding packaging in a circular economy with carbon neutrality.

Implementation by Member States

Being a directly applicable European regulation, PPWR does not require national transposition legislation. However, each Member State must adapt its internal framework (collection systems, EPR schemes, etc.) to comply with the new obligations within the given deadlines. Initial situations vary: some countries were ahead of the curve, while others need to accelerate their reforms. For instance, Germany had already introduced reuse measures in the restaurant sector in 2023 (mandatory provision of reusable containers for takeaway services), aligning with the PPWR requirements effective from 2027.

France, through the AGEC law, had set national reuse targets (5% of reusable packaging by 2023, 10% by 2027) and banned certain single-use plastics, partially anticipating the European regulation. However, other countries have yet to implement bottle deposit systems or reuse quotas; they will need to invest quickly (recycling infrastructure, labeling standardization, etc.) to catch up by 2026-2030.

Overall, preparations for implementation are underway across the EU: in late 2024, the Commission convened a working group with stakeholders to facilitate the transition and will issue harmonized standards as well as delegated acts detailing certain technical criteria of PPWR. Some adjustments and sector-specific exemptions are planned (e.g., temporary flexibility for certain industrial or medical packaging), but no general postponement has been announced at this stage. Member States are required to adhere to the common schedule, despite logistical challenges. The success of PPWR will therefore partly depend on cooperation between national authorities and industry stakeholders to implement the new requirements within the deadlines (unique labeling, reuse systems, increased collection, etc.). Short-term disparities may arise (e.g., “pioneer” States vs. “follower” States), but by 2030, the entire European market will need to comply with unified standards, reducing the risk of distortion between countries.

Impacts on industrial strategies

•  The «Design for Recycling » approach becomes essential: For companies, PPWR entails a profound overhaul of packaging strategies. Starting now, manufacturers and market players must adapt their packaging designs: more sustainable materials, optimized formats, and the elimination of complex combinations that are difficult to recycle.
• Elimination of non-recyclable multi-material packaging: These must be rethought (replacing non-recyclable layers, using mono-resins, etc.).
• Downsizing excessively large or overly lightweight packaging to reduce waste.
• Use of recycled materials: Companies must also invest in recycled materials, which can present added costs and supply constraints, given the limited availability of certain food-grade recycled resins.
• In the short term, compliance may lead to significant additional costs (packaging R&D, new tooling, production line adjustments) as well as logistical complexity (establishing closed-loop collection systems, managing reusable containers, etc.).

New opportunities unlocked by PPWR:

• Innovation: development of alternative materials (recyclable polymers, bio-based compostable materials for certain specific uses, etc.), creation of new economic models (reuse, refill, deposit systems).
• Enhancement of brand image towards consumers who are increasingly environmentally conscious. Early industry adopters of sustainable solutions can stand out commercially and gain easier access to public markets (which will include mandatory green criteria).

New challenges:

Generating savings (material reduction, range simplification) versus the cost of recycling channels. For example, we anticipate intensified collaborations within the industry—such as partnerships between packagers and recyclers to secure the supply of recycled materials, or cross-sector standardization of certain reusable containers.

Ultimately, the PPWR encourages industry to reconcile eco-design with competitiveness: packaging sustainability becomes a regulatory imperative but can also serve as a driver for innovation and growth (new packaging solutions, cost optimization over the lifecycle, new deposit services, etc.).

Focus on materials: constraints and opportunities

• PET – Bottles, flasks, thermoforms,
  • Strengths: The most recycled plastic worldwide, PET benefits from PPWR, which reinforces this dynamic. Targets include 30% recycled plastic by 2030 in food-grade PET packaging (50% by 2040). Beverage bottles must contain 30% rPET by 2030, increasing to 65% by 2040. Major beverage groups, such as Coca-Cola and Danone, had already made voluntary commitments to rPET, which the PPWR now formalizes as regulation.
  • Challenges: Securing the supply of food-grade rPET remains a core issue, as demand currently outpaces supply. Eliminating additives or barriers that hinder recycling (e.g., certain multi-layered PET types) is also imperative, though industrial alternatives are already available.
  • Opportunities:
• Expanding deposit systems for single-use bottles, which, where implemented, achieve collection rates exceeding 90%, with material quality far superior to that of selective sorting systems.
• Developing collection and recycling channels for PET trays.
• Reusing (RefPET reusable bottles, which has existed for over 30 years and could contribute to future reuse quotas, provided the logistics involved do not outweigh the associated benefits—this needs case-by-case assessment.
• Investments in chemical recycling of PET (depolymerization), which could increase the supply of high purity rPET. However, chemical recycling faces two major challenges: the first is economic due to investment costs and energy consumption; the second is scalability and the ability to source clean flakes. A chemical recycling process requires a baseline level of quality material, except for color.
• Beverage cans and Tins (Aluminum/Steel)
  • Strengths: Metal packaging, often well recycled (average recycling rate > 75% in the EU), is reinforced. Recycling targets: Minimum 25% recycled metal in cans/boxes by 2030 – a level already achieved by many manufacturers, with potential for further increase.
  • Challenges:
• Further improving collection (expanding can deposit systems in countries where they are not yet implemented).
• Replacing problematic interior coatings (e.g., phasing out BPA and PFAS in liners).
• Opportunities: Recycled metal saves ~95% energy compared to primary metal production, significantly reducing the carbon footprint of cans – an advantage if eco-balance becomes a key criterion for consumer choices.

• Glass – Bottles, Jars… :
  • Strengths: As an inert material, glass offers excellent recyclability. Glassworks can incorporate up to 90% of recycled cullet into the production of new bottles without compromising final product quality. PPWR sets a target of 50% recycled cullet in new glass packaging by 2030.
  • Weaknesses: Glass is heavy and energy-intensive to produce. However, it is important to note that each additional 10% of recycled glass introduced into the furnace achieves a further 5% reduction in CO₂ emissions and a 3% decrease in energy consumption. Investments in low-carbon electric furnaces are also among the areas for improvement, as is reducing bottle weight.
  • Challenges :
• Enhancing the recycling of colored glass, which still suffers from losses (optical sorting).
• The reuse of glass bottles, especially within short supply chains, is recommended where appropriate. When glass is reused, it results in the lowest product volume per transport unit among various packaging options; however, it should be noted that reuse requires considerable logistical support.
• Standardized bottles versus sorting centers for bottles from different brands.

Overall, glass is expected to remain a key material, particularly in the alcoholic beverage sector (wine, beer, spirits), where few low-carbon alternatives meet technical criteria, except for cans in small formats and bag-in-box solutions for larger wine formats. Its weight, fragility, and carbon footprint remain its primary drawbacks.

• Paper-based packaging and beverage cartons – Cartons, fiber-based packaging, composite cartons like Tetra Pak (paper/aluminum/plastic):

• Challenges: Beverage cartons are composite packaging, combining several materials: cardboard/fiber, plastic, and often a thin layer of aluminum. Under the PPWR, they are classified as multi-material packaging (category 3), and each layer is subject to separate regulations.

The plastic layer must comply with requirements for plastics (e.g., minimum 35% recycled content by 2030, 65% by 2040 according to packaging category).

The thin aluminum layer has no recycled content mandate, but it must meet recyclability targets and be included in metal recycling streams.

• Risks: For the cardboard component, Directive 94/62/EC as amended requires at least 75% recycled fiber by the end of 2030. The PPWR sets specific recycled content requirements only for plastic packaging.

No major player in the composite carton sector (Tetra Pak, Elopak, SIG, Stora Enso, etc.) has publicly committed to integrating recycled cardboard into the raw material (kraft board). Their initiatives mainly focus on:

• Making cartons recyclable,
  • Increasing the collection and recycling of cartons (targeting 70% recycling rate by 2030),
  • Raising the recycled content in the plastic layer, not in the cardboard.

This could pose medium-term challenges as recycled content requirements become stricter for all materials, including paper/cardboard.

Currently, cartons are recycled at an average rate of about 50% in the EU and 27% globally, which falls short of circularity. Carton recycling allows for the separation of cellulose fibers, reused in the production of recycled paper, corrugated cartons, or tissues. The plastic and aluminum layers (« PolyAl »), extremely difficult to separate, are either used for energy recovery (incineration) or recycled into non-food products (posts, benches, plastic pellets, etc.).

Manufacturers will need to improve layer separation processes (developing new recycling methods to extract fibers, aluminum, and plastics) or revisit material composition.

• Opportunities:
  • Eliminating aluminum and replacing it with paper-based barrier layers (pilot projects underway).
  • Creating chemical recycling streams for polyethylene or PolyAl to achieve “virgin” quality.

• Flexible plastics and multilayer films — pouches, bags, food wraps, and similar packaging — represent one of the most complex segments to make circular. These packaging materials are often made from multiple materials (such as plastic/aluminum laminates), making them difficult to recycle today. The PPWR requires these products to be recyclable by 2030, necessitating a radical redesign.
• Challenges: include switching, where feasible, to mono-material films (such as all-polyethylene) so they can be recycled together, as well as developing dedicated recycling technologies (optical sorting of films, chemical recycling to break down multilayers). The regulation does not mandate high recycled content for food-grade films (which remains challenging for food contact) but strongly encourages source reduction: certain small single-use plastic packages will simply be banned (e.g., ketchup sachets), prompting alternative solutions (reusable pods, bulk dispensers).
• Opportunities: innovation is flourishing (high-barrier mono-PP films, recyclable barrier coatings, biodegradable plastics—which are not always recommended as they do not encourage recycling—for very specific uses like tea bags). Large packaging companies are also exploring reuse models for e-commerce or takeaway services (reusable logistics pouches, deposit systems for bags).

While improving the recyclability of flexible packaging remains the key challenge, PPWR is creating a market for any solution that enables it: from food-grade recycled resins (which need to be developed for films) to dedicated collection systems (such as in-store pouch return programs).

• High-Density Polyethylene (HDPE) – Milk bottles, detergent bottles, jerrycans, etc.: This rigid, robust, and opaque plastic is already widely recycled for non-food contact uses (for example, detergent bottles containing up to 50% recycled HDPE). For food contact applications, very little recycled content is currently permitted (with the exception of some trials on milk bottles). Classified as « sensitive plastic packaging (non-PET), » food-grade HDPE will be required to incorporate 10% recycled content by 2030 (rising to 25% by 2040).

• Challenge: Securing approvals for food-grade recycled HDPE (which remains rare) or developing closed-loop collection systems (such as collecting and regenerating milk bottles in a short circuit).
• Advantages: HDPE is relatively easy to recycle mechanically (sorting by color, regranulation).
• Opportunities: The expansion of deposit schemes for plastic bottles, if extended beyond PET, could provide a source of high-purity HDPE. Replacing virgin HDPE with recycled material will reduce the carbon footprint of packaging. Some developments are underway in chemical recycling, but energy costs and the price of catalysts remain prohibitive.

In summary, HDPE benefits from a strong technical recycling infrastructure; the primary challenge will be extending recycling to food-grade applications.

• Polypropylene (PP) – Yogurt pots, trays, caps, etc.: PP is ubiquitous, yet its effective recyclability remains low (with recycling rates currently below 20%). Requirements: like HDPE, 10% recycled content in food-contact PP packaging (such as pots and trays) by 2030, rising to 25% by 2040; and 35% recycled content for non-food PP packaging (such as buckets) as early as 2030.

• Challenges: Creating sorting streams to separate PP from other plastics (often mixed with PE) and enhancing PP packaging recyclability, such as using mono-material PP instead of PS+film trays.  Technological challenge: producing food-grade recycled PP—currently, very few sites worldwide are capable, as this requires advanced decontamination processes or chemical recycling. Industry strategies: Some stakeholders are already replacing PS or PVC with PP (which is more recyclable), increasing the volume of PP to be recycled.
• Opportunities: If demand for recycled PP surges, this will justify investment in new specialized recycling plants (including marker-based sorting and pyrolysis of PP back into monomers). PP is also included in initiatives to standardize tethered caps on bottles (to prevent loss and facilitate PP recovery).

In summary, PP has significant ground to cover on the path to circularity, but the PPWR has made it a priority for innovation.

• Polystyrene (PS) & various plastics – *Yogurt pots, single-use packaging, EPS trays…*: PS stands out as one of the major potential losers under PPWR. Although widely used for years (yogurt containers, cups), it is now scarcely recycled, and several countries have already restricted its use (for example, the SUP Directive’s ban on expanded polystyrene cups and boxes). Outlook: by 2030, non-recyclable PS packaging will be non-compliant with PPWR—therefore, many manufacturers plan to replace PS with PET or PP for pots and trays. Exceptions: PS could survive through chemical recycling; consortia (such as Trinseo, Ineos…) are piloting polystyrene depolymerization plants that convert it back to styrene monomer, enabling recycled PS suitable for food contact. Should these technologies succeed by 2030, PS could meet the criteria (e.g., integrating 10% recycled content in yogurt pots by 2030, which is impossible by mechanical recycling but feasible by chemical means). Niche opportunities: PS offers excellent barrier and foaming properties, so the industry could advocate for its retention if a circular value chain is established. However, for now, many brands have already decided to phase out single-use PS (shifting to cardboard or PP instead).

• Other Plastics: PVC, PLA, and More
• Packaging PVC is set to be phased out, even though, paradoxically, recycling of this material is advancing in the construction sector, but its decay of use in packaging is now making it as a contaminant to other recycling streams
• Bioplastics (such as PLA, PHA) are permitted only for specific applications such as for example, compostable uses involving food waste. PPWR remains cautious regarding bio-based plastics: there is no mandated quota, but a reassessment is planned for 2028 that could potentially allow certain bio-attributed plastics to count toward recycling targets. In short, the priority is to reduce and enhance the recyclability of conventional plastics before relying on substitutes.

Professional and Stakeholder Responses

The adoption of PPWR has sparked strong reactions throughout the packaging ecosystem. While there is a broad consensus on environmental objectives, practical implementation raises concerns for certain sectors.

Industry federations (plastics, cardboard packaging, beverage sectors, etc.) welcomed the harmonization at the European level but urge caution regarding feasibility. For example, a coalition of professional associations criticized a provision introduced by the Council allowing for the creation of “state-run PROs” (producer responsibility organizations) within the sector. According to them, assigning EPR to state bodies without a mandate from producers would undermine the principle of extended producer responsibility and could jeopardize the effectiveness of recycling systems. They have formally requested that this provision be removed from the final text.

Major players in the agri-food and consumer goods sectors, meanwhile, have expressed broad support for PPWR—many had already made voluntary commitments (such as achieving 100% recyclable plastics by 2025-2030 or reducing virgin plastic use by a set percentage). This regulation reinforces these strategies, while also presenting practical challenges. Companies such as Nestlé, Unilever, and Coca-Cola have publicly approved the objectives (waste reduction, circularity), yet emphasize the need for innovation to achieve them: ensuring sufficient availability of recycled materials, establishing new reuse schemes, etc. Several companies are calling for public-private partnerships to develop the necessary sorting and recycling infrastructures. Others have welcomed the clarifications provided (unified rules replacing 27 different national regulations), which enhance investment predictability. However, some remain cautious regarding certain technical aspects: for instance, the ban on specific single-use packaging is considered too abrupt by the fast-food sector, which is requesting more time to transition to reusable alternatives.

Among packaging industry organizations, reactions range from satisfaction to vigilance. PlasticsEurope (plastic producers) and European Plastics Converters (EuPC) have endorsed the goal of increasing recycling rates but warn of a potential shortage of high-quality recycled plastics to meet quotas as early as 2030. They advocate for recognition of “complementary” solutions such as chemical recycling and, in the future, the integration of bio-based materials to achieve objectives. Paper, cardboard, and glass packaging manufacturers broadly support the move toward sustainability, viewing it as an opportunity to increase market share for their already highly recyclable materials. Eurochambres (the association of chambers of commerce), however, has warned about the costs for SMEs and called for financial support to facilitate the transition.

Environmental NGOs (Zero Waste Europe, Rethink Plastic, etc.) welcomed PPWR, deeming it necessary to reduce plastic pollution. They are particularly pleased with action against “persistent toxic substances” (such as PFAS) and the clear intent to tackle over-packaging. However, many see the final compromise as only partial progress: under pressure from certain lobbies, some strong measures were watered down—for example, the removal of mandatory quantitative reuse targets in the hospitality sector (replaced by more general obligations) disappointed advocates for reuse. Similarly, the option for companies to substitute single-use plastics with cardboard attracts criticism: NGOs fear this could simply shift pollution from one material to another if true systemic change (overall packaging reduction and widespread reuse) is not implemented.

En résumé, le PPWR est perçu comme une avancée majeure vers une économie circulaire des emballages, mais son succès dépendra de la mise en pratique. Les professionnels de l’emballage reconnaissent l’impulsion positive donnée par l’UE – « un pas important vers la neutralité climatique et la circularité d’ici 2050 » – tout en appelant à un déploiement réaliste, fondé sur le dialogue et l’innovation. Les prochaines années seront déterminantes pour transformer ces nouvelles obligations en réalisations concrètes, conciliant exigences environnementales et réalité industrielle.

In summary, the PPWR is seen as a major step forward toward a circular packaging economy, but its success will depend on effective implementation. Packaging professionals acknowledge the positive momentum provided by the EU: “an important step toward climate neutrality and circularity by 2050” while calling for a pragmatic rollout based on dialogue and innovation. The coming years will be crucial for turning these new obligations into tangible achievements, balancing environmental demands with industrial realities.

Official Sources and Key Documents

• Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste (OJ EU 22.01.2025) environment.ec.europa.eu.
• EU Council press release (16 Dec. 2024) – “Sustainable Packaging: Council Approves New Rules for Less Waste and More Reuse” consilium.europa.eu
• European Commission Presentation – “Packaging Waste” (2025): official page on packaging regulations environment.ec.europa.eu
• FKuR Fact Sheet (Feb. 2025) – “PPWR at a Glance: New EU Packaging Waste Regulation” (detailed requirements: recyclability, recycled content, reuse, etc.) fkur.com fkur.com.
• Joint statement from packaging industry representatives (Jan. 2024) – Opposition to “state-run PROs” in the PPWR europen-packaging.eu.
• Packaging Europe (March 2024) – “Packaging industry shares praise and concerns surrounding PPWR deal” (reactions from associations and NGOs) linkedin.com.
• Zero Waste Europe (March 2024) – Press release “PPWR deal: good steps to reduce packaging waste despite worrying loopholes”.

(Other reference documents: Initial proposal COM(2022)677, positions from FoodDrinkEurope, KPMG legal analyses assets.kpmg.com, etc.)