PPWR

Packaging and Packaging Waste Regulations

Summary

The Packaging and Packaging Waste Regulation (PPWR) is an EU regulation intended to reduce packaging waste, improve packaging sustainability, increase recycling and promote packaging reuse across the EU. The regulation introduces requirements covering packaging design, recyclability, recycled content, labelling, minimisation of packaging, reuse systems and restrictions on certain substances used in packaging.

Who It Applies To

The PPWR applies to all economic operators placing packaging or packaged products on the EU market, including:

Manufacturers.
Importers.
Distributors.
Brand owners.
Online retailers selling into the EU.
Businesses that use packaging to supply products to customers.
Packaging manufacturers and converters.

The regulation applies regardless of whether a company is based within or outside the EU if it places packaged products on the EU market.

What Qualifies a Company to Have to Comply

Unlike the UK EPR regime, the PPWR does not contain a minimum turnover or tonnage threshold before obligations arise.

A company must generally comply if it:

Manufactures packaging for the EU market.
Imports packaged products into the EU.
Places packaged products on the EU market.
Supplies products under its own brand in packaging.

In practice, any organisation responsible for placing packaging or packaged goods on the EU market is likely to have obligations under the PPWR.

What a Company Needs to Do to Comply Immediately

Organisations supplying packaging into the EU should begin by:

Reviewing their packaging portfolio to determine which packaging formats are covered by PPWR requirements.
Preparing and maintaining a Declaration of Conformity (DoC) for each packaging type, supported by technical documentation demonstrating compliance.
Collecting technical evidence relating to:
- Packaging composition.
- Material content.
- Recyclability.
- Recycled content.
- Substance compliance.
Assessing packaging against packaging minimisation requirements, ensuring packaging is no heavier, larger or more material-intensive than necessary.
Checking compliance with substance restrictions, including limits on heavy metals and restrictions on PFAS in food-contact applications.
Registering with applicable national Extended Producer Responsibility (EPR) schemes and reporting packaging volumes where required.

What a Company Will Need to Do to Comply in the Future

Over the coming years, organisations will need to progressively meet additional PPWR requirements, including:

Recyclability Requirements

Packaging must be designed for recycling and will be subject to recyclability performance criteria and classifications. Packaging that cannot meet minimum recyclability standards may eventually be prohibited from the EU market.

Recycled Content Requirements

Packaging will need to contain a minimum percentage of recycled content, with specific targets set for different packaging types.

Packaging Minimisation

Packaging minimisation requires careful consideration of the design and materials used.

Businesses will need to demonstrate that packaging volume and weight have been minimised and that unnecessary empty space or excessive packaging has been eliminated.

Reuse and Refill Targets

Specific sectors will be subject to mandatory reuse and refill targets, requiring the introduction of reusable packaging systems and infrastructure.

Harmonised Labelling

Packaging will increasingly need to carry standardised EU labelling to support consumer sorting and recycling.

Ongoing Technical Documentation

Businesses will need to maintain technical documentation and keep Declarations of Conformity up to date to demonstrate compliance throughout the product lifecycle.

Penalties for Non-Compliance

The PPWR does not establish EU-wide fines. Instead, each Member State must create its own penalty regime. Penalties must be effective, proportionate and dissuasive. Potential consequences include:

Administrative fines.
Product withdrawal from the market.
Sales restrictions.
Customs intervention and import blocks.
Other national sanctions established by Member States.

For many businesses, the most significant risk is the inability to place products on the EU market if they cannot demonstrate compliance through the required documentation and technical evidence.

What Could Trigger Enforcement?

Examples include:

Failure to prepare or maintain a required Declaration of Conformity (DoC).

Failure to maintain the required technical documentation.

Non-compliance with recyclability, recycled-content, labelling, packaging minimisation or reuse requirements.

Breaches of substance restrictions, including requirements relating to PFAS and heavy metals.

How We Can Help

Our team can assist your company in understanding and complying with the PPWR requirements.

The team's principal aim is to take away the burden of putting together the data requirements for PPWR compliance.

By leveraging our expertise, your company can focus on its core business activities while ensuring compliance with the evolving PPWR requirements.

Using your existing data, whatever its form and format, we can help build dossiers and documents to support compliance with the PPWR requirements.

Longer-term, if required, we can leave you with a fully implemented and compliant packaging data management system that simplifies ongoing reporting and compliance under the PPWR regime.

We offer services including packaging audits, preparation of Declarations of Conformity, technical documentation support and guidance on recyclability, recycled content, labelling, packaging minimisation, and substance compliance.