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PPWR - New EU Legislation on Packaging and Packaging Waste

The upcoming EU Regulation on Packaging and Packaging Waste (PPWR) marks a paradigm shift in the regulation of packaging across the EU. The regulation will be directly applicable in all member states and replaces the previous directive (94/62/EC). The goal is to harmonize rules, promote a circular economy, and reduce the environmental impact of packaging.

What does it mean for flexible packaging?

Flexible packaging will be subject to several new requirements, including:

  • Design for Recycling (D4R): From 2030, all packaging must be designed for recycling and meet recyclability criteria according to established standards. From 2035, packaging must also be recyclable in practice and at scale.
  • Recyclability Performance Grades: Packaging must achieve at least grade C (≥70% recyclability) from 2030 and at least grade B (≥80%) from 2038.
  • Recycled Plastic Content: From 2030, plastic components in packaging must contain a certain amount of recycled material. Requirements vary depending on the type of plastic (e.g., PET in contact with food).
  • Ban on Certain Substances: PFAS in food contact materials will be banned during 2026, and heavy metals must not exceed 100 mg/kg.
  • Labeling and Digital Information: From 2028, packaging must be labeled with harmonized symbols for material type, recyclability, and any recycled content—often via QR codes or other digital technologies.
  • Minimization and Empty Space: From 2030, the weight and volume of packaging must be reduced to the necessary minimum, and empty space in transport and e-commerce packaging must not exceed 50%.

Key deadlines (Expected Timeline):

  • February 11., 2025: Regulation enters into force.
  • 2026: Ban on PFAS in food contact materials.
  • 2028: Labeling and digital information requirements take effect.
  • 2030: Packaging must be designed for recycling and meet recyclability requirements.
  • 2035: Packaging must be recyclable in practice and at scale.
  • 2040: Stricter requirements for recycled content in plastic packaging.

What should companies do now?

Companies that produce or use flexible packaging should already:

  • Review their packaging design and material choices.
  • Map out fractions and quantities.
  • Document compliance with requirements in technical documentation.
  • Prepare for new labeling requirements and digital information systems.
  • Join collective schemes (e.g., VANA) and ensure proper registration with authorities – Danish Producer Responsibility (DPA).