It only actually becomes concrete in Annex II. From 2030, the Packaging and Packaging Waste Regulation PPWR stipulates that at least 70 per cent of fibre-based packaging and transport packaging in the EU must be recyclable. From 2038, 80 per cent will apply. Are these targets feasible?
This is a question that we want to discuss on the SOLPACK 6.0 panel (23-25 September 2025 at FACHPACK Nuremberg): How can we deal with the PPWR's requirements for the recyclability of fibre packaging in the future if it then goes into recycling? Here are a few inputs on some of the most important questions at the moment.
Is anyone already working on improving the recyclability of packaging?
To make packaging recyclable and therefore reusable, there are several approaches that span the entire supply chain. Accordingly, initiatives aimed at preparing the industry for this are coming from various sides.
One example is the INGEDE Symposium with its focus on Design for Recycling. Among other things, the symposium discusses new protective layers and barriers that are functional, but at the same time make recycling more difficult or can lead to poorer recycled fibre quality. Fibre-based composite packaging is also a key topic. INGEDE is also active in technical committees and regulatory and standardisation organisations and is working on the definition of industry standards. Projects such as EnEWA, which aim to increase the return flow into the waste paper recycling stream, will also be presented at the symposium.
Among other things, the Forum Rezyklat is focussing on data quality for PPWR-compliant reporting. For example, the forum has developed an innovative new "Packaging Components" data attribute: This is where companies enter the components that make up packaging. These components are selected from a special code list, which the forum will make available on its website from the autumn.
The manufacturers don't have to hide either. Greiner Packaging, among others, is working on new standards together with DIN and Austrian Standards. Together, they are creating criteria for design for recycling and sorting processes, thereby taking a further step towards the Packaging and Packaging Waste Ordinance.
"Basically," says Pacoon Managing Director Peter Désilets, "the PPWR describes relatively clearly what information should be included in the conformity reports. But the crucial question is what form and level of detail these reports will take". Various proposals are currently being developed or have already been submitted in order to give the industry clarity on what market participants can expect. "It is important that the reports ultimately agree on a standard if possible in order to simplify recording and monitoring," Désilets demands.
Are there proposals for charges on fibre packaging?
Yes, of course there are such proposals. The most common approach is the introduction of a graduated fee that rewards higher levels of recyclability with lower fees. Eco fee modulation is a topic of the PPWR in order to achieve a better recycling output. This could be done via absolutely defined fees or via percentage surcharges. There are also other approaches to how such a system could be organised. A linear degression is conceivable, for example, but also a malus system or a bonus-malus combination.
The thrust is clear: to provide a financial incentive so that packaging in the EU achieves higher recyclability. "At the latest since the Packaging Act in Germany, awareness of the varying degrees of sortability and recyclability of materials and the need for a financial incentive system has increased significantly. With the current dual system model, it is of little financial interest to make packaging much more design for recycling. This is already different abroad, for example in France or with the EU fees on non-recyclable plastics. But this is sometimes just a drop in the ocean and not a real incentive," says Désilets.
The authorisation or setting of such fees would have to be carried out in cooperation between the legislator and the dual system. Or be initiated directly by the legislator, as was the case with the Single-Use Plastic Fund Act, where the fees for different product categories were specified.
Can countries go beyond the targets of the new regulation?
The different limits that currently exist in the member states of the Union are not an obstacle. The PPWR requirements relate to the technical recyclability of all packaging - i.e. the proportion that can theoretically be recovered through recycling. Countries such as Germany or Austria, where the bar is higher than the 70 or 80 per cent stipulated in the directive, have made a concrete interpretation of the general European target.
The values set by national authorities are therefore not in contradiction to the PPWR, but are a concrete technical implementation with which each EU member state ensures that the PPWR targets can also be achieved in practice. These states will therefore not have to lower their limit values. On the contrary: national concretisation will become more important throughout the EU as a result of the PPWR.
Does the joint collection of packaging waste harm reuse?
From the perspective of paper manufacturers, mixed fractions are a huge problem. If consumers dispose of plastics, metals and fibres in the same bin, the end result is always lower fibre quality and probably a lower collection rate.
In this case, the paper and cardboard fractions have to be mechanically separated from the other fractions during the sorting process, which partially degrades the fibres and therefore makes them less recyclable. In addition, the mixing results in greater contamination. It can also be assumed that normal fibre packaging with a high fibre content of 80 to 90 percent is not sorted at all because it is unprofitable in terms of quantity and the contamination in the 'yellow bag' stream greatly reduces its attractiveness for paper recyclers.
"To a certain extent, the Dual System's fee structure has also hindered the development of more sustainable fibre packaging. On the one hand, the classification as PPK (paper, cardboard, carton) is based on the paper industry's old specification with the 95-5 rule, i.e. a maximum of five per cent foreign matter in the packaging," says Peter Désilets.
The aim of this rule, which was largely supported by the European Confederation of the Paper Industry (CEPI), was of course that the fibre output in recycling would be higher and better with a lower proportion of foreign matter. However, technology has evolved since then: "We are seeing more and more easily recyclable fibre packaging with ten or 20 percent foreign matter content, which is easy to separate. However, this is not rewarded by the fee schedule. This is also in line with the PPWR's long-term target," says Désilets.
In line with PPWR requirements, the paper industry has now published a Design for Recycling guide on how to recycle fibre packaging with different contaminants and coatings. This is an important step towards increasing understanding of the development of fibre packaging and optimising recyclability.
Is there a connection between laminate films and fibre quality?
Basically, it sounds logical: laminate films that can be easily removed in the recycling process should not impair the fibre quality for reuse. Unfortunately, this is not the case. On the one hand, there are losses: fibres that remain attached to the film are lost for recycling. On the other hand, residual foreign matter can always remain in the fibres, such as adhesives, coatings or inks. Today, the films are not further sorted and recycled separately or reutilised. They end up being incinerated to generate energy. Nevertheless, the myth that if a film is laminated onto fibre packaging, the packaging cannot be recycled in waste paper is false. In case of doubt, this is easier than a water-soluble coating, which can contaminate the fibres, stick together or even form lumps during the drying process, which then re-deposit on the machines.
Nobody will deny that easily removable laminates are better than their predecessors. But even they cannot prevent a loss of quality. Peter Désilets draws attention to the different perspectives: "A foreign material is usually also an interfering material. The question remains as to how well this contaminant can be removed. Using the example of adhesive tape, it is better for a few fibres to stick to the adhesive tape and be disposed of with the tape than for the adhesive to remain on the fibres and possibly stick the fibres together later."
What challenges do paper manufacturers and converters face?
More impurities, lower fibre yield, higher processing costs: paper manufacturers and converters are complaining about increasing problems with fibre packaging streams. There are three main reasons for this.
👉 Multilayer: There is an increasing amount of multilayer packaging on the market, such as paper-plastic composites, lacquer or barrier coatings. This makes separation more difficult, leads to higher proportions of impurities and lower quantities of fibres to be recovered.
👉 Technology: There is a bottleneck in the area of detection and sorting technology. The infrastructure is lagging behind developments, meaning that a lot of packaging ends up in the mixed stream.
👉 Packaging design: Lightweighting papers have fewer fibres per square metre, which reduces the recycling mass. The trend towards heavier printing makes additional deinking steps necessary, which in turn has a negative impact on fibre quality.
Paper manufacturers and INGEDE are therefore calling for several countermeasures:
👉 Packaging must be increasingly based on design for recycling.
Minimise the number of unnecessary composite solutions.
👉 Better sortability through labelling and increased use of AI.
👉 Separate collection of high-quality paper packaging.
"The sorters of lightweight packaging from the Yellow Bag have been complaining for a while that composite packaging on fibre material hinders and contaminates the recycling stream, which reduces the output rate. However, the general question must be whether this fibre packaging - and we always assume good recyclability - would not be much better off in waste paper," says Peter Désilets.
After all, apart from drinks cartons, they are very likely to be lost in the 'yellow bag'. "There should therefore also be a graduated fee for fibre packaging that is based on the actual recyclability, not the proportion of foreign matter. And as part of the PPWR, clear labelling of the corresponding disposal stream should also be implemented in Germany," demands the Managing Director of Pacoon.
Focus on PPWR: We are looking forward to SOLPACK 6.0!
As you can see, there is a lot to discuss when it comes to implementing the PPWR. The directive may not be perfect, but ultimately it harbours a real opportunity to take recycling in the European Union to a much higher level.
We are already looking forward to intensive discussions and exciting presentations and talks about the new EU regulation: at the SOLPACK 6.0!