It's not about the industry or the size of the company: manufacturers, importers, online retailers, stationary retailers, fulfilment service providers and packaging suppliers - they are all directly affected by the PPWR, the EU's Packaging and Packaging Waste Regulation. Anyone who receives, places, produces, imports or distributes packaging within the EU must prepare for this.
Companies and brands now have a duty to make progress towards recycling, reuse and material savings as part of the new EU packaging regulation. The many myths circulating about the PPWR are proving to be of little help. It's high time to set the record straight.
Myth 1: "We still have plenty of time"
Postponing unpleasant tasks is already not a good idea in private life, but in business it can quickly become dangerous. The PPWR is not a project for the distant future: the European Commission published the draft in autumn 2022 and the regulation came into force on 11 February 2025. Although there are indeed individual deadlines that point a few years into the future, the first provisions will come into force in August 2026. A transition period of 18 months sounds generous at first. However, many companies will have to review and, if necessary, revise their packaging designs, start adapting their supply chains and ERP systems and, last but not least, train their employees during this eighteen-month period. There are also certification processes, tests and conversions in production. Anyone who hesitates now is therefore under enormous time pressure and risks not being able to meet the deadlines or having to resort to "stopgap solutions" instead of optimising processes.
Myth 2: "A lot is still unclear about the specifications"
A common misconception: the Packaging Ordinance actually defines very precisely which targets are to be achieved by when. "The 'what' is completely clear," says Pacoon Managing Director Peter Désilets, "only the 'how' is still being clarified in many cases. We can already say very precisely which goals are to be achieved. In a few cases - such as transport packaging - quotas are still being discussed. However, most questions revolve around how the requirements must be met." And the fact that parts of the regulation are being legally contested does not change the fact that it is legally in force in its entirety. Companies that postpone their preparations due to potential changes are therefore taking a high risk.
Myth 3: "The PPWR mainly affects plastic packaging, but paper and cardboard are hardly affected"
This misconception is also widespread. However, the PPWR is completely material-independent and applies to all packaging solutions that are placed on the market in the EU, including those that are considered positive in terms of the circular economy. Materials such as paper, cardboard, wood, glass or metal are explicitly mentioned and treated separately. There are specific requirements for each type of material, ranging from recyclability and recyclate content to basic minimisation. Although corrugated cardboard packaging is exempt from the reuse quotas in certain areas, this does not change the fact that it must also meet the requirements for recyclability and packaging minimisation. These requirements have yet to be defined. Sustainable packaging made from fibre materials must also not create unnecessary empty spaces and may also be coated with PFAS or other problematic substances, which will be limited for food packaging from 2026. "In addition, other solutions such as reusable crates can also have an impact on the use of cardboard packaging if the reuse solutions are cost-saving after a few loops," emphasises Peter Désilets, "and corresponding solutions are already on the market and are beginning to establish themselves."
Myth 4: "Transport security is exempt from the changes"
From 2030, the PPWR will stipulate strict reusability quotas. In the intralogistics sector, this is up to 100%. It is important to know that the regulation does not take into account the mass proportions of the transport unit, but considers each of its components individually. This means that transport securing elements such as stretch film or strapping are also affected. In fact, there is a draft from the EU Commission that could exempt these elements from the 100% reusable quota. "That's why we keep hearing that transport security packaging such as stretch film, strapping or paper-based solutions are exempt from the reusable packaging requirements," explains Peter Désilets. "However, the draft only addresses the 100% quota. However, the 40% requirement could still represent a not insignificant hurdle, considering that around 200 million disposable pallets are still in circulation every year. We are curious to see whether the draft will be amended to increase the pressure on single-use plastics."
Myth 5: "Recyclability = sustainability"
The terms "recyclable" or "recyclable" were not clearly defined for a long time, and many companies printed them on their packaging as a marketing measure. The Packaging Ordinance tightens the screws when it comes to recycling: According to it, only packaging that can be recycled in economically viable quantities is considered recyclable. In addition, appropriate recycling infrastructures for collection, sorting and utilisation must actually exist. Specific design-for-recycling criteria will come into force in 2028, and from 2030 all packaging will have to fulfil these criteria and provide proof of compliance. This can essentially have an impact on composite materials, black plastics or dark colours, disruptive labels or adhesives. How recyclability is to be measured is still being defined. In the eyes of Peter Désilets, the German minimum standard would be desirable on the part of the central body: "It remains to be seen whether the other EU countries, which still have a lot of catching up to do, will support this. In other words, a lot of packaging that is currently considered ecological and 'recyclable' could be banned from 2030. Others that are not significantly better than the standard that will then apply will no longer be allowed to communicate this."
Myth 6: "The Packaging Ordinance creates harmonised EU law"
The PPWR does indeed aim to harmonise national packaging regulations and strengthen the European Union's internal market. However, the member states retain the right to go beyond these requirements, provided they do not hinder the free movement of goods. This means that in future there could well be national bans on certain packaging formats or stricter incentive systems. In future, it will therefore be crucial for companies to keep an eye on possible special national regulations in addition to the new regulation. "This is precisely why our eight-step roadmap to PPWR compliance also includes the step 'Comparison with other national and EU laws in the sales markets', which we have been carrying out for customers for years," says the Pacoon Managing Director.
Myth 7: "Environmentally friendly packaging? As an SME, we couldn't care less"
Small companies are sometimes under the misconception that they fall under the radar of the PPWR. However, it applies in principle to any company above a certain number of employees, annual turnover or packaging volume placed on an EU market - including small e-commerce retailers, local producers or importers. They are all subject to extended producer responsibility (EPR) and are therefore obliged to register and bear disposal costs in every EU country to which they export or in which they market products. For small companies, the costs incurred can even be proportionally much higher than for large corporations.
Myth 8: "We'll just buy recyclate certificates"
It sounds like the easiest way to fulfil the recyclate quotas: leave the packaging design as it is and buy certificates or recyclate instead. However, this calculation is extremely risky. The market for high-quality recyclate is already tight today. If many companies need 30% recyclate at the same time from 2030, there will almost certainly be massive bottlenecks and price increases. The prices for food-grade PET recyclate have already doubled since many manufacturers have wanted to show off their use of recyclate and have switched to PET packaging. Those who only rely on buying in are making themselves dependent on volatile markets and risk supply shortfalls. Companies should therefore aim for long-term recyclate supply contracts today or - even better - invest in closed-loop systems or their own recycling partnerships. Alternative packaging materials or packaging redesigns can ensure that the need for recyclate is reduced. It remains to be seen which sources will be available for recyclate quotas in the future. The recyclate trade is only one option. However, it can be assumed that recyclates will become more expensive per se due to the specifications. Special attention must also be paid to recyclate certificates. This is because a large proportion of packaging already comes from Asia. Ways of reliably certifying recyclates need to be defined here.
Myth 9: "The packaging regulations only apply to manufacturers within the EU"
In principle, the obligations of the PPWR apply to anyone who places packaged goods on the EU market. Importers therefore have the same obligations as manufacturers based in a member state. They are responsible for ensuring that the imported packaging fulfils the PPWR requirements and must be able to prove this through technical documentation and conformity assessment.
Myth 10: "Once compliant, always compliant"
Manufacturers must submit an initial written self-declaration by August 2026 for all packaging that is currently in circulation, stating that it fulfils the requirements of the PPWR. The basis for this are certificates for the hazardous substances, but later also documents for minimisation, recyclability, use of recyclates, reusable circulation rates and a few more. Compliance with the first labelling obligations must also be demonstrated by August 2026. A tight schedule that is already putting some companies under pressure. But anyone who thinks this is the end of the story is mistaken: the PPWR requires continuous monitoring of compliance. Every time changes are made to packaging, new products are introduced or materials are adapted, it must be checked again whether the requirements are still being met. It is therefore crucial to establish appropriate processes as soon as possible. And conformity must exist before the sale, it must not be created afterwards.
Myth 11: "Only single-use packaging requires reporting and EPR fees"
Most countries only have EPR fees for single-use packaging, which is used to pay for disposal. Pioneers such as France have also introduced eco-modulation to favour recyclable packaging. However, it is often overlooked that in all countries, reusable packaging or transport packaging, which is usually not subject to EPR fees, must also be reported and registered. Failure to register can lead to your packaging getting stuck at customs, you paying high penalties and having to arrange and prove registration - which takes a few weeks - in order to "free" your packaging and the products it contains. "If your customer has then been waiting for weeks for the ingredients for production and is looking at the competition for alternatives, the above costs are the least of your problems in an emergency," says Peter Désilets.
Myth 12: "My packaging or product supplier prepares the declaration of conformity for me"
Anyone who believes that the declaration of compliance can simply be delegated is seriously mistaken. A contract filler can certainly provide certain information. However, the producer or distributor who places the product on the market is responsible for the declaration. The roles of economic operators can be duplicated here, but it is understandable that only the person who produces the final product has all the information. The packaging suppliers can only confirm their level of knowledge. What print or labels do you still apply, how many different artworks do you create and what is the latest status of the artwork for the individual components, do you combine the packaging into multipacks or what exactly do you pack in them, how many cycles have the reusable packaging completed and how do you calculate the recyclate quotas in your plant? These are questions that your supplier usually doesn't know. And you, as the person responsible for your company, have to sign it.
A challenge beyond 2030
"It's very important to think not just about the material, but about all the requirements for the coming years," summarises Peter Désilets. "That's why we don't see the PPWR as a challenge until 2030, but beyond." Some packaging can be made compliant by changing or optimising materials. However, data handling is an ongoing task. Higher overall costs across the value chain are also to be expected in the coming years. New solutions can be more profitable than simple optimisations.
Peter Désilets: "As leading experts for sustainable packaging solutions in Europe, we have been developing innovative packaging solutions that are future-proof and compliant for years. In addition, we already offer digital solutions that will become even more networked in the coming months. Our PPWR Check© web tool is an initial aid to self-help, our advice helps with the development of compliant solutions, the digitalisation of our data is already fit for the future and simplifies reporting for companies. We will soon be announcing further major collaborations that will accelerate the transformation of companies towards sustainability."