The new EU packaging regulation PPWR came into force in February 2025 and has clear objectives. Everyone can probably rally behind its provisions: With the packaging regulation, the European Commission wants to reduce packaging waste, significantly increase recycling and harmonise European law to a certain extent - the objectives of the PPWR are aimed at significantly minimising environmental impact.
So far, so pleasing. However, for all companies that place packaging on the market, produce, import or distribute packaging within the EU, the new regulation will bring massive changes, some of which will have a profound impact on established operational processes. The PPWR introduces new requirements for design, material use, recyclability, recycled content and reusability. Labelling requirements are also being tightened.
These are the nine most important measures that you need to implement now at the latest in order to be prepared for the coming years from 2026, when the PPWR comes into force:
1. get to grips with the new requirements of the PPWR and their deadlines!
The Packaging and Packaging Waste Regulation fills more than 130 printed pages with the finest legalese. In view of the big deal that the PPWR is supposed to be, this is absolutely appropriate - but of course it's not much fun to read, as the regulation refers to many other regulations outside the PPWR.
But it doesn't help: it is crucial for companies to be able to assess in which areas and to what extent they will be affected. It is also particularly important to be aware of the transitional periods. For example, companies must be able to submit a declaration of compliance for all packaging from 12 August 2026, but longer deadlines apply to other areas - such as the requirements for the recyclability of packaging or the minimum recyclate content in plastic packaging.
Peter Désilets, Managing Director of Pacoon, is experiencing the increasing pressure on companies first-hand. "As we have been dealing with the details of the PPWR since the beginning of 2024 using customer portfolio analyses as an example, we can offer a unique guide and advise companies with our PPWR Check© web tool. The number of requests for consulting support is also increasing, after many companies initially tried to analyse the PPWR themselves."
2 analyse your packaging portfolio!
The first operational step must be a thorough inventory: What packaging are you currently using or placing on the market? Systematically record all primary, secondary and tertiary packaging, including the materials, layer structures, masses and quantities used.
You should only be satisfied when you have achieved real transparency across your entire portfolio, and it is best to create a matrix at the same time that allocates the packaging types to the respective product lines. Don't forget packaging that comes from suppliers or that contract fillers bring to the market for you, and packaging that is exported. The more accurate this step is, the better you can work towards PPWR compliance.
Peter Désilets recommends that all companies also talk to their suppliers: "Because if transport packaging has to be handled in reusable packaging on a large scale, the recipients are obliged to collect, clean and digitally track this packaging. And as the number of variants increases, so does the complexity."
To reduce this complexity, Pacoon has also set up the 360 ReUse working group within the ENFIT Supply Chain Safety Organisation, where companies agree on compatible processes. Interested parties are welcome to contact Pacoon.
3. check and document recyclability!
Especially around the topic of recyclability there aremany misunderstandings. This is probably also due to the fact that the term "recyclable" has been used (and printed on packaging) quite arbitrarily up to now.
However, the European Packaging Ordinance defines recyclability very precisely: according to the new requirements, packaging must be designed in such a way that it can be recycled to such a high quality that the secondary raw materials produced from it are suitable as a substitute for primary raw materials. At the same time, however, it must be able to be collected, sorted and recycled after use in such a way that the recyclability of other waste streams is not impaired - in fact, not just in theory.
From 2030, almost all packaging must be at least 70 per cent recyclable. If they do not achieve this, they may no longer be placed on the European market. From 2038, packaging will even have to reach 80 per cent. The design-for-recycling guidelines for some product groups will also be published by January 2028 at the latest, and these will also be binding.
"Many companies have already checked their recyclability in recent years," says Peter Désilets. "We still have to wait and see which standards will be relevant for the calculation. Thanks to our many years of experience, we can recognise a trend even with an initial basic assessment. We also know many alternatives and can provide support if alternative PPWR-compliant packaging needs to be tested."
4. get your partners on board for the new packaging regulation!
The PPWR is not an arena for lone wolves. It requires close cooperation and communication between companies and suppliers (e.g. of transport packaging), packaging manufacturers and service providers. Ask for technical documentation and data sheets, recycling certificates or proof of recyclate content. Also contractually clarify who is responsible for compliance within the supply chain and how changes are documented.
The work within the company will also be spread across many shoulders. In addition to the PPWR, the EPR fees, registrations in the countries, national packaging laws and other EU laws such as the SUPD or EUDR must also be taken into account in a holistic approach.
"We repeatedly experience that the working group in companies extends across the entire spectrum, right up to IT," explains the Pacoon Managing Director, "because the data should be managed digitally in the best possible way, which is why we create the data from our PPWR Check© web tool from the outset with the internal ERP systems in an interface-capable manner. This allows companies to remain flexible in how they manage and process the data later on."
5. use Design for Recycling for packaging in the EU!
Packaging design that has the entire life cycle in mind: With the PPWR, Design for Recycling comes massively into focus. In addition to the materials themselves, this also involves numerous other aspects such as additives, adhesives, closures, printing inks, barriers and much more - each component must prove conformity on its own, and each component can also affect the recyclability of the packaging and thus the circular economy during the sorting and recycling process.
Design for recycling combines functionality, sustainability and law and is therefore fundamentally an interdisciplinary approach. And a matter for professionals. Peter Désilets: "As leading experts in sustainable packaging, we have been dealing with all topics relating to D4R for the most important materials for 18 years. This also enables us to point out critical aspects and components and avoid surprises."
6. observe the requirements for recyclate content in your plastic packaging!
The PPWR stipulates minimum proportions of recycled plastic in certain types of packaging. Companies should therefore urgently review where the use of recyclates is technically and aesthetically possible and develop appropriate strategies to gradually integrate recycled materials into their packaging. Quality assurance, material availability and price development are the key factors here.
And this is where things are likely to get exciting: From 2030 at the latest, when most PET packaging will have a recycled content of at least 30%, massive bottlenecks and price increases are to be expected. It remains to be seen where the required quantities will come from. Companies would do well to conclude long-term recyclate supply contracts as quickly as possible. Of course, it is even better to invest in closed-loop systems or their own recycling partnerships.
However, the requirements for recycled content will also increase for other polymers. Solutions as to how recyclates for food packaging beyond PET can be met are currently being discussed. These could be chemical recyclates, which are currently being discussed with an x-fold cost aspect, or enzymatic or solvent-based recycling technologies. The industry never sleeps and the technologies continue to develop. For example, bio-based raw materials are still being discussed to replace recyclates or a mass balance procedure for recycling trade, which is currently endeavouring to be recognised.
So be prepared to fulfil the recyclate requirements and do not rely on exemptions due to technical restrictions.
And one more aspect will become important: certification. In view of the fact that most packaging in the EU is imported from Asia, ways must first be defined to reliably certify the recyclates. However, the first material flows are already forming in China and are vying for recognition. The industry is therefore on the move.
7. familiarise yourself with the labelling!
The EU Packaging Regulation not only addresses environmental protection and the circular economy. It is also about providing consumers with correct information. The times when labels such as "sustainable" or "recyclable" were distributed very freely are now coming to an end: With the PPWR comes harmonised specifications for labelling what packaging is made of and how to dispose of it correctly. EmpCo (Empowering Consumers for the Green Transistion) will also come into force from September 2026. Greenwashing will be significantly restricted here because many blanket statements will be prohibited. In addition, environmental claims (green claims) require verifiable evidence and usually certificates from independent third parties.
"With our sister company Pacoon for packaging design, we know the processes for adapting artwork," says Peter Désilets. "The months-long lead time required to have compliant packaging on the market by September 2026 means that we have to start checking and correcting the print documents as quickly as possible. We are happy to screen the packaging and recommend the necessary steps - or implement them directly with our design colleagues."
From 2028, all packaging in the EU member states must carry information on compostability, recyclate content and disposal - often supplemented by QR codes. You should therefore check which labelling obligations apply to your products. Stock levels and print templates must also be adapted in good time.
8. expand your data management for the regulation accordingly!
The PPWR places extensive documentation obligations on you. In addition to the information for the declaration of conformity, the digital product passport will also require a lot of information about materials or recyclability. Details are still to be developed. The declarations of conformity - the written self-declarations by manufacturers that their packaging fulfils the PPWR requirements - will be due as early as August 2026.
"We have developed our own format for the declaration of conformity that contains the required data," says Peter Désilets. "We are building a platform to link the necessary data and reports in order to manage the data. Customers who already analyse their portfolio using the PPWR Check© web tool will soon be able to automatically derive the basic data directly from the data and pre-fill the compliance report." In future, this data will also be linked to the companies' ERP systems.
A robust data management system must therefore also be in place in the background. You should therefore check whether your current ERP or PLM systems are suitable for this or need to be expanded. These cannot perform automatic checks today, but they do contain some relevant data that the PPWR Check© web tool also requires. The results of the checks should later be made available to the ERP systems.
Automated recording and reporting functions facilitate compliance and reduce manual effort. Also remember to ensure processes for regular audits and external reviews.
9. put together a task force and create a business case
The implementation of the PPWR is not a one-off project, but a long-term transformation process. It is therefore important to sensitise everyone in the company - especially in the areas of purchasing, development, production and marketing - and to bring them up to speed with internal workshops and training courses.
It is also crucial to clearly define which people in which teams are responsible for PPWR compliance. In addition, create a company-wide roadmap with clear goals, responsibilities and budgets - and communicate this roadmap to internal stakeholders, customers and external partners.
For most people, 2030 still feels a long way off. The fact that compliance has to be declared as early as 2026 therefore comes as a surprise to many. Peter Désilets: "This emphasises the urgency with which the topic of PPWR should be addressed. There will still be a number of obstacles on the road to compliance, and the number of experienced consultants is manageable. Well over a million companies worldwide will have to adapt to the regulation. The last-minute solution will not be the best or cheapest, and those who adapt in time are also most likely to benefit from Eco Fee Modulation and lower CO2 values."