You have to remember how long the new Packaging Ordinance has been an issue. The EU Commission presented the proposal for the PPWR, which is to replace the corresponding directive, back in 2022 - so there were two years of intensive discussions and negotiations before it was adopted. This makes it all the more astonishing how intensively it is being shaken up. "The PPWR is constantly being called into question by the various sectors," states Pacoon Managing Director Peter Désilets. "Most recently, the regulation was reopened in order to renegotiate individual points. Other times, deadlines are to be postponed or requirements adjusted. However, this would reward all the obstructionists and sit-outs. And should the PPWR actually be opened: When would it actually be closed again with the changing majorities in the EU Parliament?"
So let's start with the worst-case scenario.
Worst case: The PPWR is partially or completely renegotiated
Sounds unrealistic, was also recently rejected by the EU Commission, but is repeatedly brought into play: If the Packaging Ordinance is actually unravelled again and thus possibly postponed for years, this would have extremely unpleasant consequences on several levels.
Consequence #1: The level playing field recedes into the distance
Per se, all sectors have clearly committed to the PPWR in 2023 - brand owners, retailers and packaging manufacturers. In addition to the overarching goal of reducing the environmental impact of packaging, the PPWR also pursues fair, standardised conditions for European and non-European industry and trade. The regulation also affects everyone who places packaging or transport packaging from outside the EU on the market in a member state. If the regulations are dropped, things will continue as before: Asian importers will continue to sell their packaging at significantly lower prices without being bound by stricter requirements such as recyclability or the use or minimisation of recyclates or reusable containers. Those who cannot keep up with these prices will continue to have poor chances on the market.
The competitive disadvantage of European companies would therefore be further exacerbated without the PPWR. While EU manufacturers invest in sustainable packaging and bear higher production costs, non-European suppliers can compete with cheaper, more environmentally harmful packaging. This leads to a paradoxical punishment of the responsible: companies that already focus on sustainability are disadvantaged by higher costs, while environmentally harmful behaviour is rewarded. A lack of overarching eco-modulation through disposal fees leaves the door open for poor circular packaging. Plastic packaging would be particularly hard hit because a large proportion of it is already imported from non-EU countries, either as packaged products or as packaging itself.
There are also hidden follow-up costs that are ultimately borne by the general public: The disposal of imported cheap packaging, the environmental damage caused by microplastics and the health effects are reflected in public budgets. Without uniform standards, Europe indirectly subsidises environmentally harmful practices in third countries.
Consequence #2: Each country keeps its own packaging law
To a certain extent, the PPWR should lead to legal levelling in the member states. With one important restriction: national legislators are free to tighten the regulation's rules on their own initiative. France is currently regarded as a progressive leader in environmentally friendly packaging. French laws are already on a par with the PPWR requirements and in some cases exceed them. "But what happens if the PPWR does not come into force?" asks Peter Désilets. "Will France then define the new minimum standard for packaging? Or will companies then treat themselves to two packaging lines - one for France and one for the other countries? Hardly, we are already seeing this in the UK, where companies are adapting to the EU market. And we are already seeing laws around the world that follow the PPWR to a certain extent."
However, the problem would go beyond France: If all countries were to actually define their own requirements, this would ultimately mean that companies would have to adapt their packaging to each individual country within and outside the EU. An absolute worst-case scenario for the free movement of goods.
Fragmentation would have far-reaching economic consequences. SMEs would suffer disproportionately, as they often cannot afford expensive legal advice for each market and - as we are already seeing today - unknowingly fail to comply with national laws. Large corporations, on the other hand, have the resources to set up compliance departments for each country - a clear competitive advantage due to regulatory chaos.
The single market would effectively disintegrate into 27 individual markets. Transaction costs would rise sharply as a result of different labelling, material requirements and recycling specifications. Logistics chains would have to be split up, stocks would have to be held separately for each market and goods would have to be reported differently. This fundamentally contradicts the European idea of economic integration.
Consequence #3: Companies lose investments and planning security
Preparing for the PPWR demands a lot from companies. Many companies have already invested money and manpower in sustainable packaging solutions or are planning to do so. But at least they now know what they can prepare for, even if many are still waiting for everything to be finalised. Although most of the requirements are already in place. In many cases, it is not WHAT is to be achieved that has not yet been defined, but HOW - calculation, methods, documentation, record keeping.
Postponing or significantly changing the regulation could lead to strategic paralysis: Companies postpone necessary decisions because it is unclear whether investments will pay off. We are already seeing this today when companies are still considering what the regulation means for them after almost a year since the PPWR came into force. "Although we have been able to easily identify this with our PPWR Check(c) web tool since April 2024, companies spend months trying to understand the law. This wastes manpower that they urgently need to find a solution," says Peter Désilets. This in turn blocks the green transformation of the entire packaging industry. Innovative start-ups in the field of sustainable packaging are losing funding because investors shy away from the regulatory risk. And the first mover disadvantageis cemented. Consultants are demanding more activity and are stuck in a "holding pattern" - although there are already too few packaging experts who are familiar with the subject. This bottleneck will become even bigger over time if companies want to get into the doing.
Consequence #4: The EU is (further) losing credibility
The extent to which the European Union and the idea behind it are under attack becomes clear in pre-election times at the latest. The EU is the perfect target for populists to vent their discontent. The EU packaging regulation is hardly an issue for the general public; many have never heard of it. However, its failure would receive intensive media coverage. And it would be grist to the mill of those who have always known that "they in Brussels" can't get anything done.
Failure would therefore massively reinforce the narrative of the "EU unable to act". Particularly problematic: the EU would deny its own green deal ambitions. How credible are climate targets if even concrete, elaborated measures are not implemented? This would considerably weaken the EU's position, not least in international climate negotiations, but some parties only see climate targets as a problem anyway, not an advantage. Other countries are already much further ahead and are currently extending their lead.
Ultimately, it would be a democratic problem: the European legislative process is complex, but legitimate. Years of negotiations between Parliament, Council and Commission would be cancelled out by last-minute interventions by individual players. And could fuel doubts about the democratic functioning of the EU institutions.
Consequence #5: The idea of a circular economy suffers a setback
The PPWR will not save the world on its own, but it is already playing a pioneering role. The requirements for food contact material are comparable. All major countries and every continent have already defined their requirements for FCM and health impacts. However, given the contribution of packaging waste to CO2 emissions, the PPWR is a significant step towards environmental and climate protection. While a reduction in CO2 emissions is not part of the PPWR, it will inevitably be achieved with the targets of more reusable, adapted packaging, higher recycling rates and use of recyclates (or equivalents such as bio-based raw materials where appropriate).
Any delay means that large amounts of packaging waste will continue to be produced that could be avoided. The EU has set itself ambitious climate targets, but without timely implementation of the PPWR it will be much more difficult to achieve them. And the targets have already been softened up to the final version through successful lobbying - and the lobbying is continuing towards softening. Consequence #1 should be read again to see whether this serves the packaging industry.
However, a changed packaging landscape also has an indirect effect: consumers who come into contact with sustainable packaging in their everyday lives are constantly reminded of the importance of a genuine circular economy. This is also to be achieved through standardised labels and communication, not only in the PPWR, but also in the EmpCo from September 2026 (Empowering Consumers to the Green Transition), which focuses on green claims. As a result of EmpCo, there will be fewer sustainability claims on packaging, but more verifiable and relevant ones.
The signalling effect of a failure would be devastating. If the EU fails on a comparatively consensual topic such as packaging, what chance do more ambitious circular economy initiatives have? Other sectors - textiles, electronics, construction - are keeping a close eye on whether the EU fulfils its promises. Apart from that, all sectors and products are already being asked to manage and document their components in the form of digital product passports in the coming years.
Peter Désilets: "In other industries, we see what happens when climate targets are called into question or ignored: in the solar energy sector, in e-mobility, in the construction and energy sector. Domestic industry is left behind or becomes dependent on other countries for decades to come, consumers pay the price in the medium and long term, health is impaired with corresponding consequential costs for society and the national budget, and nature is destroyed. The question is not: Can the planet still be saved? The question is: Can humans still live on this planet in the future?"
Best case: The Packaging Ordinance comes into force across the EU on time and unchanged
So far, so unpleasant. In view of the fact that this scenario may well become reality, it is worth pointing out what the PPWR could trigger in the best-case scenario.
Consequence #1: The PPWR leads to a surge in innovation in packaging materials
Alternative materials are often considered too expensive or too risky. Regulatory pressure is changing this. As soon as it is clear that certain plastic packaging will be banned or severely restricted, companies can expect a guaranteed demand for alternatives. At the same time, R&D departments have the justification to allocate budgets to disruptive solutions. We are already seeing new solutions finding their way onto the market. And packaging manufacturers are endeavouring to offer PPWR-compliant packaging.
At the same time, a new competitive dynamic is emerging: when it becomes harder to undercut the competition with cheap plastic, genuine innovation becomes a worthwhile differentiator. Market share will be won by those who bring the most functional, cost-efficient and sustainable packaging solutions to the market. And if companies are already looking around for these solutions, they may also open their eyes to new approaches off the beaten track.
Consequence #2: The market for recycled materials will be harmonised
The fragmented market comes at a high price. Companies currently have to produce different packaging variants, undergo separate conformity tests and apply different labelling for recyclability. Frictional losses that a harmonised standard would put an end to.
Even more important, however, would be the impact of the new regulations on the secondary raw materials market: as soon as standardised quality and verification criteria for recyclates are in place, a genuine internal market for secondary materials will gradually emerge. This will result in stable prices throughout Europe. And the development of a potent pool of secondary raw materials. The costs for packaging will tend to rise because the requirements and fees will become higher and more standardised, also due to eco-modulation. Countries will have to find new fee models, the demand for recyclates will increase, fossil-based virgin materials will decrease and probably also become more expensive in the course of new modulation models.
The standards for design-for-recycling in turn lead to the harmonisation of input materials. This will enable sorting and processing plants to process international material flows in future. Investments in high-performance systems will therefore amortise much faster. It can be assumed that newer sorting technologies will also be used in the EU member states that do not yet have an infrastructure, which can separate materials even more finely and therefore produce better recyclate. However, the "death of recyclers" is a major cause for concern in the industry if the recyclate gap threatens to widen even further from 2030.
Consequence #3: First movers boost their brand image through packaging
How many consumers are truly environmentally conscious (and, above all, willing to pay more for it) is debatable. What is undisputed, however, is that there are more of them. Companies that react early to the requirements of the PPWR position themselves as sustainability leaders in this group. And this also applies to the virtual world. Innovative, sustainable packaging is also being shared and discussed on social media. Until 2030, the efforts can still be honoured, which will then become the standard.
At the same time, sustainably packaged goods are also a criterion for listing: large retail chains must increasingly achieve their own sustainability targets and also declare the conformity of the packaging they sell. At the same time, the new packaging can improve their own carbon footprints and thus also reduce costs. Ideally, this is reflected in the annual and sustainability reports and favours loans and investments.
Consequence #4: The regulation creates planning security
Regulatory uncertainty is one of the worst obstacles to innovation. The PPWR's precise transition periods ensure that companies can plan their investments with comparatively little risk. And they can be confident that their solutions are also compliant.
Some categories, such as transport packaging, have high requirements for returnable packaging. This must be considered in the context of hygiene requirements. Today, cleaning standards in transport logistics are already a fig leaf; recalls in the food sector are usually the result of poor hygiene in the transport containers, not the production facilities. Peter Désilets has been drawing attention to this neglected topic since 2024: "The PPWR will ensure that new cleaning standards, traceability, harmonised packaging containers and special ethnic requirements such as halal or kosher are implemented. To this end, we have set up a 360 Reuse working group within the ENFIT Supply Chain Safety Organisation. This is intended to help companies along the supply chain to define harmonised packaging and processes to achieve product safety."
The resulting greater planning security also facilitates investment and makes the ROI in terms of costs and CO2 emissions more calculable. The clear roadmap of the Packaging and Packaging Waste Regulation makes it easier for banks and investors to assess the conformity of a business model. And ultimately, a standard that comes into force on time also prevents EU member states from introducing their own regulations. The single market says thank you!
Consequence #5: Design-for-recycling standards improve production, logistics and recycling rates
Standardised design principles for packaging have far-reaching consequences. If all manufacturers work according to the same principles, an ecosystem of compatible components is created. Packaging manufacturers can fall back on standardised semi-finished products instead of developing customised products.
This has an impact on production, logistics and recycling: machines and systems are confronted with a narrower range of specifications, which shortens set-up times and improves capacity utilisation. The supply chain benefits from optimised palletisation and loading, and stock levels can be reduced. Standardisation also makes itself felt in recycling: If the input material is predictable, the systems can achieve higher throughputs with better quality. Overall, the proportion of recycled material increases and costs fall.
Consequence #6: The packaging flows are digitalised
The PPWR is driving the digital transformation of the packaging industry. Each packaging is given a digital identity with complete information on material composition, origin, recycling instructions and end-of-life options. This means that sorters and recyclers know better what they are processing, consumers can see how to dispose of it correctly and the authorities can monitor compliance.
However, digitalisation has even more advantages. Sorting can be optimised with the help of new technologies such as artificial intelligence, individual pack codes or other sorting information. Deposit systems and closed loops are optimised through precise tracking, individual deposit heights are technically possible with each refill and can be quickly adapted to the circumstances without affecting the hundreds of millions of provisions, as is the case in today's pooling systems. Companies benefit from automated data collection when it comes to reporting. And last but not least, the data from the Digital Product Passport provides market information on European material flows in real time.
"Which scenario ultimately prevails will depend heavily on politics and lobbying," says Pacoon Managing Director Peter Désilets. "The opportunities for the industry have grown with the PPWR if solutions are actively worked on. Short-term success through prevention can increase the damage in the long term. It's like treating the symptoms instead of the cause, which leads to higher costs. As the entire industry is behind the PPWR, I can only recommend that companies prepare for the targets now. After all, those who approach these tasks well prepared will be freer in their decision-making than if a last-minute decision dictates the investments and subsequent costs."