The decisions have long since been made. The effects will only be felt in the coming months and years. And they will be very far-reaching.
When the European Commission launched the PPWR - the Packaging and Packaging Waste Regulation - in November 2022, it did so against the backdrop of the European climate targets, which were already massively shaky. The Commission quite rightly recognised packaging as a strong lever in the drive for a green economy. And it decided to tighten the reins drastically and increase the pressure.
As the British social scientist Gregory Bateson once said: "The problem with the future is not the future, but the present." Pacoon Managing Director Volker Muche puts it a little more concretely: "The pressure from the PPWR will extremely challenge old routines in dealing with packaging, otherwise the "change" from a linear economy to a circular economy will hardly succeed."
The goal: promoting ecological behaviour
The main aim of the PPWR is to oblige packaging manufacturers to act in a more environmentally responsible manner than before. An expression of the fact that the marathon towards a genuine circular economy is now set to take a major step forward.
Time Table: What happens now
The development of a common European regulation has not gone entirely smoothly, at least until now. Most recently, the EU Commission, Council and Parliament attempted to harmonise their somewhat divergent ideas in the so-called "trialogue". As a compromise has apparently been reached here, the roadmap should hold.
The final PPWR regulation should be published before the European Parliament elections in June 2024. The actual implementation in the member states will therefore begin in 2025. As soon as this legal act is finalised, the EU Packaging Regulation will replace the respective national law.
Once this has happened at the latest, the work for companies will begin: They have at least 18 months to implement the changes and thus bring the objectives of the PPWR to life.
At Pacoon, preparations for the PPWR have long since begun: "We are already working with customers on specific solution concepts and are deeply immersed in various targets, even if various aspects are still vaguely formulated. According to our estimates, however, far too many producers are still in "observation mode" or are not even aware of what the PPWR means for them," says Muche.
Incidentally, the EU packaging regulation will not only apply to companies within the EU, but also to all others that import packaging or packaged goods into a member state.
What specific regulations will we face?
The PPWR is not content with tweaking minor details. If it comes into force in the expected form, it will lead to fundamental changes in the interests of the environment. A selection of the most important measures:
Avoid packaging waste
The PPWR includes specific targets for reducing and avoiding packaging waste. The focus is on unnecessary empty space, for example, which also means that the use of packaging that is deliberately too large to suggest a lot of content is prohibited. Manufacturers, retailers and importers will therefore be obliged to demonstrably minimise the use of packaging material.
"The EU's Green Deal, which is the driving force behind many other legislative changes in the context of sustainability, also has an economic target component, namely to promote technological developments in the EU that contribute to sustainability. I see this positively confirmed by the many innovative and AI-supported technologies that are making a circular economy a reality," says Muche.
Recycling packaging material and making it easier
Minimum standards are being introduced for the recyclability of packaging. Companies can fulfil this by changing the material used in their packaging solution, for example.
Increase the proportion of recycled material
The use of recycled materials is to increase significantly, particularly in the case of plastic packaging. The specific target values depend on the type of packaging, the type of use and the material used. Packaging that is compostable or contains less than five per cent plastic is exempt from this obligation.
Volker Muche sees a very clear objective of these efforts: "Using recycled plastic to replace virgin plastic, i.e. fossil-based raw materials, is the consistent goal of an optimised circular economy. The number of parameters that need to be determined, controlled, adjusted and transferred here is enormous and can only be realised with AI."
Labelling packaging
In future, the labelling of packaging must include information on recyclability, as well as instructions for correct disposal. This is a regulation that has already been implemented to some extent at national level in some European countries. The additional labelling requirements for packaging are particularly complex and require good preparation on the part of manufacturers.
Submitting declarations of conformity
One content of the PPWR that could lead to particular organisational effort: Companies will be obliged to submit comprehensive declarations of conformity. This confirms fulfilment of the obligations under the PPWR.
Appoint authorised representatives
Companies that are based outside the European Union but sell packaging or packaged products in a member state must appoint an authorised representative. They act as the company's representative in relation to the PPWR obligations. This includes, among other things, providing the declaration of conformity.
Obligation to participate in financing
An important aspect of the Packaging Ordinance is extended producer responsibility. The EPR (Extended Producer Responsibility) providesfor a financial contribution from the producers and distributors of packaging placed on the market. The money will cover the costs of collection, sorting and recycling. At the same time, the EPR is an incentive to produce or use a more environmentally friendly range of packaging.
Maintaining an overview of the basic obligations
These are far-reaching changes. And they will happen gradually and at a pace that is not always predictable. Maintaining an overview here is as difficult as it is necessary - because companies must set the course now at the latest in order to be compliant when the PPWR comes into force. There is no plan B for them here.
In addition to the PPWR, the world of packaging is also constantly experiencing other regulatory changes. Pacoon supports you with two special services to keep you up to date at all times.
Permanent screening: regulation monitoring
In 2022 alone, the European Union implemented 1,473 decisions, regulations and directives that directly or indirectly affect packaging and the environment. Pacoon's Regulation Monitoring Service keeps you up to date at all times on what legal changes are taking place at European and national level. And what obligations and rights are associated with them.
The screening is tailored to the specific effects on your product portfolio of packaging materials - the service not only informs you about upcoming changes to legislation in individual countries, but also provides customised recommendations for your packaging strategy.
The comprehensive overview: Regilabels
Regilabels from Pacoon is a comprehensive summary of labelling requirements and other packaging regulations in 30 European countries and the USA. Together with our partner Certify and other experts, we have created a pdf document that contains all the relevant information on the registration of packaging and labelling in Europe and the USA. The document is available in German and English and is updated every six to eight months.
