PPWR in Action: New Developments and Strategic Implications for Businesses
In December, we published a guide post on our blog shortly after the European Union adopted the Packaging and Packaging Waste Regulation (PPWR), outlining important information that companies should know. From December to March, significant developments have occurred, and we now have more concrete details about implementation timelines, strategic implications, and best practices for businesses. This article serves as a complement to our first overview, providing deeper insights into how companies can prepare for this regulation.
PPWR: From Adoption to Implementation
When we last discussed the PPWR in December, the focus was primarily on the regulation’s adoption and its broad implications. Now, with the European Parliament’s formal approval in April 2024, we have a clearer picture of the timeline: the regulation is expected to come into force in Q4 2024, with immediate effect upon entering into force.
What makes this particularly significant is that, unlike its predecessor (the Packaging and Packaging Waste Directive), the PPWR is legally binding and requires compliance from all companies and products within its scope without national transposition. This means businesses across all sectors that produce or use packaging must act promptly.
PPWR: The Scale of Change
Our latest clients’ work reveals that the scale of change required is more substantial than many businesses initially anticipated. Experience from client engagements suggests that as much as 80% of current packaging solutions may need to be redesigned to meet the new requirements. The financial implications of failing to comply could be severe, potentially representing between 30% of European sales to total sales bans on the European market.
Key Updates on PPWR Requirements
The PPWR spans 321 pages with 71 articles across 13 chapters, supported by 12 annexes.
To make this more digestible, we’ve grouped its contents into 10 core topic clusters:
- Waste reduction targets
- Recyclability requirements
- Recycled content targets
- Reuse/refill targets
- Compostability targets
- Packaging minimization targets
- Single-use plastic bans & substance bans
- Labelling requirements
- Extended producer responsibility (EPR)
- Deposit return scheme (DRS)
The PPWR’s impact on a business depends on three critical dimensions:
- Materials used (plastics, paper, metal, wood, others)
- Use type (primary/sales, secondary/grouped, tertiary/transport packaging)
- Product types (food contact-sensitive, food non-contact sensitive, non-food contact-sensitive, non-food non-contact sensitive)
This three-dimensional approach means businesses need a more sophisticated analysis to understand their specific compliance requirements.
The most significant impact will be on:
- Retailers with private label products
- FMCG companies and brands
- Recycling and waste management businesses
- Packaging manufacturers
Pharmaceutical and medical businesses will experience less immediate impact due to exemptions for contact-sensitive medical packaging, though their secondary and tertiary packaging still falls under the regulation.
Future Developments Already Planned
The PPWR is a dynamic framework with more than 15 further reviews, assessments, and delegated acts scheduled in the coming years, including:
- A delegated act in 2026 to set minimum number of reuses for packaging
- Further acts in 2028 on design-for-recycling criteria and recycling performance grades
- Establishment of a framework for extended producer responsibility fee modulation
- A review of the empty space ratio and related exemptions in 2031
Strategic Opportunities
Some good news: companies that approach PPWR strategically can gain significant competitive advantages beyond mere compliance. Many of our clients have already begun transforming this regulatory challenge into business opportunities:
- Redesign product packaging: Use design to sustainable value approach that optimizes compliance, consumer value, and cost efficiency.
- Identify new market opportunities: Explore reuse and refill services, take-back systems, and innovative business models.
- Secure cost reductions: Minimize packaging to reduce transport and storage costs while benefiting from lower EPR fees.
- Secure early access to recycled content: Establish supply chains for sustainable materials before demand intensifies.
- Develop strategic partnerships: Collaborate across the supply chain to establish reuse systems and source sustainable materials.
- Enhance operating model: Strengthen governance over packaging and packaging waste to meet reporting requirements.
At Indeed Innovation, we help you transform PPWR compliance from a regulatory burden into strategic advantage. Our journey with clients typically begins with a comprehensive workshop that brings together key stakeholders from across your organization to align on prioritiehttps://www.indeed-innovation.com/bookacall/s and develop a tailored roadmap for success in the new packaging landscape.
(no sales calls, hands-on talks with our circular packaging strategist, designers, policy experts and engineers)
With implementation timelines now clearer and the full scope of changes better understood, businesses must act promptly. Achieving full regulatory compliance typically takes up to two years, making early preparation essential.
The PPWR represents both a regulatory challenge and a strategic opportunity. Companies that embrace these changes proactively can not only ensure compliance but also gain competitive advantages in sustainability, cost efficiency, and market positioning.
For specific questions about how the PPWR affects your business, please reach out to our experts who can provide tailored guidance for your specific packaging portfolio and business model.
The PPWR is expected to come into force in the fourth quarter of 2024, with immediate effect upon the regulation entering into force. Unlike its predecessor, which required national implementation, PPWR applies directly to all EU member states.
PPWR affects all companies that produce, use, or handle packaging in the EU market. This includes manufacturers, retailers, importers, brand owners, e-commerce businesses, and logistics companies. Even non-EU companies exporting packaged products to the EU must comply with the regulation.
By 2030, 10% of non-alcoholic and alcoholic beverages (excluding wine) must be in reusable packaging. By 2040, at least 70% of transport packaging must be reusable. Additional targets for specific packaging types are also included.
PPWR bans specific single-use plastic items, including packaging for unprocessed fresh fruits and vegetables, miniature toiletry packaging in hotels, and certain food service packaging. The regulation targets packaging formats where sustainable alternatives are readily available.
By 2029, there must be 90% separate collection for single-use plastic and metal beverage containers (up to 3 liters), except if a country is already at 80% separate collection by 2026. This system encourages consumers to return packaging for recycling.
Yes, there are approximately 30 exemptions, including for contact-sensitive packaging of medical devices, infant formula, and baby food; foods for special medical purposes; dangerous goods; and micro-enterprises (for certain requirements such as reuse and refill targets).
Cosmetics and personal care packaging, such as cream jars and hotel toiletries, face significant challenges due to current multi-material designs. Companies will need to simplify packaging, incorporate more recycled content, and develop reuse/refill systems, particularly for hotel amenities.
Packaging manufacturers should focus on developing mono-material solutions, improving recyclability, increasing recycled content offerings, and innovating in reusable packaging systems. Early adaptation can position manufacturers as preferred suppliers for brands seeking PPWR compliance.
