The European Union’s new Packaging and Packaging Waste Regulation, known as PPWR, marks a major shift in how packaging is designed, assessed and placed on the European market. The regulation replaces the previous EU directive on packaging waste and introduces directly applicable rules across all member states.
For companies operating across Europe, the regulation means stricter oversight and less room for national interpretation. It also requires businesses to reassess how their packaging portfolios are structured, particularly in relation to recyclability, waste reduction and documentation.
The regulation introduces harmonised requirements covering recycling performance, reuse targets, recycled content thresholds and more detailed reporting obligations. These rules are intended to standardise packaging regulation across the EU but are also expected to increase regulatory scrutiny for manufacturers and brand owners.
A shift from directive to binding regulation
Unlike the earlier Packaging and Packaging Waste Directive, which allowed member states to implement rules through national legislation, the new PPWR will apply directly in all EU countries. This change aims to reduce regulatory fragmentation across the single market.
For companies selling products in several EU markets, this shift creates both challenges and opportunities. Compliance assumptions that previously relied on national interpretation will need to be reassessed, while packaging solutions that worked in one market may no longer meet the stricter EU-wide standards.
At the same time, businesses that respond early could streamline packaging portfolios, reduce material use and avoid last-minute redesigns once the regulation becomes fully enforceable.
Industry experts, therefore, stress that companies first need a clear and evidence-based understanding of their current packaging structures before redesigning materials or changing supply chains.
Packaging portfolio audits become critical
One of the key preparation steps for companies affected by the PPWR is conducting a comprehensive packaging portfolio audit. This process involves analysing all packaging formats used by a company across brands, products and markets.
A portfolio audit evaluates several technical aspects, including materials, weight, barrier layers, inks, adhesives, coatings and recyclability. The aim is to assess compliance not only with current regulations but also with the upcoming requirements introduced by the PPWR.
Without such a structured overview, companies risk making costly mistakes. Some may overcorrect by replacing packaging formats that could be improved with minor adjustments. Others may underestimate compliance risks and discover regulatory problems too late, potentially delaying product launches or market access.
By systematically reviewing packaging, companies can classify solutions as compliant, partially compliant or non-compliant under current and upcoming EU rules.
Data-driven approach to regulatory compliance
An effective packaging audit generally follows a structured process.
The first step is defining the scope and consolidating data. Companies collect information on brands, product formats, materials and market distribution from internal systems and supplier declarations.
The second stage focuses on technical material evaluation. Each packaging format is examined in detail, including multilayer structures, barrier properties and average packaging weight. If the available information is incomplete, laboratory testing or supplier verification may be required.
Third, companies assess recyclability and regulatory alignment. Packaging designs are compared with emerging EU design-for-recycling criteria and performance standards expected under the PPWR framework.
The fourth step involves classifying the compliance status of each packaging solution. Companies categorise products as compliant, partially compliant or non-compliant and identify potential regulatory risks.
Finally, companies prioritise actions and develop a roadmap. High-volume products or strategically important formats are typically addressed first, followed by medium-term redesigns and longer-term packaging innovation.
Packaging strategy under tighter EU regulation
A packaging portfolio audit is not only a compliance exercise. For many companies, it can become the starting point for broader packaging optimisation strategies.
By identifying opportunities to reduce packaging weight, simplify materials or improve recyclability, companies may also reduce costs and streamline supply chains. Early preparation may also help businesses avoid sudden redesigns, strained supplier relationships or emergency investments once the regulation takes full effect.
However, the transition is likely to require significant adjustments across several industries, particularly for companies using complex multilayer packaging or materials that are difficult to recycle.
As the PPWR moves closer to full implementation, businesses operating in the EU are expected to face growing pressure to demonstrate that their packaging solutions meet the new regulatory standards.
Source: MM Group (industry guidance on EU PPWR regulation)
Fact check:
The EU Packaging and Packaging Waste Regulation (PPWR) is part of the EU’s broader waste reduction strategy. The regulation introduces stricter requirements for recyclability, reuse and recycled content in packaging placed on the EU market. Unlike earlier directives, it will apply directly in all EU member states once adopted.
