Felicitas Frick, Ferdinand Zotz, Letizia Fratini
February 16, 2025
What does the new EU packaging regulation mean for your business?
The new EU Packaging and Packaging Waste Regulation (PPWR) marks a significant step towards a circular economy by targeting the reduction of packaging waste and promoting sustainable packaging solutions.
Packaging is one of the EU’s largest and fastest-growing waste streams, driven by increasing consumption and e-commerce. The introduction of the PPWR means binding measures to minimise waste, enhance recyclability, and expand reusable packaging systems.
For manufacturers, importers, and distributors, the PPWR brings significant changes that require both strategic and operational adjustments. From new recyclability requirements to mandatory recycled content targets, companies must act soon to align their operations with the EU’s ambitious sustainability goals. In a nutshell, all actors who place packaging and packaged goods on the market are affected by the Regulation’s obligations .
The PPWR includes ambitious objectives covering the entire life (and second life) of all types of packaging in terms of environmental compatibility and labelling:
- Reducing the amount of packaging waste
- Promoting a circular economy for packaging
- Promoting the use of recycled content in packaging
- Harmonisation of the internal market for packaging
- Restriction of substances of concern
This article outlines the key elements of the PPWR, its timeline for implementation, and what businesses need to consider to remain compliant and competitive. It also highlights how Ramboll can support companies in navigating these regulatory changes and turning compliance into an opportunity for innovation and growth.
The EU introduced the Packaging and Packaging Waste Directive (94/62/EC) in 1994 to manage packaging waste, but varying national implementations led to inconsistencies. To address this, the European Commission proposed the PPWR in 2022, shifting from a Directive to a directly applicable Regulation. The PPWR sets harmonised, legally binding rules to ensure uniform compliance and the support of a circular economy. The European Parliament approved it on 24 April 2024, followed by the Council on 16 December 2024, with effect from 11 February 2025 .
By introducing the PPWR, the EU aims to eliminate regulatory fragmentation, provide clearer guidelines for businesses, and establish a unified approach to packaging design, production, and waste management across the internal market.
The PPWR primarily addresses producers as key actors, with most obligations coming into effect after August 2026. In line with the PPWR’s definition of a producer, all actors who place packaged goods on the market are affected by the Regulation’s obligations .
1. Design for recyclability
All packaging placed on the EU market must be fully recyclable by 2030, adhering to strict design criteria. Packaging will be assessed for recyclability based on material composition and ease of recycling in existing waste management systems.
2. Mandatory recycled content
Plastic packaging must meet minimum recycled content targets, gradually increasing over time. This pushes manufacturers to incorporate secondary raw materials, supporting the circular economy and reducing reliance on virgin plastics.
3. Packaging waste reduction
Companies must contribute to a 15% per capita reduction in packaging waste by 2040 compared to 2018 levels. This requires minimising unnecessary packaging, optimising material use, and adopting more efficient packaging designs.
4. Reuse and refill systems
Businesses in sectors like e-commerce, hospitality, and food services are obligated to implement or participate in reusable and refillable packaging systems. This shift reduces single-use packaging and encourages more sustainable consumption patterns.
5. Ban on excessive and single-use packaging
The PPWR prohibits certain types of unnecessary packaging, such as overly large packaging for small items and disposable packaging in the hospitality sector. This measure targets wasteful packaging practices and promotes resource efficiency.
6. Restrictions on hazardous substances
The regulation limits the use of harmful chemicals, including a ban on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging. This ensures safer packaging materials for consumers and the environment.
7. Standardised labelling and consumer information
To improve waste sorting and recycling, packaging must feature clear, harmonised labels indicating material composition and disposal instructions. This simplifies recycling processes and enhances consumer participation in waste reduction.
PPWR follows a phased implementation to give businesses time to adapt to new requirements. Figure 1 shows the timeline of producer obligations. Businesses should act early to meet these deadlines and ensure compliance.
For producers, the PPWR requires significant adjustments in packaging design, supply chain management, and material sourcing. Companies must invest in sustainable materials, redesign packaging for recyclability, and engage in circular business models.
Compliance complexity requires significant investment, especially for smaller businesses, and the adaptation of global supply chains for larger ones. Recycled content requirements may increase competition for materials, affecting costs and timelines. Reuse and refill systems add operational complexities.
While these changes pose challenges, they also offer opportunities for innovation, brand differentiation, and long-term cost savings through more efficient material use. Early adopters of sustainable packaging can enhance their market position and appeal to eco-conscious consumers. Sustainable packaging can become a key market differentiator. Optimised packaging design and material use can result in cost savings and smoother market access due to proactive compliance. The PPWR promotes collaboration across industries, driving shared progress through partnerships.
In summary, the PPWR challenges businesses to balance compliance with growth. Embracing sustainability and innovation can mitigate risks and open new growth pathways in the circular economy. Early action will be key for businesses to stay ahead of regulatory deadlines and position themselves as leaders in sustainable packaging solutions.
• Comprehensive Compliance Assistance
Ramboll aids clients in deciphering the PPWR, investigating pertinent obligations for manufacturers and other actors across all types of packaging. Our services include high-level overviews and gap analyses as well as detailed discussions on timelines, definitions, and potential exemptions, ensuring businesses meet regulatory requirements effectively.
• International legislative insights
With extensive knowledge from previous projects, Ramboll delivers a wide-ranging review of state legislation and policy trends concerning packaging. Our profound understanding covers Europe, Asia-Pacific, the US, and insights into other regions. Ramboll's worldwide network of experts is uniquely positioned to offer unparalleled support to clients on an international platform. Our team ensures that strategies not only comply with current regulations but also align with upcoming industry trends.
• Technical and market studies on packaging options
Our experts are available for assessing options for sustainable packaging, including technical options for different materials, recycling performance, and feasibility for re-use of different types of packaging. A specific focus of our team is on plastics.
“The PPWR challenges businesses to balance compliance with growth. Embracing sustainability and innovation can mitigate risks and open new growth pathways in the circular economy.”
Want to know more?
Felicitas Frick
Senior Consultant
+49 1522 2583947
Ferdinand Zotz
Principal, Circular Economy and Resource Management
+49 89 978970141
Letizia Fratini
Consultant