PPWR

The European Union’s Packaging and Packaging Waste Regulation 2025/40 (PPWR) introduces a major regulatory shift for packaging sustainability. Adopted under the EU Green Deal and Circular Economy Action Plan, the PPWR aims to reduce environmental impact by enforcing stricter packaging design, usage, and end-of-life treatment requirements. Notably, it replaces Directive 94/62/EC and applies to all packaging placed on the EU market, regardless of its origin.

PPWR Scope and Legal Basis

The European Union’s Packaging and Packaging Waste Regulation 2025/40 aligns with the EU’s Circular Economy goals and climate neutrality targets. It applies to:

Packaging for all products sold in the EU, including imports
All industry sectors: food and beverage, cosmetics, electronics, e-commerce, and more
B2C and B2B packaging, transport packaging, and single-use formats

Material Categories Covered by PPWR

Specifically, the regulation applies to a wide range of packaging materials:

Plastics (rigid, flexible, bioplastics)
Paper and cardboard
Glass
Metals (steel, aluminum)
Wood
Composite/multilayer materials

Key Requirements:

Companies must adhere to the following core requirements:

Minimization: Packaging must be reduced to the minimum volume and weight needed for safety and functionality.
Recyclability: All packaging must be recyclable at scale by 2030.
Reusable Packaging: Quantified reuse targets for specific sectors.
Recycled Content: Mandatory thresholds for recycled plastic content.
Hazardous Material Restrictions: Ban of certain substances (e.g., PFAS, carbon black).

Banned Packaging Materials PPWR

The PPWR bans materials and formats that impede recyclability or have high environmental impacts.

Restricted Formats and Substances

Single-use plastic food service packaging, including cutlery, plates, straws (per EU 2021/1970)
Carbon black plastics, which cannot be detected via NIR sorting
PFAS (Per- and Polyfluoroalkyl Substances) in food-contact packaging
Non-recyclable composite structures with inseparable layers

Compliance Documentation

Companies must be prepared to submit:

Material safety data sheets (MSDS)
Declarations of conformity (DoC)
Independent lab test reports verifying recyclability and chemical content

Recycled Content Requirements

The PPWR mandates a progressive increase in recycled content for plastic packaging.

PPWR Recycled Plastic Thresholds

In detail, the PPWR mandates a progressive increase in recycled content for plastic packaging.

Year	Food Contact	Non-Food Contact
2030	30%	65%
2040	65%	70%

Accepted Verification Methods

Mass balance approach certified by schemes like ISCC PLUS
Supplier declarations verified via third-party audits
Recycling certificates from accredited recyclers (e.g., EuCertPlast)

Design for Recycling Standards

In general, the regulation outlines specific criteria for designing recyclable packaging.

Technical PPWR Requirements

Plastic Packaging:
- Minimum 95% of a single polymer
- Additive content limited to 5%
- No metalized films, carbon black, or silicone coatings

Paper/Fiber Packaging:
- Plastic content <5% of total weight
- No plastic windows >5% of surface area
- Must use water-based adhesives and inks

Testing Protocols

Near-infrared (NIR) sortability tests
Sink-float separation to evaluate polymer purity
Pilot-scale recycling trials simulating real-world conditions

Reusable Packaging Requirements

PPWR mandates the reuse of systems in various sectors.

Reuse Targets by Sector

According to the on Packaging and European Commission’s 2022 proposal, Packaging Waste Regulation (COM(2022) 677 final) :

E-commerce packaging: 10% reusable by 2030
Food and beverage service: 20% reusable by 2030

Reusability Criteria

Durability: Minimum 20 re-use cycles
Must resist industrial washing and handling
Unique ID systems: RFID, QR codes, or serial numbers
Monitoring infrastructure to track returns and reuse

Extended Producer Responsibility (EPR)

PPWR strengthens EPR systems by assigning full waste management costs to producers.

EPR Fee Modulation Factors

Recyclability score
Environmental impact of material
Use of recycled content
Sorting and collection difficulty

Reporting Requirements

Annual data submission per SKU:
- Material type and weight
- Packaging format
- Reuse and recycling rates
Submission of digital product passports (DPPs)

Compliance PPWR Roadmap

Material and Packaging Assessment

FTIR (Fourier Transform Infrared Spectroscopy) to verify polymers
DSC (Differential Scanning Calorimetry) for thermal behavior
TGA (Thermogravimetric Analysis) to quantify additives

Redesign Strategies

Replace multi-materials with mono-materials
Use recyclable inks and adhesives
Incorporate standardized closures and labels

Documentation Preparation

Technical files for each product line
Third-party testing documentation
Supplier statements and certification of compliance

Conclusion: Preparing for the Circular Packaging (PPWR)

The PPWR imposes a demanding but essential framework for packaging sustainability. Full compliance requires:
- Robust supply chain cooperation
- Investments in material testing and innovation
- Data-driven design changes
- Active participation in EPR schemes
Companies that act early will benefit from smoother market access, reduced regulatory risks, and improved brand reputation. Enviropass Expertise Inc. offers technical support, compliance consulting, and eco-design services to help you meet PPWR requirements.

Need help? Contact Enviropass today to begin your PPWR compliance journey.