Objectives of the PPWR.
The regulation aims to reduce unnecessary packaging and waste and promote reusable systems and recycling. For almost every company, changing its packaging strategy - from the supply chain to labelling - represents a cross-industry challenge. At the same time, the still incomplete legislation requires companies to remain agile and adapt flexibly to future changes.
Sustainability creates a competitive advantage.
Background - More than just a guideline.
The PPWR replaces the previous Packaging Directive 94/62/EC and establishes a fully harmonised set of rules in line with the EU Green Deal. Unlike directives, the regulation has direct legal effect, meaning that national laws must be adapted. Since coming into force on 11 February 2025, an 18-month transition period applies, which ends on 12 August 2026.
Relevance for your company.
The PPWR affects all economic operators in the supply chain.
Producers, manufacturers, importers or distributors - each economic operator is subject to specific obligations that need to be identified and assessed.
The obligations vary from a conformity assessment for the producer in accordance with Articles 35-39 of the PPWR, which certifies conformity in accordance with Articles 5-11 of the PPWR, the information obligations of suppliers in accordance with Article 16 of the PPWR, to cases in which the producer's obligations also apply to importers and distributors, Article 21 of the PPWR.
The specific obligations must be determined on the basis of the concrete position in the supply chain.
From the supply chain to labelling.
Focus of the PPWR.
1. Substance Restrictions in Packaging (Article 5):
These restrictions are among the first to take effect. Cumulative limits of 100 mg/kg for lead, cadmium, mercury, and hexavalent chromium, as well as requirements regarding the use of PFAS, are among the measures currently known.
2. Recyclability of All Packaging by 2030 (Article 6):
Packaging must be designed with recycling in mind based on the Commission's specifications. Minimum recyclability rates of 70% from 2030 onwards are possible and are expected to increase over time.
3. Minimum Recycled Content in Plastic Packaging (Article 7):
Packaging producers are required to meet minimum percentages for the use of recycled plastic derived from plastic waste.
4. Minimization of Packaging (Article 10):
Packaging must be reduced to the minimum necessary in terms of weight and volume.
5. Focus on Reusable Packaging (Article 11):
The regulation outlines new requirements defining which packaging types are considered reusable and sets targets for increasing the use of such packaging.
6. Extended Producer Responsibility (EPR):
Expansion of the responsibilities of packaging producers, including obligations related to the collection, sorting, and recycling throughout the entire lifecycle.
Essential components for future packaging.
A dynamic framework.
With a maximum of 18 months remaining until the first requirements come into force in August 2026, the PPWR remains an incomplete regulatory framework despite its official start.
These gaps make it essential for companies to pursue two strategies in parallel:
Short-term implementation of known requirements (e.g., substance restrictions)
Long-term flexibility to respond to future changes (e.g., planned quotas for recycled content from 2030 onwards)
Monitoring developments at both the European and national levels
From screening to strategic reorientation.
The next steps for your company.
1. Assessment:
Analysis of the current packaging portfolio and review of compliance with known requirements.
2. Gap Analysis:
Identification of gaps in the packaging strategy and prioritization of necessary actions.
3. Strategy Development:
Creation of a tailored implementation plan, taking transitional periods into account.
4. Implementation and Process Adjustment:
Adaptation of the packaging concept and internal processes – including new documentation and reporting obligations.
Structured implementation minimises risks.
Conclusion.
The PPWR is far more than just a compliance issue - it brings together requirements that will affect your company in the long term. This moment of change offers the opportunity to combine regulatory certainty with the switch to sustainable, recyclable packaging and thus secure a competitive advantage.
Use the transition period as a strategic advantage.
Please contact us.
Find out how the Munich Consulting Group can support you - from a joint gap analysis and the identification of risk areas to the development of specific measures and an early warning system to utilise the PPWR as an opportunity for your company.
