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Understanding PPWR

Understanding PPWR

  • What is PPWR
  • PPWR latest updates
  • What your business needs to know
  • How will PPWR affect your industry?
  • Useful links
  • Sustainability has become the main driver of change in the plastics industry.

    On Wednesday 24th April 2024, the EU Parliament agreed on new measures to reduce packaging waste and increase the sustainability of packaging via the Packaging and Packaging Waste Regulation (PPWR). The regulation aims to tackle the volumes of packaging waste, harmonise internal market rules and boost the circular economy. To help prepare for the profound impact that these new ambitious targets will have on the whole plastics value chain, AMI has created ‘Understanding PPWR’, your comprehensive online hub to navigate the complexities of the EU’s new Packaging and Packaging Waste Regulation.

    Our team of expert consultants have compiled clear, concise information to address specific concerns and answer all your PPWR questions. We understand how important your time is, so let us analyse the PPWR for you. As the regulation develops, we will examine its relevance and the effect of its implementation for all relevant industries within the plastics supply chain. This allows you to find the information you need quickly and easily.

    We will keep you informed throughout the coming months and years with the latest industry news surrounding PPWR. We will also be assessing the impact of the regulation at our events and in our market reports. For now, take some time to explore the hub and familiarise yourself with the valuable resources available.

Understanding PPWR - video library

  • ∂

    We are excited to launch our new PPWR video library, a comprehensive resource designed to offer in-depth insights into various aspects of PPWR (Packaging and Packaging Waste Regulation).

    Here, Consultant Olivia Poole guides you through the Packaging and Packaging Waste Regulation covering a variety of important topics, including the objectives, the specific measures being introduced, and the timeline and implementation plan.

  • Interview gif

    This collection features informative videos from key members of AMI, each providing expert analysis and commentary on the implications of PPWR in their respective areas of expertise, including:

    • Polymer demand and recycling (Elizabeth Carroll)
    • Recycling and sustainability (Silke Einschuetz)
    • Flexible films (Susannah Owen)
    • Palletisation films (Alexandra Fish)
    • Rigid packaging (Martyna Fong)
    • PFAS (Richard Shepherd)
    • Access the PPWR video library

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  • What is the Packaging and Packaging Waste Regulation?

    In simple terms, the PPWR establishes a wide-ranging plan which aims to create binding and uniform packaging rules in the EU internal market to cover the whole packaging lifecycle. These rules will reduce packaging waste, harmonise the internal market and boost the circular economy.

    The Regulation includes:

    • Design for recycling criteria, including “recycled at scale”
    • Minimum recycled content targets for plastic packaging
    • Reuse targets for industrial and consumer sales packaging
    • The implementation of Deposit Return Systems
    • Packaging bans for certain uses from 2030
    • Packaging minimisation targets
    • Labelling requirements
    • Per capita waste reduction targets
    • Extensive reporting requirements
    • Groundwork for future rulings on bio-based plastics and PFAS

    The overall goal of PPWR is to create a more sustainable packaging system within the EU. This is achieved by dictating the use of recyclable materials, promoting reusable packaging options, and holding producers accountable for the end-of-life management of their packaging.

What your business needs to know

Article 6 states that all packaging placed on the market will be recyclable. This is based on the 2020 EU Circular Economy Action Plan that aims for all packaging to be “reusable or recyclable in an economically viable way by 2030”. From 2030, packaging will be considered recyclable if “it is designed for material recycling, which enables the use of resulting secondary raw materials that are of sufficient quality when compared to the original material that it can be used to substitute primary raw materials”. From 2035, it will be recyclable if “it can be collected separately, sorted into specific waste streams without affecting the recyclability of other waste streams and recycled at scale”.

Currently, standards defining recyclability are in place at national level, but there are no harmonised rules. PPWR aims to create harmonised rules and a reliable legal framework for design for recycling.

Design for recycling criteria (by polymer and by format) will be established via a delegated act. Medical goods, infant foods, and transport of dangerous goods will only be exempt until 2035.

Packaging recyclability is to be expressed in performance grades A, B, C (e.g. material compatibility, additives, fillers, etc.), per packaging format. Thresholds for each scoring level are to be established. EPR fees will be modulated based on these grades.

When a packaging unit’s recyclability performance grade is below 70%, it is considered to be non-compliant with the recyclability performance grades, will be considered technically non-recyclable, and its placing on the market should be restricted. Therefore, after 2030, market access will be only for recyclable packaging.

Design-recycling-criteria-including-recycled-scale-table.png

Assessments based on Design for Recycling criteria are to be carried out for each packaging category listed in Table 1 of Annex II (a total of 30 categories, 18 of which are plastics). Please see Annex II, Table 4 for a list of parameters for setting Design for Recycling criteria.

From 2035 a new factor, “recycled at scale” will be added to the assessment of packaging recyclability. The assessment will be carried out based on the quantity (weight) of the material effectively recycled from each of the packaging categories.

Packaging will be considered recycled at scale if (Article 3 (38)) it “is collected separately, sorted and recycled in installed infrastructure using established processes proven in an operational environment”… “which ensure, at Union level, an annual quantity of recycled material under each packaging category listed in Table 2 Annex II, equal to or greater than 30% for wood and 55% for all other materials”. The thresholds will be reviewed in 2035. “It includes packaging waste that is exported from the Union for the purpose of waste management”.

Article 7 outlines the minimum recycled content targets for plastic packaging (only). They aim to create steady demand for recyclates, allowing demand decoupling from virgin plastic price developments, resulting in increased investment security for recyclers.

Minimum recycled content targets for plastic packaging table

The targets exclude most medical or compostable packaging, or plastic parts representing less than 5% of total weight of a packaging format, plus other exceptions (see Article 7 (4)).

Recycled content can also be recovered from post-consumer plastic waste collected or recycled in a third country as long as this meets EU standards (Article 7 (3)). This was a necessary compromise for the Regulation to be passed.

By 31st December 2026, there will be delegated acts for establishing a methodology for calculation and verification of recycled content as well as a delegated act to establish sustainability criteria for plastic recycling technologies. By 1 January 2028, the Commission will assess the need for derogations from the 2030 targets for non-PET packaging on the basis of non-availability of recyclate.

Article 29 lays out the reuse targets for industrial packaging, as shown in the table below. The targets are considered quite controversial and subject to intense lobbying. While an impact assessment was made for the initially proposed targets (covering only takeaway and beverage packaging), no impact assessment has been made for the accepted draft. The Environment Commissioner has committed to assess the impact on pallet wrap this year and consider an urgent exemption.

Reuse targets for industrial and consumer sales packaging table

Member states can exempt companies for 5-yearly periods based on the member states performance relating to targets for packaging recycling and waste prevention or based on the corporate waste prevention and recycling plans of individual companies. The EU Commission can also set exemptions based on economic constraints, hygiene and food safety, and environmental issues.

All of the above will be reviewed by 2034 with the 2040 targets in mind.

Article 44 outlines that by 1st January 2029, Member States have to introduce Deposit Return Systems for single-use plastic beverage bottles and single-use metal beverage containers of up to 3 litres. Exceptions apply to wine, aromatised wine products, spirit drinks, milk and milk products listed in Part XVI of Annex 1. Member States can choose to include them if they wish. Member States who achieve an 80% collection rate of the targeted packaging types without a deposit and return system in 2026 may request not to establish a deposit and return system.

These requirements will help deliver greater consistency and higher return rates across Member States. They have been set based on stakeholder views, expert analysis and best practices from the existing deposit and return systems. The requirements are designed to allow for innovation while offering a level of flexibility to adapt to local circumstances.

Article 25 and Annex V aim to prevent unnecessary or avoidable packaging, such as single-use packaging, for which viable reusable alternatives exist, and grouped plastic packaging used to incentivise consumption. The exact scope and exemptions are to be clarified via guidelines by the end of 2026. This proved to be a highly controversial section of the PPWR, with the initial Commission proposal being material neutral, although the adopted ENVI Committee proposal is not and appears to be particularly focussed on plastics.

Packaging bans for certain uses from 2030 table

Article 10 aims to ensure all packaging placed on the market is designed so its weight and volume is reduced to the minimum necessary to ensure packaging functionality and safety. For grouped packaging, transport packaging or e-commerce packaging, there will be an empty space ratio of 50% maximum. Filling materials are to be considered ‘empty space’.

Articles 12 and 13 covers the labelling requirements for plastic packaging, summarised in the table below. Labels should be based on pictograms, easily understandable and placed firmly so they cannot be easily erased. The labelling of recycled content or bio-based plastic content is not mandatory.

Labelling requirements table

Article 43 requires Member States to reduce (post-consumer) packaging waste generated per capita from a 2018 baseline:

  • 5% by 2030
  • 10% by 2035
  • 15% by 2040

Options to reduce packaging waste should incentivise the waste hierarchy (reduce, reuse, recycle). Member states are encouraged to seek to reduce the total amount of plastic packaging waste generated, rather than shifting to lighter packaging. The targets are to be reviewed in 2031, including assessment of the need to include targets specific to certain packaging materials.

EPR will become mandatory for all member states, with fee calculation considering; the actual costs of collection, sorting and recycling; labelling waste bins; and the analysis of mixed municipal waste. Member States may also include the costs of cleaning up litter.

There will be mandatory fee modulation based on the recyclability of packaging and an optional but expected fee modulation based on additional recycled content.

Article 8 states that the European Commission will review the state of technological development and environmental performance of bio-based plastic packaging (not biodegradable) by the end of 2027. Based on this review it shall, where appropriate, present a legislative proposal for sustainability requirements for bio-based feedstock in plastic packaging and lay down targets to increase the use of bio-based feedstock in plastic packaging. These targets will be complimentary, not replacing, recycling targets with only a few possibilities where bio-based could be used instead of recyclates. Article 5 states that by 31st December 2026, the Commission will prepare a report on the presence of substances of concern in packaging and packaging components, aided by the European Chemicals Agency. The aim is to determine the extent to which they negatively affect the re-use and recycling of materials or impact chemical safety. 18 months from the date of entry into force, food contact packaging shall not be placed on the market if it contains PFAs in a concentration of or above the following limit values:

  • 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded from quantification)
  • 250 ppb for the sum of PFAS measured as sum of targeted PFAS analysis, optionally with prior degradation of precursors (polymeric PFAS excluded from quantification)
  • 50 ppm for PFASs (polymeric PFAS included); if total fluorine exceeds 50 mg /kg the manufacturer, importer or downstream user shall upon request provide to the enforcement authorities a proof for the fluorine measured as content of either PFAS or non-PFAS.

Member States shall report for each calendar year data on:

  • the amounts of packaging made available on the market for the first time on the territory of that Member State for each packaging category as listed in Table 3 of Annex XII (as defined in Table 2 of Annex II)
  • amounts of collected packaging waste for each packaging material as referred to in Article 52
  • the amounts of recycled packaging waste and recycling rates for each packaging category as listed in Table 3 of Annex XII.

Furthermore, the packaging manufacturer would be required to carry out a conformity assessment, draw up a Declaration of Conformity, and maintain this together with the technical documentation specified in the PPWR on file for 10 years after the packaging is placed on the market. They must also be made available to the Member State enforcement authorities upon request. If the manufacturer is outside of the EU, the importer would assume responsibility for the EU Declaration of Conformity and technical documentation.

Additional insights: how will PPWR affect your industry?

Uncover a wealth of industry support resources. Gain insights, thought leadership and targeted support designed to meet your unique business needs.

  • Feature
    Understanding PPWR - CapsulesUpdate: how will PPWR affect the capsules industry?20 June 2024
  • Feature
    Closures PPWRClosure industry is gearing up for PPWR13 June 2024
  • Feature
    Single Serve Caps vs PPWRInterpretation of the newly adopted PPWR for the capsules industry7 May 2024
  • Feature
    Has the EU put single serve capsules at a crossroads?Has the EU put single serve capsules at a crossroads?31 May 2023

Latest updates

The PPWR received final approval from the European Parliament. It was approved with 476 votes in favour, 129 against and 24 abstentions.

The regulation is voted through at the European Parliament with a large majority of 476 votes in favour, 129 against and 24 abstentions.

EU Council and EU Parliament agree on the provisional version of PPWR.

Lead committee ENVI adopt their report on PPWR (after 2741 amendments).

European Commission brings forward a draft proposal of the existing EU rules on Packaging and Packaging Waste.

Useful links

We have compiled a list of useful links for you to visit. Here you can also directly enquire about any of our events, market intelligence or consultancy services to gain further support in PPWR and your wider industry.

Packaging waste: EU rules on packaging and packaging waste, including design and waste management.

We partner with key industries across the global plastics supply chain to create conferences that inspire, including:

  • Chemical recycling
  • Mechanical recycling
  • Flexible films recycling
  • Multilayer films
  • Stretch and shrink films
  • Closures and bottles
  • Single-serve capsules
  • Thin wall packaging
  • Polymer sourcing and distribution

Need more tailored support?

Talk directly to our specialist consultants.

They will answer your questions, provide solutions, and help you navigate your specific needs.

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