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.

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.

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.

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.

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.

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.

European Parliament elections are due to take place.

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.

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:

• Single-serve Capsules Europe 2024
• Recycling Flexible Packaging 2024
• Multilayer Flexible Packaging Europe 2024
• Chemical Recycling North America 2025
• Stretch and Shrink Film Europe 2025
• Chemcial Recycling Europe 2025

Our expert provide high-quality market reports on the plastics industry supply chain, including:

• Chemical Recycling, Global Status
• Single Serve Capsules, Global Market 2024
• Stretch and Shrink Film - Global Market 2024
• Mechanical Plastics Recycling - The Global Market 2023
• Global Polymer Demand Data

• Martyna Fong, Director, Market intelligence
• Silke Einschuetz, Senior Consultant Recycling & sustainability
• Olivia Poole, Consultant
• Elizabeth Carroll, Consultant, Recycling and sustainability