In mid-December 2024, the European Council formally adopted the PPWR (Packaging and Packaging Waste Regulation) – a significant step toward reducing the ever-increasing packaging waste and promoting sustainable packaging solutions.
Following its publication in the EU Official Journal in January 2025, the regulation will come into effect 20 days later and become mandatory for all EU member states after 18 months. An important but often overlooked aspect: it must also be considered when importing goods into the EU.
Unlike previous packaging regulations, the new EU Packaging Regulation introduces a fundamental shift, bringing sustainable changes in packaging design, reuse, and recycling. The often vague and non-binding commitments from the communication departments of many brands must now be replaced with concrete and verifiable targets. In this context, “sustainable” truly marks the beginning of a systemic change: the traditional linear economy model – operating under the “make-use-waste” principle – is gradually being replaced by a circular economy that keeps raw materials in circulation.
Determining how a company is affected by the PPWR and what specific actions are required for compliance is not an easy task, given the complexity of the regulation.
To assist with this, Pacoon Sustainability Concepts GmbH has developed a support tool – the PPWR Decision Tree – to help companies quickly grasp the EU regulation and easily identify potentially affected packaging within their operations. The key advantage: detailed knowledge of the regulation’s content is almost never required.
Background
The European Packaging Regulation, as it is commonly referred to in German-speaking regions, marks the beginning of a major transformation within the EU’s economic space. Compared to other economic regions, Europe has a geological disadvantage: it largely relies on imported raw materials. Events like COVID-19, the instability of political structures in partner countries, and the Ukraine war have demonstrated how fragile the economy becomes when critical goods are unavailable. The goal is to counteract this dependency through new innovative technologies, enabling a circular economy that helps mitigate reliance on finite resources while addressing climate change and pollution.
The overarching goals of the European Green Deal are:
- (a) Greater independence in raw material supply
- (b) A strong economic stimulus through the development, production, and export of innovative, future-oriented technologies within the circular economy—leading to new, sustainable jobs
- (c) Achieving environmental targets to become the world’s first climate-neutral economic region
71 Articles, Plus Annexes and Cross-References
Packaging is particularly well-suited to drive this European transformation strategy. Its lifecycle is very short, typically protecting a product from production until purchase or use. For food packaging, this period is often no longer than 18 months, and for perishable products, only a few weeks. This results in high material consumption (e.g., cardboard and plastic), which is evident in the excessive packaging waste seen in household recycling bins.
Thus, recycling and reuse of packaging across all EU member states are at the heart of the EU Packaging Regulation. The goal is to establish a uniform standard for handling packaging, harmonizing previously fragmented national regulations and simplifying trade within the EU’s internal market.
However, the EU-wide validity of the regulation does not mean that national packaging laws lose their importance. In fact, member states can impose stricter regulations than the PPWR, so national laws remain relevant and must be carefully observed.
The regulation applies to all packaging placed on the EU market, affecting primarily manufacturers and importers. It covers all packaging types, whether B2B or B2C, including sales packaging, e-commerce packaging, and transport packaging. Although plastics are subject to the strictest requirements, all packaging materials fall under the PPWR’s scope.
With 71 articles, plus annexes and references to other regulations, the PPWR is a complex legislative framework. Additionally, further legal acts clarifying its requirements will be published over the next two years. The regulation affects not only manufacturers and importers but also the recycling industry, packaging producers, and policymakers within EU member states.
Support Tools: Decision Trees & PPWR Check
Pacoon Sustainability Concepts (PSC) has already analyzed PPWR requirements for various clients across different market segments. Each industry must address specific questions to understand how its packaging portfolio can remain compliant or what changes may be necessary.
In initial client projects, this compliance analysis was conducted through specialized workshops, involving all relevant departments within a company.
One of the biggest challenges at this early stage of the PPWR is interpreting its terminology and formulations. The Decision Tree and the specially designed Web Tool “PPWR Check” transform these complex requirements into a clear and practical decision-making process. This enables employees to quickly and easily identify PPWR compliance requirements for any packaging scenario.
It is important to note that compliance is not just about the packaging or material itself but about fulfilling multiple scenario-based requirements. PSC has therefore defined the following PPWR categories:
- Sales Packaging: Packaging that forms a sales unit together with the product
- Beverage Packaging: Packaging that forms a sales unit with a beverage
- Transport Packaging: Packaging that facilitates handling and transport of one or more sales units
- E-Commerce Packaging: Transport packaging used for online sales or remote purchases
- HORECA Sector (Hotel, Restaurant, Catering): Packaging for hospitality and food services
A single packaging type may be used in multiple sectors, leading to different compliance requirements. For example, transport packaging may have different rules depending on its destination (within the same EU country or across borders) or the recipient (e.g., business partners or consumers).
Since PPWR implementation is phased, multiple compliance deadlines are set for 2030, 2035, 2038, and 2040.
Starting April 2025, the PPWR Check web tool (www.ppwrcheck.com) will be available. Without specialized training in legal texts, entire teams can simultaneously analyze packaging portfolios across multiple languages in minutes, uploading data via Excel for instant PPWR compliance checks. Additional services will follow, such as an AI-powered Q&A tool covering multiple laws and languages, compliance tracking, and further regulatory updates in the coming years. This ensures companies have a permanent compliance monitoring tool beyond 2030.
Speed is Key
Companies typically seek external support for PPWR compliance due to:
- Lack of internal resources to manage this significant regulatory framework alongside other daily projects
- Limited experience with national and EU laws
The PPWR Decision Trees provide a fast and practical solution, identifying compliance gaps in minutes—saving time for strategic planning of future packaging solutions. Some requirements, especially in transport packaging, demand long-term systemic changes rather than quick material swaps. Delaying action could lead to costly emergency solutions or even marketing bans.
The PPWR should be seen as a guide for making packaging more sustainable. Companies failing to comply face a ban on marketing their products within the EU or specific markets. Many solutions require systemic development, and switching to alternative packaging options can take years.
Thus, an early analysis is critical to allocate personnel and resources efficiently and ensure compliance. With the PPWR Check and Decision Trees from PSC, companies can quickly identify requirements and proceed with portfolio analysis and optimization.
