PPWR Regulation: What the new Packaging Act means for foodstuff manufacturers

For companies working on new materials the Regulation has strategic weight. Philip Ortin, Head of Strategic Growth & Alliances at traceless materials, emphasises the importance of standardized rules first and foremost. Requirements that are clear, reliable and harmonized across Europe are vital if nature-based alternatives are to make the transition from “niche” to market-standard and to safeguard investments. Based on this reading, the new EU packaging regulation functions as a market signal: Those who focus on circular solutions will be able to plan with confidence and will thus have the opportunity to implement innovations on an industrial scale.

The Regulation also marks an important juncture from the perspective of providers of reusable packaging. Jonathan Schröder, co-founder and CEO of CU Mehrweg, describes it as a “clear stop signal” for a disposable packaging system that has been structurally favoured for decades. At the same time, he draws attention to conflicting goals in its actual formulation. “One aspect we must look at critically is the fact that reusable packaging systems are subject to the same recycled material quotas as disposable packaging.” He notes that reusable packaging already operates in closed cycles and controlled material flows, and thus makes substantial contributions to the circular economy. Additional quotas could unnecessarily complicate the implementation of such systems.

The EU Packaging and Packaging Waste Regulation (PPWR) as a challenge for foodstuff manufacturers

For foodstuff manufacturers, the new requirements under the Regulation involve significant changes. In particular, Schweig refers to the switch to recyclable and/or reusable packaging. “That also includes supposedly ‘good’ materials such as paper or glass.” Then there are minimum quotas for recycled components in plastic packaging. Food-grade packaging containing 30% recyclates have to be made available soon.

At the same time, there are tough requirements in terms of food safety and hygiene. Recycled materials must satisfy the highest standards, which necessitates closer collaboration along the value chain in order to get filling operators more closely involved in development processes.

In addition to technical questions, there is also growing organizational pressure. Schweig refers to the challenges facing SMEs in particular, which still often lack suitable technical documentation for implementing digital labelling and complying with verification obligations. Not only that, but putting deposit or return systems in place and complying with extensive documentation and reporting obligations require new structures and workflows.

Ortin notes that existing approaches alone will fall far short of satisfying the ambitious target and quota requirements under the Regulation. The result will be a structural gap that can be filled only with the additional use of alternative, bio-based and recyclable materials.

Biocircular and reusable: New ways of dealing with packaging waste

Accordingly, new material concepts and systemic alternatives are coming to the fore. The company ‘traceless materials’ is developing materials designed for the bio cycle which can be fed back into natural cycles following use. It is starting with coatings for paper packaging of greasy foods and is planning further solutions in the area of blown and cast film, as a PPWR-compliant substitute for packaging for fruit and vegetables or dry products, for example. The target is to make relevant volumes available by 2030 – just under 100,000 metric tons per year – and thus achieve effective market scaling.

Reusable packaging is growing in strategic importance in parallel. The EU packaging regulation prioritizes reuse, which means reusable packaging scores in terms of preventing waste and ensuring clean material flows in particular. CU Mehrweg focuses on light, stackable and standardized containers that can be integrated into existing production and logistical processes. According to Schröder, lightweight products in the dry segment in particular offer efficiency advantages compared to traditional reusable solutions involving glass or stainless steel. Access for smaller manufacturers will also be facilitated by using existing reusable packaging structures in trade and partnering with a network of contract filling operators.

Sustainable packaging as a criterion for purchase

Consumption patterns for sustainable packaging indicate a growing sensitization among consumers. Ortin refers to empirical findings: “Studies show that a good half of European consumers consider environmental aspects in their purchasing decisions.” About one-third deliberately buy fewer products in plastic packaging, while a relevant proportion avoids plastic altogether or has already switched brands because of concerns regarding packaging.

Schweig observes an increased acceptance of sustainable packaging among younger and environmentally aware target groups in particular. They are willing to pay for it to a degree, but only in the low percentage range, and subject to transparent communication. At the same time she warns against the risks to reputation caused by greenwashing. The packaging regulation and supplementary provisions on environmental statements increase the pressure to back environmental promises with robust evidence.

Schröder describes a high level of acceptance for reusable packaging, especially in Germany. Positive feedback and a higher than expected acceptance of deposits bolster his confidence that return rates of over 90 percent can be achieved without the system being perceived as an additional expense.

Making strategic use of sustainable packaging

The growing sensitization of consumers is opening up new strategic opportunities for companies at the same time. Sustainable packaging solutions not only have a functional impact but they are also perceived more and more as a visible signal of corporate attitude. “They have long been more than just protective solutions,” says Ortin. “They are an expression of a brand’s attitude and value.” Sustainable packaging and recyclable solutions can convey a sense of responsibility and future viability, and thus influence purchasing decisions.

New reusable packaging formats offer strong potential for standing out from the competition, in Schröder’s view. They create “light-bulb moments” and make it possible to generate credible brand stories with a visible impact. And sustainability becomes something that can be perceived directly.

Schweig recommends being careful, however. Packaging decisions must be based on facts and be robust from a regulatory perspective. A supposedly environmentally friendly solution, coated paper packaging, for example, could prove not to be recyclable or fail to meet regulatory requirements. Under the PPWR, misconceptions such as this could quickly turn into risks.

Toward a circular economy with the new EU packaging regulation

For the long term, the PPWR is more than just a detailed regulatory document. It serves as a driver of structural change toward economic models that look after resources and are viable for the future. Schröder expects reusable packaging to become a strategic complement to many packaging portfolios and that closed cycles will become established beyond the beverage sector. Ortin views the Packaging Directive as a driver of clear trends toward recycling-compatible design, the reduced use of materials, higher proportions of recycled materials, and biomaterials. That increases the need to scale innovative materials faster, driven by regulatory pressure and growing market demand.

Schweig places this dynamic in a broader economic context: “The economic world we operate in has changed, and not all the raw materials we need will be available in sufficient volumes in future.” She notes that the goal must be to break the link between consumption of raw materials and economic growth, and to enable growth in a context of reduced resource consumption. For the packaging industry, that means minimizing packaging, rigorously recycling materials and systematically expanding the reuse of materials. The most effective lever takes the form of comprehensive optimization along the entire packaging chain, from primary to transport packaging, and in correcting widespread misconceptions, e.g. that thicker packaging automatically guarantees better product protection.

FAQs – The new EU Packaging and Packaging Waste Regulation (PPWR) in brief

What is the new Packaging Act?

The PPWR (Packaging and Packaging Waste Regulation) is the new EU packaging regulation, Regulation (EU) 2025/40, which supersedes the previous Directive. As a regulation that is directly applicable, it is binding in all member states with no need to be transposed into national law first. Its goal is to minimize packaging waste, expand recycling and bolster the circular economy throughout Europe.

Who does the Packaging Act apply to? 

The EU packaging regulation PPWR covers almost all packaging that is marketed in Europe, regardless of whether it is made of plastic, paper or composite materials. “Packaging” refers to any product intended to protect another product, keep it together, facilitate its transport or sale, or display goods at the place of sale.

When does the new Packaging Act take effect?

The new requirements of the European packaging regulation will apply throughout the EU from August 2026. From that point it will be refined in stages through to 2030.