EU packaging waste regulations are a significant opportunity

EU packaging waste regulations are a significant opportunity

April 2024

by Tim Hartley, Senior Consultant at 42T

Proposed EU rules for packaging present a significant opportunity for manufacturers to move their packaging portfolios in line with new regulations, stay ahead of the market and capitalise on the increased revenue predicted by the EU. By acting now, the packaging industry can also be a key player in mitigating environmental challenges.


PPWR packaging regulationsPackaging plays a crucial role in advertising, protecting, and transporting goods. Without it, there would be significantly greater spoilage and product waste, especially in the food and beverage industry.  

However, packaging is a major environmental concern. It consumes a significant amount of virgin materials (40% of plastics and 50% of paper used in the EU) and constitutes 36% of municipal solid waste.

The packaging challenge

The rising use of packaging and low re-use and recycling rates hinder the development of a low-carbon circular economy. The increased use of packaging design characteristics, such as bonding different materials that hinder recycling has been observed, leading to a growth in unrecyclable packaging.

Moreover, technically recyclable packaging often goes unrecycled due to insufficient collection, sorting, and recycling processes or lack of cost-efficiency. This results in environmental issues like CO2 emissions, resource overexploitation, biodiversity loss, and pollution. 

Differing regulatory approaches among Member States of the EU have created obstacles for the global packaging market to function effectively. These differences include labelling requirements, definitions of recyclable packaging, responsibility for waste, and marketing restrictions on specific packaging formats.

PPWR packaging regulations

However, these disparities also create legal uncertainty for businesses, reducing investment in innovative, environmentally friendly packaging, and circular business models.

What is PPWR?

The European Commission is proposing EU-wide rules on packaging to tackle the ever-growing waste crisis, and consumer frustrations. PPWR stands for Packaging and Packaging Waste Regulation, a European Union regulation aimed at reducing packaging pollution and building a circular economy for packaging. The regulation includes core measures on waste prevention and re-use, as well as full recyclability of packaging.  

For consumers, these regulations promise reusable packaging options, eliminating unnecessary packaging, reduced overpackaging, and clear labelling to support proper recycling. These rules present new business opportunities for the packaging industry, especially for smaller companies.  

They will also decrease the reliance on virgin materials, boost recycling capacity, and make Europe less dependent on primary resources and external suppliers. These measures could drive the packaging sector towards climate neutrality by 2050. 

However, some have criticised the regulation for setting unrealistically high targets for reusable packaging which could make it more challenging to recycle plastic packaging. The PPWR will result in significant changes for anyone working in or serving the packaging industry.  

What are the regulations now?

The Packaging and Waste Directive (PPWD) primarily influences packaging in the EU. It is a European Union directive that deals with the problems of packaging waste and the currently permitted heavy metal content in packaging. The Directive obligates member states to meet targets for the recovery and recycling of packaging waste and  covers all packaging in the Community market.  

Targets are set as a percentage of packaging flowing into the waste stream. The Directive sets targets for recovery and plastic recycling and requires the implementation of measures to prevent packaging waste in addition to preventative measures under ‘essential requirements’ which may include measures to encourage the re-use of packaging.  

While this directive was successful in some of its intended targets, it also has some shortcomings: 

Implementation is at the national level 

This leads to differences in interpretation and enforcement. The lack of harmonisation can result in varying recycling rates and approaches to packaging waste management across different countries, creating potential barriers to an efficient and effective recycling system 

Focus on recycling to manage packaging waste 

This has meant that other waste reduction methods have yet to be given targets and therefore overlooked. 

Focus on plastics 

While the directive addresses the recycling and recovery of plastic packaging waste, it may not cover all types of packaging materials comprehensively.  

What are the key updates in the new PPWR?

1. Packaging material composition changes

Producers will have to include mandatory rates of recycled content in new plastic packaging to increase the use of recycled materials. Additionally, certain plastics will be banned, minimising the harmful impact of introducing these compounds into the environment. 

2. All packaging on the EU market to be recyclable by 2030 

Companies will be required to offer a certain percentage of their products in reusable or refillable packaging. The 2030 target will be achieved by setting design criteria for packaging, improving standardisation in recyclable packaging formats, and establishing clear guidelines for compostable packaging.  

3. Clear and harmonised labelling 

All packaging must conform to a harmonised labelling system defining which waste stream the products can be placed in. The same symbolism being used across the EU should help clarify for both users and producers, resulting in more recycling. 

4. Regulations to reduce unnecessary packaging

This will include setting maximum empty space ratios and minimising packaging weight and volume where possible. Some packaging forms will also be banned, including single-use packaging for many industries. 

What impact is this likely to have?

According to the EU press release, if successfully implemented, the proposed measures could reduce packaging waste by 15% per member state (per capita) by 2040, compared to 2018 levels. This would result in an overall waste reduction of about 37% across the EU. Furthermore, greenhouse gas emissions from packaging could be reduced by 23 million tonnes, and water use would be reduced by 1.1 million m3 by 2030. 

While the eventual benefits to the environment and economy will be substantial if these regulations are fully realised, the initial adoption will be challenging. There have already been concerns raised about how ambitious the stated targets are, with the concern that if these changes are brought in too quickly it could lead to a large amount of waste as new systems have to be adopted and the old ones removed. 

Additionally, there have been calls for greater elaboration on some of the specifics of the new regulations before they become enforceable. The scale of supply chain change for packaging companies still needs to be determined.  

Regardless of the specifics of the regulations, it is clear that companies need to change the way they operate in some form by changing their material source, the materials themselves, the design of their packaging or even the way their business model works around packaging. 

What can 42T do?

At 42T we have a team of expert designers and engineers with a wealth of experience in the packaging industry, from concept design to manufacturing line optimisation.

As regulations change, there will be several scales of change, from 'running as normal' with recycled instead of virgin materials, to a complete packaging redesign with both new materials and reduced amounts of materials.  

We have the capability to support your packaging teams with the changes that will be required.  We have also run projects of varying sizes across a different industries helping clients reduce their material usage, saving cost and complexity, or transition from existing mixed material packaging to mono-material solutions.

Additionally, we have experience with novel materials including bioplastics and biodegradable materials for challenging storage applications.  

If you require a team of specialists to help move your packaging portfolio in line with new regulations and stay ahead of the market, capitalising on the increased revenue predicted by the EU, contact us at 

Where to from here?

The proposed EU-wide rules for packaging present a significant opportunity for packaging manufacturers to embrace sustainability, reduce waste, and contribute to the circular economy. By acting now, the packaging industry can be a key player in mitigating environmental challenges, meeting consumer demands, and securing a climate-neutral future for Europe. 

Tim Hartley | +44 (0)1480 302700 | LinkedIn: Tim

Tim Hartley is a consultant at 42 Technology with experience in conceptual design, development, testing and prototyping. He has worked on many different products from diverse industries. These range from surgical devices to food and beverage handling systems.  42T believes in drawing in knowledge from other sectors to achieve client goals.

At 42T we have a team of expert designers and engineers with a wealth of across different industries, from concept design to manufacturing line optimisation. 

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