In this article Michael Nieuwesteeg, Helen Crowe and Serra Anker from NVC take a look at the upcoming legal requirements, standards and legislation for the Packaging and Packaging Waste Regulation (PPWR) and examine the opportunities and threats for the food industry.
The Packaging and Packaging Waste Regulation (PPWR) covers all packaging and packaging waste on the European market, including all materials and packaging in the commercial, household, industrial and other sectors. The food industry accounts for an estimated 2/3 of all packaged products. It is estimated that the world packs a total of over 320,000 products every second. Every second, the same number of emptied packs enters the waste stage. *(1) How is Europe tackling this?
The first European legislation on packaging and the environment dates back to the year 1994. In December of that year, Directive 94/62/EC on packaging and packaging waste (the PPWD) was introduced. Over 30 years later (on 11 February 2025 to be precise), Regulation 2025/40 on packaging and packaging waste came into force: the PPWR.
Like the PPWD, the PPWR regulates what types of packaging may be placed on the EU market, as well as measures for the management and prevention of packaging waste. The general application date of the PPWR is 18 months after its entry into force, i.e. 11 August 2026. The PPWR has been given a larger scope than the PPWD.
For example, one now also mentions greenhouse gas emissions and water use:
“The PPWR establishes a new set of requirements in line with Europe’s waste rules that cover the entire packaging life cycle – from product design to waste handling. By 2030, the measures are expected to significantly reduce greenhouse gas emissions and water use, while preventing and reducing the adverse impacts of packaging and packaging waste on the environment and human health.” *(2)
While the PPWD will be repealed 18 months after the PPWR comes into force, some provisions will continue to apply after that date.
Requirements: Micro, Macro and Misty
At NVC Packaging Centre, we look in particular at the legislative requirements for individual businesses (after all, businesses are our association members). We use a sort of filter to help companies distinguish three types of requirements: Micro, Macro and Misty.
Micro-requirements are requirements that every pack must meet. Compare it to the requirement of a maximum speed for motorists combined with enforcement by a speed camera. Any car speeding is flashed and automatically goes on fine via the license plate number – and enforced by the Central Judicial Collection Agency.
In terms of micro requirements, the PPWR is mainly about the essential requirements. This was also the case in the PPWD. The European Commission puts it as follows:
“All packaging must comply with essential requirements related to its manufacturing, composition, and reusable or recoverable nature.”
Macro requirements have an aggregate character. For example, a requirement could be that 95% of motorists on a given route should not drive faster than the maximum speed limit. In the PPWD and PPWR context, many macro requirements come to mind, for example on recycling rates. They can be identified by the basic formulation: “so many % of packaging placed on the market in this region must be recycled in that year”.
The basic idea is that the rules aim to “minimise the quantities of packaging and waste generated while lowering the use of primary raw materials and fostering the transition to a circular, sustainable and competitive economy.”
The idea is that a stricter regulation (PPWR) brings more here than the somewhat looser Directive (PPWD). As the European Commission puts it, “by replacing the PPWD, the new regulation harmonises national measures further – strengthening the internal market – notably for secondary raw materials, manufacturing, recycling and reuse.” *(3)
What is interesting about macro requirements is that they first intervene at the national (member state) level. If a member state fails to meet the set macro requirement, any enforcement on the part of the Commission comes years later. For example, the Commission recently started infringement proceedings on the failure of certain member states to meet recycling rates of more than five years ago.
Misty requirements are – the word says it all – foggy. To draw the parallel with the speed limit again: the legislator could also use the flash photos to inform motorists that it would be better to drive an electric vehicle. And preferably not a Tesla. Or Chinese BYD. But no Volkswagen ID.4 either, unless… In the packaging dossier, something similar applies to the definition of the much-discussed Circular Economy.
This concept is not adequately defined anywhere at European level. In this context, the Dutch government talks about “an economy without unnecessary wastage (verspilling)”.*(4) So with necessary wastage…? In the PPWR, misty claims are recognised by phrases such as “the aim is…” or “inter alia by…”.
Upcoming legal requirements inventoried
As a food manufacturer, it is important to be aware, with or without the help of the NVC ‘Micro-Macro-Misty filter’, of the legal requirements in terms of PPWR. Below, we provide a brief (but not exhaustive) overview. The PPWR aims to:
- · Prevent and reduce packaging waste, including through more reuse and refill systems.
- · Make all packaging on the EU market recyclable in an economically viable way by 2030.
- · Safely increase the use of recycled plastics in packaging.
- · Decrease the use of virgin materials in packaging and put the sector on track to climate neutrality by 2050.
Specific new rules compared to the PPWD concern:
- · Restrictions on certain single-use plastics, such as pre-packed fruit and veg weighing less than 1.5 kg and individual portions of condiments, sauces, and sugar in hotels, bars and restaurants.
- · Minimising the weight and volume of packaging and avoiding unnecessary packaging.
- · 2030 and 2040 targets for a minimum percentage of recycled content in packaging.
- · A requirement for take-away businesses to offer customers the option to bring their own containers at no extra cost.
- · Minimising the use of so-called substances of concern, including restrictions on packaging containing per- and polyfluoroalkyl substances (PFAS) if they exceed certain thresholds.
(Standards) development to essential requirements
As mentioned, this concerns in particular the essential requirements when it comes to micro requirements for packaging. A report from the year 2020 *(5) indicates how and where the Commission intends to achieve further developments here.
- · In addition to the requirement to be reusable or recyclable, the packaging shall be designed not to exceed the minimum volume and weight necessary for the functionality. This was already the case, but the Commission wants to make consumer preferences or marketing less guiding when setting the legal criteria.
- · The European Commission wants to amend European standard EN 13428 *(6) “to refine the critical areas that limit further reductions in the volume or weight of packaging and amend Annex II to make the use of the Standard compulsory, or include the relevant content in the Annex if it is not possible to mandate the use of Standards.”
- · Producers must report to a central registry on the relationship between the volume, weight and planar area ratios of packaging to product.
- · Packaging must not exceed any of a set of threshold ratios of packaging to product established in terms of volume, weight and surface area. Which thresholds these are remains foggy.
- · For the existing list of hazardous substances (mentioned in Annex II), it is stated that there is a desire to maintain it, but to rely more on REACH, and FCM (food contact materials) regulation in enforcement to adequately address the use of other hazardous substances in packaging.
- · Include specific requirements to phase out the use of SVHC (Substances of Very High Concern) in packaging through reference to Annex XIV of REACH.
- · All reusable packaging must be recyclable, unless there is a demonstrable robust case for an exemption (incidentally, this was in principle already the case under the PPWD’s essential requirements).
- · Develop guidelines for effective reuse systems based on a European standard.
- · Mandate reuse for some transport packaging.
- · Develop a new EN standard establishing a mandatory process to be followed to assess the potential to include recycled content.
- · Implement recycled content targets for specific formats.
- · Adapt standard EN 13432 to further specify the concepts of ‘compostable’ and ‘biodegradable’ packaging.
- · Modify standard EN 13432 to ensure that actual composting conditions (home composting, industrial composting, aerobic composting, anaerobic composting) are taken into account.
- · Labelling packaging as reusable or recyclable, as well as indicating compostability of packaging.
- · Labelling E-commerce packaging with stickers to highlight to consumers to report unnecessary void space to authorities in order to support enforcement.
- · The European Commission is to conduct a review in 2025 to assess the feasibility of digital watermarking technology * (7) with a view to to adopt a legal requirement for its use. A well-known frontrunner in this is the socalled Holy Grail marking technique. But block-chain projects could also contribute here.
Legislation related to the PPWR
The PPWR actively refers to other pieces of legislation at European level. These already exist or are under development. Below we list the most important ones.
- · The Commission will adopt implementing acts for marking and identification.
- · The rules for reporting and subsequent enforcement are expanded.
These include:
- · Directive standardising and rationalising reports on the implementation of certain Directives relating to the environment (such as the PPWR, but also the CSRD for reporting on sustainable development).
- · Decision concerning questionnaires for Member States’ reports on the implementation of certain Directives in the waste sector.
- · Decision establishing the formats relating to the database system and implementing decision amending this decision.
- · Implementing decision laying down the methodology for the calculation of the annual consumption of lightweight plastic carrier bags.
Work in progress – what to do?
It is clear from the above, that many of the legal requirements that directly impact individual companies and their packaging, are in fact still only defined to a limited extent. This is one of the reasons why the business community actually does not yet know where it stands, and why the European congressional and advisory mill is running at full speed.
The European Commission puts it this way:
“The requirements in the PPWR will be further specified in harmonised standards for packaging, guidelines, and subsequent adoption of implementing and delegated acts. Further information on the implementation of the PPWR will be published soon.” *(8)
This relative regulatory vacuum is currently filled by numerous national, regional or private organisations, which come up with their own rules and guidelines for packaging. In the Netherlands, this is notably Stichting Verpact, where they have developed six different Recycle Checks in combination with a fee modulation structure.
The Recycle Checks are constantly being tightened and updated. For plastic packaging, a set of rules has been devised that allows companies to get a discount on their mandatory contribution to the foundation (six different elements, each accounting for €0.10/kg on a total rate of €1.35/kg). In case of innovation, the Verpact Foundation offers ‘tailor-made solutions’. *(9)
What to do now as a food manufacturer?
How to unbox the PPWR for your company, so to speak? In any case, it is important to stay up to date and thereby keep or bring the knowledge and skills of employees to an adequate level. Information service MERGE (the NVC Members-only Environmental Regulations Guide) is an effective tool for this. It is often combined with the NVC Workshop Sustainable Innovation in Packaging.
When updating existing and starting new packaging projects, it is best to focus on the micro-requirements, taking into account the macro- and misty-requirements expressed at European, national or private level. As a company, you are ultimately responsible for your product in your packaging.
Last but not least, it is important to keep international harmonisation in sight. Most likely, a company depends on more than just the Dutch market (the import and export of foodstuffs, the purchase of marketed food packaging, the collection and processing of the resulting emptied packaging anywhere).
In this context, for a sustainable future of any food manufacturer, the top priority is to monitor and maintain in-house consistency of packaging policy. In other words, your packaging dossier should at least be able to serve the entire European market – and preferably also be a good step towards the UK Recyclability Assessment Methodology (RAM) legislation*(10) on the same topic.
Intracompany consistency means that you do not have to start from scratch for each country to set up your organisation around packaging. More than ever, the rule is: think before you start. But start now.
If you liked this story, you might also enjoy:
The ultimate guide to the Packaging and Packaging Waste Regulation in 2025
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Everything you need to know about global packaging sustainability regulation in 2025
The key to increasing the use of reusable packaging in supermarkets
1: * The Packaging Up-cyclability Materials Accelerator (PUMA) Manifesto, EAN/ISBN 9789074862066, dated 6 May 2020.
2: * EU rules on packaging and packaging waste, including design and waste management: https://environment.ec.europa.eu/topics/waste-andrecycling/packaging-waste_en
3: * EU rules on packaging and packaging waste, including design and waste management, https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
4: * NVC views on government vision of Circular Economy dated 14 December 2022: https://www.nvc.nl/userfiles/files/NVC%20ZIENSWIJZE%20%20op%20AVV%20Tarieven%20Stichting%20Afvalfonds%20Verpakkingen%20-%20WEB%20sec.pdf
5: * Effectiveness of the essential requirements for packaging and packaging waste and proposals for reinforcement, https://op.europa.eu/en/publication-detail/-/publication/05a3dace-8378-11ea-bf12-01aa75ed71a1
6: * EN 13428 Packaging – Requirements specific to manufacturing and composition – Prevention by source reduction: https://standards.cencenelec. eu/dyn/www/f?p=CEN:110:0::::FSP_PROJECT,FSP_ORG_ID:22859,6242&cs =11541DF04CAD59C73601A5595881E67AA
7*: Digital watermarks are invisible, optical codes that can be integrated into packaging. They are similar to an invisible barcode. They are detectable only with special cameras added to sorting lines, as well as barcode scanners and smartphones.
8*: European Commission website dated 28 May 2025, https://environment. ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
9*: Verpact Foundation, ‘Tailor-made solutions for innovations…’, https://www.verpact.nl/en/fee-modulation-plastic-20
10*: Recyclability assessment methodology: how to assess your packaging waste, https://www.gov.uk/guidance/recycling-assessment-methodology-howto-assess-your-packaging-waste
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