PPWR Series: Recyclable Packaging
Why you should be acting now to design recyclable packaging for your products
Replacing the current Packaging and Packaging Waste Directive, one of the central pillars of the Packaging and Packaging Waste Regulation (Regulation (EU) No. 2025/40) is the requirement for all packaging to be recyclable by 2030. This will introduce clear, enforceable obligations for businesses across the packaging supply chain as well as increase consumer expectation in this area.
In this article, we explore how the PPWR introduces obligations for recyclable packaging, what it means for producers and importers, and how businesses can start preparing now.
According to the Eurostat website*, in 2021, the EU generated a staggering 84 million tonnes of packaging waste. That is 188.7 kg packaging waste per inhabitant. But only a fraction of this waste is recycled. For example, the same 2021 data reports that each person living in the EU generated an average of 35.9 kg of plastic packaging waste but out of this, only 14.2 kg were recycled.
Recyclability concept
So what is the European Commission doing to control the amount of packaging ending up as waste? Within the PPWR, obligations will be introduced to ensure that packaging will not only be theoretically recyclable but that it can also be recycled on a practical basis (i.e. via material recycling at scale). This will mean that packaging must be:
Designed for recycling based on design for recycling (DfR) criteria.
Part of an effective collection, sorting, and recycling system, proven through practical recyclability assessments.
Combination of the two criteria are considered to mean that the material is ‘recyclable’. Each criteria will require additional legislation to be published in order to further define what DfR looks like and what will constitute ‘recycled at scale’ and the PPWR also introduces deadlines for legislators to act in this regard.
In addition the PPWR will require the minimisation of the use of substance of concerns known to have impact on packaging reuse and recycling - For further information on Substances of Concerns, please read our article ‘Substances of Concern in Packaging: Why You Need to Pay Attention’
Phased deadlines
The European Commission, Parliament and Council recognise that such sweeping changes to packaging cannot be made overnight, nor are the necessary infrastructures in place to recycle all materials at scale. Therefore, the final PPWR text contains a number of phased deadlines and additional measures before the ultimate aim can be achieved.
Note: The following deadlines are those set in the PPWR but could be subject to change should the additional legislation mentioned above be delayed.
To prove ‘designed for recycling (DfR)’ principles, packaging will be classified into performance grades A to C or not recyclable.
From 1 January 2030
From 2030, only grades A-C will be permitted to be placed on the market.
From Jan 2035
Packaging must additionally ‘pass’ the new recycled at scale assessment to be placed on the market.
From Jan 2038
Packaging should be at least grade B to be placed on the market.
These measures will require businesses to:
Evaluate the recyclability of their packaging to move towards the highest grades.
Redesign packaging that does not meet the required performance level.
Despite the current uncertainty over finalised DfR principles and methodologies, at Bloom we strongly recommend that companies start to audit the packaging they are using and, particularly in the case of new product development, to consider the decisions that can be made ahead of time.
How can we help?
Audit: We offer a packaging audit service where we highlight any potential issues under PPWR and opportunities to improve, which may include shifting towards mono-materials, eliminating problematic formats, and reducing unnecessary components (we’ll also cover the topic of packaging minimisation later in the series). Often we find that companies simply don’t have access to the information they need and so a key feature of our audit is to examine the information available from your supplier and to advise on any measures needed to better understand your compliance levels. We can also assist in helping you to obtain the information you need.
Packaging design strategy: If you don’t yet have a packaging design strategy or set of principles, we’d be happy to support you in developing one to help prepare your business ahead of the publication of finalised Design for Recycling (DfR) requirements. If you already have established principles, we can provide an independent review and offer insights based on our industry-wide observations to help you benchmark and strengthen your approach.
Keeping informed: As the delegated and implementing acts defining DfR and methodologies become available, we will be working closely with our customers to adapt to the finalised requirements.
Get in touch to learn more about how we can support your PPWR compliance journey.
In our next article we’ll be exploring the requirement to incorporate recycled content into plastic packaging. We release articles from this series every Wednesday but follow our LinkedIn page to receive notification when the article is available!
* https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20231019-1
Amanda Isom