Finally, the EU Council has approved the final version of the EU Packaging Regulation (PPWR).

Will everything be easier for manufacturers of packaging and packaged products from now on? Does the dream of a harmonized labelling requirement for all European markets come true? Sounds too good to be true! The regulatory landscape is complex. Addressing 27 different waste systems, waste sorting streams and numerous labelling and information requirements proofs to be quite a challenge.

Let’s rewind a bit: it all started with the vision of a low-CO2, circular future in Europe. The regulation pursues two major goals: 1. the reduction of packaging waste (prevention) and 2. the promotion of reuse & refilling as well as recycling.

However, the regulation intends to do more than just set targets for specific quotas and quantities. It pursues the overarching goal of creating a culture of conscious consumption and product design, becoming less dependent on primary raw materials from outside the EU and reducing our ecological footprint under the umbrella of the old Commission’s Green Deal. Thus, the regulation complements the Ecodesign Regulation (ESPR) adopted in summer 2024 for the product category “packaging” and is a logical addition to the legislative texts already adopted, such as the “Right to Repair” Directive, EmpCo, EUDR, CSRD, etc. and other regulations still in the pipeline.

Despite previous efforts, which were mainly reflected in national legislation, the amount of packaging waste in Europe grew steadily to almost 190 kg per capita/year by 2021; an increase of 20 percent within ten years (source: Eurostat). An unwelcome side effect: there are now 27 implementing national regulations in the European Member States, a wide variety of waste sorting streams and EPR systems and organizations, sanctions and deposit systems. On January 1, 2025, new labelling obligations will come into force in Spain, Portugal and Greece, adding to the numerous requirements already in place in the EU.

Back to the initial question: As manufacturers supplying transport packaging, service packaging or sales packaging, whether as single-use or reusable packaging, can with expect harmonization of labelling and information requirements?

As expected, it will probably not be quite as simple. A harmonized label for material identification will not applicable until 2027/2028 and national regulations will continue to apply at least until then. Substances of concern in packaging must be labelled using digital labelling technologies. Member States can decide to maintain or introduce national sustainability and information requirements, provided they do not conflict with the regulation.

Close monitoring is needed to keep track of the large number of legal acts announced. They are intended to specify the “how”, “where” and “how much” of the individual requirements. A solid basis for implementation will only be presented in stages over the coming years. Questions regarding details on the following information and labelling requirements still need to be answered:

• Label with information on the proportion of recycled / bio-based plastics
• Harmonized pictogram indicating the material composition including the method for composite packaging
• Colour coding for packaging subject to deposit and return systems
• Method for indicating substances of concern in packaging
• Labelling of reusable packaging with information on the local, national or EU-wide reuse system via QR code.

In addition, further specifications have been announced, for example regarding the assessment of recyclability for classification into performance levels (design for recycling & recycling-at-scale) or the calculation of the proportion of recycled material from consumer plastic waste. Still, Member States can continue to individually design measures such as the level of EPR fees or the labelling of packaging subject to a national or regional deposit and return system. Some labelling options will also be harmonized, such as digital data carriers that can be used to pass on sorting information to the consumer or indicating compliance with the EPR obligations. This shows that there will continue to be a wide range of implementation options, particularly about the information and labelling requirements for products and their packaging.

In summary, it can be said that economic operators will gain a little more legal certainty as certain labelling and information requirements will be harmonized. The regulation gives us an idea of what is to come. The standardization of performance characteristics regarding recyclability for the adjustment of eco-modelled EPR fees, labelling and information obligations and other requirements for packaging composition and design, reduce compliance risks and make it possible to provide uniform packaging designs in different markets of the EU Member States. The optional and mandatory provision of certain information via digital data carriers facilitates the provision of information together with information from other regulations that affect the packaged product too. However, the PPWR also introduces many new obligations and prohibitions, such as restrictions on environmental claims and substances used in packaging materials. As the PPWR covers the entire packaging life cycle, obligations should be considered already at the design stage of the packaging on order to implement a robust, time- and money-saving management set-up along the value chain for the final product and its packaging.

Do you need support in implementing the new packaging requirements? We are happy to help you address data, design and process requirements, e.g. as part of a…

• “Packaging mapping”: Which information and labelling requirements are relevant, and which data must be available to be able to ensure compliance with the requirements (e.g. on materials, disposal solutions, etc.)?
• “Artwork process”: Which adjustments should you make now when designing your packaging and “what” must be labelled “how” in the future, e.g. reshaping the design process allowing adaptation to upcoming requirements?
• “Artwork check”: Is your packaging labelling artwork currently compliant? Is all information available? Is a process implemented with which adjustments can be made in a timely manner?
• “Green Claims Mapping”: Are environmental claims currently being used? If so, is the data required to verify the claims available? Is a decision-making process defined and implemented?
• “Environmental communication strategy”: How can requirements be strategically integrated into the value creation process?
• “Monitoring solution”: How can the complex monitoring of legal changes and specifications be set up efficiently? Implement NovaLoop oOKAPI as a SaaS solution.

Please reach out to us for more information and to learn how we can support your team.