Frequently asked questions about the PPWR

1. What is the PPWR?

The Packaging and Packaging Waste Regulation (PPWR) is a new packaging regulation that the European Commission wants to introduce. The proposal for the PPWR was published in November 2022 and it is still being negotiated by EU member states.

The PPWR will be the successor to the current European packaging directive, the Packaging and Packaging Waste Directive from 1994. Member states could transpose this directive into national legislation in their own way; the Netherlands did so in the 2014 Packaging Management Decree.

If passed, the PPWR will be a European law that will be effective in all EU countries (taking into account any lead time mentioned in the regulation - 12 months for now). This means a level playing field for all member states. National laws should be adjusted accordingly.

2. Why is the European Commission proposing the PPWR? 

The current European Packaging Directive has failed to address the negative environmental impacts of packaging, according to the European Commission. The EC says too much packaging is produced, there is too much empty space in packaging, packaging is not sufficiently recyclable, not enough packaging is reused and not enough recyclate is used in new packaging. There are also too many differences in the way the Packaging Directive has been implemented by member states, which has led to an uneven playing field.

Although recycling rates have increased in the European Union, the amount of waste generated is growing faster than actual recycling, according to the European Commission. The amount of waste - mainly from single-use packaging - increased by more than 20% over the past decade. In line with the European Green Deal, Europe wants to tackle packaging and waste management to achieve a clean, sustainable and circular economy.

3. When will the PPWR be effective and what does the timeline look like?

On 30 November 2022, the European Commission released the PPWR as a proposal. From then on, it became a file in the European Parliament and in the Council of the European Union. The proposal is expected to be voted on at the end of this year (2023), after which negotiations between the Parliament, the Council and the Commission will start (expected in early/mid 2024). Thereafter, the PPWR will be adopted, signed and published by the Parliament and the Council (expected in late 2024/early 2025). The PPWR measures will take effect 12 months after publication.

4. What is the purpose of the PPWR? 

The aim of the PPWR is twofold. Firstly, the European Commission wants to reduce the environmental impact of packaging, by reducing the amount of packaging entering the market, preventing packaging waste, increasing efforts to reuse and refill packaging, high-quality recycling, increased ability to use recycled plastic, better recyclable packaging and detailed packaging administration. Secondly, the European Commission wants an efficient functioning of the internal market (EU), by harmonising legislation to create a level playing field.

5. How does the PPWR relate to the Single Use Plastics (SUP) Directive?

The PPWR is a regulation that has yet to come into force. The SUP-Directive is a directive that came into force in 2021. Since then, the SUP measures have been phased in by member states. Eventually, both laws co-exist and producers and importers of packaged products have to comply with both laws. The PPWR applies to all packaging, while the SUP directive covers single-use plastic packaging. The approach of the PPWR and SUP directive are fairly similar: the aim is to prevent as much packaging waste as possible and reuse or recycle where it arises.

6. What will packaging placed on the European market soon have to comply with?

With the PPWR, the European Commission is setting sustainability requirements for packaging. These become the new so-called Essential Requirements (in Dutch: Essentiele Eisen). All packaging placed on the market must meet these requirements. The PPWR proposal covers the following issues (in a nutshell):

Harmful and hazardous substances in packaging
The sum of concentrations of lead, cadmium, mercury and hexavalent chromium in the packaging or packaging components must not exceed 100 mg/kg;

Recyclable packaging
All packaging must be highly recyclable by 2030. How this will be measured is still to be determined by the European Commission.

Recycled content
The use of recyclate in new products and packaging must increase. The minimum content of recycled content in plastic packaging will go up step by step in the coming years.

Compostable packaging
Two years after the introduction of the PPWR - according to the European Commission's proposal - tea bags, coffee pads and coffee cups, labels on fruit and vegetables and very light plastic carrier bags must be compostable.

Minimising packaging
Packaging should be as light as possible and not contain unnecessary space/air.

Reusable or refillable packaging
More reusable and refillable packaging should be used in certain product groups. These include: large household appliances, transport, e-commerce, hot and cold drinks (take-away), beer and wine.

Banned
In some environments (hospitality, hotels and retail), the use of certain packaging is banned (see also question 7).

Declaration of conformity
A declaration of conformity must be made by companies who put packaging on the European market, demonstrating that the packaging meets the above requirements. The declaration of conformity must be kept for 10 years.

7. Which packaging will eventually be banned by the PPWR?

A number of packaging types will be banned for certain purposes by 2030:

Single-use plastic wrappers to group individual sales units;
Single-use plastic packaging for fresh fruit/vegetables under 1.5 kg;
Single-use plastic packaging for drinks and food so-called 'eat-in' establishments (catering);
Single-use packaging for flavourings, preserves, sauces, coffee creamers, sugar and condiments (catering industry);
Certain one-way packaging in hotels, such as hygiene and toiletries and cosmetics.8. What does the PPWR say about standardisation for disposal instruction on packaging in Europe and from when would that start to apply?

When the PPWR is published (expected in late 2024/early 2025), the standardised logos should be available within 18 months (mid-2026). Use will then become mandatory 42 months after publication (expected mid-2028).

9. What is expected of me as a company with regard to the
packaging administration?

Companies are expected to document in increasing detail and in a demonstrable way why they have designed packaging the way they have. The materials and components it contains must also be recorded. Attention is paid to optimising reusability of the packaging (re-filling by the producer/importer), recyclability and use of recycled materials.

The number of packaging categories to be reported on is likely to increase significantly with the PPWR. In doing so, it is no longer always sufficient to distinguish by main material (glass, paper and cardboard, plastic, etc.); increasingly, distinctions will be made by material type (PET, PP, PE) or colour (transparent, colourless, blue, multicolour).

A recyclability score will be attached to the various categories. The fees paid by companies to the extended producer responsibility organisations (in Dutch: UPV) will be differentiated accordingly. This also applies to the application of recycled material.10. As a company, what can I do in advance to prepare for the PPWR?

Although the rules on packaging administration are not yet effective immediately, it is already good to start documenting properties of your packaging in more detail. Important items are from which (sub)materials the different parts of the packaging are made, an estimate of how recyclable the packaging is and how much recycled material you currently already use (for plastic packaging).

The recycled material should be 'post-consumer'; that is, the waste does not originate from a production environment, but has already been put on the market once and collected as waste. It is advisable to research which recyclers can provide you with this material.

Please note that this page contains a summary of the PPWR and is not exhaustive. No rights can be derived from it.