The first rules of the EU Packaging and Packaging Waste Regulation (PPWR) were implemented across the EU on Wednesday, August 12. The regulation, which replaces a 1994 directive, applies to all packaging placed on the EU market, whether empty or full, and regardless of the material used.
The regulation applies to packaging produced within the EU as well as packaging imported from third countries. Under the new rules, all packaging must be designed for material recycling and capable of being separately collected, sorted, and recycled on a large scale.
The PPWR aims to reduce packaging waste, increase recycling, and protect consumers from harmful chemicals. The regulation sets strict limits on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging. PFAS are used in food packaging to provide water and oil resistance, including in takeaway containers, fast-food packaging, microwave popcorn bags, baking paper, and pizza boxes. Food packaging containing PFAS above specified limits will no longer be allowed on the EU market, though existing stocks of packaging containing PFAS may still be used.
The limit values for PFAS are so low that intentional use is virtually excluded.
Waste reduction and packaging limits
The EU aims to reduce packaging waste per capita by 5 percent by 2030 and 10 percent by 2035, with a target of 15 percent by 2040, using 2018 as a baseline. In 2023, the average amount of packaging waste generated per inhabitant in the EU was 177.8 kilograms.
Average packaging waste generated per inhabitant in the EU in 2023.
For transport and shipping packaging, a maximum void space of 50 percent is mandated. The Federal Association of E-Commerce and Mail Order Germany (BEVH) noted that the 50 percent empty space limit is difficult to maintain for bulky items like table fans.
From 2030, several new mandates will take effect. Most obligations regarding packaging recyclability, reuse targets, and reduction of plastic use will become effective from 2030. This includes restrictions on certain small single-use plastic packaging formats used in hotels and restaurants, as well as a prohibition on certain single-use plastic packaging for unprocessed fresh fruit and vegetables. Very lightweight plastic bags will also be prohibited, unless necessary for hygiene reasons or for loose food items to combat food waste. Additionally, all new plastic packaging must include a certain percentage of recycled plastic starting in 2030.
The regulation includes exemptions for certain sales packaging, such as those made of light wood, cork, textile, rubber, ceramics, porcelain, or wax.
Industry and regulatory response
EU commissioner Jessika Roswall, for Environment, Water Resilience and a Competitive Circular Economy, stated the regulation is an investment in Europe's future. Philip Heldt, a consultant for resource protection at the Consumer Association of North Rhine-Westphalia (Verbraucherzentrale NRW), praised the move to promote reusable glass systems.
From a commercial perspective, the German-Italian Chamber of Commerce stated that national implementation regulations and specific sanction rules are currently still missing. Michael Waasner, President of the IHK for Upper Franconia, warned that companies must decide on new packaging today because they cannot wait for legal acts that will only come tomorrow.
That is too bulky in terms of complexity.
Christoph Petri of the DIHK also suggested pausing the implementation due to legal gray areas and the fact that it is uncharted territory for many companies. Meanwhile, the German Hotel Association (IHA) and the Dehoga Federal Association stated that many gastronomic businesses have already adapted their processes and established reusable systems due to the reusable offer obligation in Germany since 2023.
The regulation also requires companies to appoint an authorized representative in the target country for shipping packaging. From 2028, a harmonized labeling system to facilitate correct separation of packaging waste by consumers in EU countries will be implemented.
Zhou Mi, a researcher at the Chinese Academy of International Trade and Economic Cooperation, stated that the new unified EU framework prevents companies from seeking entry points with lenient standards.
