The European Union (EU) is taking a massive step toward a circular economy with the Packaging and Packaging Waste Regulation (PPWR), which fundamentally changes the rules for packaging and packaging waste. This regulation covers all packaging and packaging waste on the market, regardless of the material type, and will enter into general application as of August 12, 2026. However, the effective dates for certain specific provisions within the regulation may vary.
Core Sustainability Requirements Under PPWR
To transform the packaging sector into a greener structure, the new regulation introduces strict rules under the following main headings:
- Labeling and Environmental Claims: Labeling rules, including recycling symbols and environmental claims on packaging, are being brought under strict supervision.
- Substance Restrictions: The use of certain heavy metals and substances of concern in packaging components is being restricted. Specifically, the use of PFAS (per- and polyfluoroalkyl substances) in food-contact materials is being limited.
- Recyclability and Recycled Content: It will be mandatory for all packaging to be recyclable by 2030. Additionally, minimum recycled content targets are being established for plastic packaging.
- Bio-based Plastics: Sustainability criteria and targets are defined to increase the use of bio-based raw materials in plastic packaging.
- Compostable Packaging: While the definition of “compostable packaging” is being clarified, the regulation specifies which packaging formats must mandatorily be compostable.
- Packaging Minimization: Packaging must be designed at a minimum level in terms of weight, shape, and volume, without compromising its function.
- Reuse: Criteria for reusable packaging and specific usage targets for these containers are being established.
A “Harmonized” Era for Recycling Symbols
The EU aims to end the confusion caused by differing rules among member states. Pursuant to PPWR Article 12.1, it will be mandatory for packaging placed on the market to carry a harmonized label regarding material composition to facilitate the waste sorting process for consumers.
In current practice, recycling symbols vary according to national laws. For example, while France is the only EU country that mandates the use of specific symbols (such as the Triman logo), countries like Italy and Spain require material information but do not impose a specific symbol. With the new regulation, this fragmented structure will be replaced by a uniform system.
What Awaits Brand Owners?
All brand owners who use packaging for their products—especially those in the cosmetics sector—must complete the compliance process and prepare a Declaration of Conformity (DoC). It is critical for businesses to take the following steps during the preparation phase:
- Compliance Audit: Existing packaging should be audited for compliance with the new standards.
- Manufacturer Registrations: It should be verified that packaging manufacturers are registered in the relevant member states.
- Supply Chain Analysis: Actors in the supply chain must be identified, and responsibilities, including Extended Producer Responsibility (EPR), must be clarified.
- Up-to-date Monitoring: Possible updates, amendments, or postponements in the legislation must be closely monitored.