PPWR: From regulation to reality

The PPWR has now been generally applicable across the European Union (EU) for just over two months. Has everything changed in the packaging industry since 12 August? Of course not. But things are moving, particularly where packaging is developed and specified, documentation is prepared and companies work with customers and suppliers.

The EU’s Packaging and Packaging Waste Regulation (PPWR) has arrived in day-to-day business, just without a big bang. Packaging companies are now facing some very practical questions: Do we have all the information we need about our materials? What evidence do our suppliers need to provide? What data are customers asking for? And how do we develop packaging today when some of the requirements it will need to meet in the future have yet to be defined in full? That is where the industry finds itself just over two months into the PPWR.

For companies producing food packaging, per- and polyfluoroalkyl substances (PFAS) have become a very real issue. The relevant PPWR limits now apply to food-contact packaging. For manufacturers of films, trays or coatings, that means taking a close look at what their materials contain and what documentation is available to support this.

For other areas, the picture is less clear-cut. Recyclability is already part of the equation, while the harmonised design-for-recycling criteria will come into play at a later stage.

So for now, the packaging industry finds itself somewhere between “already applies” and “still to come”.

It may sound like a simple question. But it isn’t. Under the PPWR, the information behind a packaging solution is becoming increasingly important. Material composition, individual components, recycled content and the relevant documentation all need to be available and reliable.

Recycled content is a good example of how much is still evolving. The European Commission is currently working on rules for calculating and verifying recycled content in plastic packaging, as well as sustainability criteria for recycling processes.

For packaging companies, much therefore depends on how well information flows between suppliers and customers. What data does the material supplier provide? What can be documented in-house? And what information does the customer expect in return?

The PPWR is no longer a matter for Regulatory Affairs alone. Development, procurement, quality and sales all have a seat at the table.

That is probably one of the biggest challenges at the moment. The PPWR applies, but many of the details are still being worked out. In a number of areas, the EU still needs to specify exactly how the requirements will work in practice. And these are not minor details. The European Commission, for example, is still developing specific rules on packaging labelling, including labels for waste sorting as well as for reusable packaging and packaging containing recycled or bio-based content.

Anyone developing a new packaging solution today therefore needs to think beyond the next production run. After all, many packaging solutions are designed to remain on the market for several years. At the same time, there is little point in anticipating requirements whose final details have yet to be defined.

Not the entire packaging world. But they have certainly brought some new questions into day-to-day business. What data do we already have, and what is still missing? What information do suppliers need to provide? What will customers ask for in future? And which developments from Brussels do companies need to keep an eye on?

The PPWR may not yet be visible on every pack. But it increasingly has a seat at the development table.