PPWR: Every Design Decision Becomes a Compliance Decision

The new EU Packaging and Packaging Waste Regulation (PPWR) has far-reaching implications for the packaging industry. After examining the role of data and packaging information in the first part of our series, we now turn our attention to the packaging itself: What does the regulation mean for packaging development, material selection and design?

Developing packaging has always been a balancing act. Product protection, material use, machinability, logistics, marketing and costs all had to be carefully aligned. With the PPWR, another requirement comes into play. While the regulation does not prescribe specific materials, it does define requirements that packaging must meet in the future. As a result, every design decision now has an additional regulatory dimension.

The key question is therefore no longer simply whether a package fulfils its technical function. It is equally important whether it complies with requirements for recyclability, recycled content and material efficiency. One key date is 12 August 2026, when most PPWR obligations and requirements become applicable. The regulation itself has already been in force since 11 February 2025.

The regulation aims to align packaging more closely with the principles of the circular economy. As a result, companies must already consider during the development phase how materials can later be sorted, recycled and returned to the material cycle.

Packaging development is therefore becoming increasingly interdisciplinary. Structural design, material development and product protection remain core tasks, but they are increasingly complemented by sustainability and regulatory requirements.

Design for Recycling represents a shift in the way new packaging is developed. The objective is to design packaging so that it can be collected, sorted and recycled as efficiently as possible after use. This means looking at the package as a whole. Materials, labels, colours, adhesives and closures all influence how well packaging performs in recycling processes.

As a result, seemingly small details can determine recyclability. Material combinations that are difficult to separate, full-body sleeves or certain coatings may complicate sorting. At the same time, packaging must continue to fulfil its primary function by protecting products, ensuring shelf life and performing reliably on modern production lines.

In short, Design for Recycling means considering technical performance and circularity together from the earliest stages of development.

The PPWR also introduces requirements for reusable packaging. These include participation in functioning return systems and specific labelling requirements for reusable packaging. From 2030 onwards, companies must meet defined reuse and refill targets in several sectors, including transport packaging, e-commerce and food service. Reusable packaging will also need to carry labels or digital identifiers, such as QR codes, providing information about its reusability.

Certain exemptions apply to the reuse targets, for example for dangerous goods packaging, specific food contact packaging, pallet wrapping and strapping. Small and medium-sized enterprises may also qualify for exemptions under certain conditions.

The PPWR makes existing trade-offs more visible. Packaging must protect its contents—such as food—provide reliable barriers against oxygen or moisture, run efficiently on packaging machinery and at the same time be as recyclable as possible. Companies therefore need to balance technical performance, regulatory compliance and resource efficiency simultaneously.

These requirements often come into direct conflict, particularly in demanding applications. High-performance barrier solutions frequently rely on material combinations that are more difficult to recycle. As a result, packaging development is increasingly becoming a holistic process in which no single requirement can be considered in isolation.

Mono-material packaging is regarded as an important building block for improving recyclability. Packaging made from as few different materials as possible can generally be sorted and recycled more efficiently than complex multi-material structures. High-performance mono-material films are already available for various applications, including dry goods, cosmetics and e-commerce packaging. However, they are not yet suitable for every application requiring very high barrier performance to ensure product protection and shelf life.

At the same time, material manufacturers are developing new solutions such as paper-based barrier systems and functional coatings that aim to combine recyclability with high product protection. These developments suggest that no single material will dominate in the future. Instead, different applications will continue to require different packaging solutions.

Mandatory minimum recycled content targets further increase the importance of post-consumer recyclates. These are recycled plastics recovered from packaging and other plastic products after consumer use, collected, sorted and reprocessed for new applications.

Integrating these materials into existing packaging concepts is not always straightforward. Recyclates often differ from virgin materials in terms of colour, processing behaviour and material properties. Consequently, they frequently require adapted packaging designs, material formulations and production processes.

Reducing material consumption remains one of the key ways to conserve resources. Lightweighting can lower transport weights and reduce material use. However, lighter packaging is only beneficial if product protection, recyclability and process reliability remain uncompromised.

Successful lightweighting therefore depends on intelligent engineering. New geometries, optimised material distribution and higher-performance materials can reduce material consumption without sacrificing functionality or circularity.

The PPWR affects not only packaging itself but also the way different departments work together. Packaging developers no longer make material decisions in isolation. Procurement evaluates raw material availability and recyclate quality, production assesses machinability and process stability, quality management verifies product safety, while regulatory specialists ensure compliance with legal requirements.

In addition, external partners throughout the supply chain must collaborate more closely. Material suppliers, packaging manufacturers and brand owners increasingly depend on one another because many design decisions affect several companies simultaneously.

For brand owners, packaging is becoming an even more important element of their sustainability strategy. Packaging manufacturers are developing solutions that combine regulatory compliance with technical performance. Machinery manufacturers are supporting this transformation by adapting equipment to new materials, changing packaging structures and increasing production flexibility. As a result, the pace of innovation is accelerating.

The PPWR does not prescribe specific packaging solutions. However, it changes the criteria according to which packaging will be developed in the future. Recyclability, material efficiency, recycled content and product protection must all be considered together from the outset. As a result, packaging development is increasingly becoming a collaborative task—not only within individual companies, but across the entire value chain.