The EU’s new Packaging and Packaging Waste Regulation (PPWR) is reshaping how companies design, source, and manage packaging. No longer a directive open to interpretation, this regulation applies directly across all EU Member States — with clear targets for recyclability, recycled content, and packaging minimization by 2030.
For brands and manufacturers, that means one thing: your packaging suppliers are now critical partners in achieving compliance. But if they’re not already working on a plan to help you become PPWR-ready, that’s a red flag.
The coming years will bring tighter limits on hazardous substances, mandatory recycled content in plastics, stricter documentation requirements, and higher expectations for traceability and reuse. To meet these demands, businesses must know where their suppliers stand — and start having the right conversations now.
This blog outlines six key compliance areas to guide your supplier discussions. From substances of concern and design for recycling to certification and traceability, use these as your roadmap to ensure your supply chain is prepared — not scrambling — when enforcement begins.
The PPWR goes far beyond recycling targets — it demands traceability, transparency, and technical proof at every stage of packaging production. Below are six key compliance areas to discuss with your packaging suppliers, along with guiding questions to assess their readiness.
Packaging must be free from hazardous substances and comply with strict limits on chemicals such as PFAS and heavy metals. This is not only a safety issue but also a prerequisite for recyclability and reusability.
Key questions to ask your suppliers:
From 2030, all packaging on the EU market must be recyclable — and not just in theory. It must be proven recyclable “at scale” using EU infrastructure. That means every layer, adhesive, and label must align with real-world recycling systems.
Key questions to ask your suppliers:
The PPWR sets mandatory recycled content targets for plastic packaging by 2030 and 2040. Suppliers must ensure availability, quality, and traceability of PCR materials to help you meet those targets.
Key questions to ask your suppliers:
Under PPWR, companies must be able to trace the origin of materials — including recycled inputs — back through the supply chain. Reliable documentation will be essential for audits, declarations, and digital product passports.
Key questions to ask your suppliers:
Beyond recyclability, PPWR introduces clear rules to minimize packaging weight, volume, and empty space. The goal: reduce waste without compromising product protection or functionality.
Key questions to ask your suppliers:
Compliance under PPWR isn’t just about design — it’s about proof. Every packaging item will require a Declaration of Conformity and supporting technical documentation that regulators can request at any time.
Key questions to ask your suppliers:
The six key areas cover the core PPWR compliance pillars, but several additional topics deserve attention — especially as the EU moves toward circular systems, digital product passports, and stricter labeling rules.
These extra questions can help identify long-term risks and opportunities in your packaging supply chain.
The PPWR promotes reusable packaging and refill systems as part of its waste reduction goals. Even if reuse isn’t yet feasible for your product, suppliers should already be exploring pilot projects or adaptable designs.
Ask your suppliers:
From 2030, all packaging will require standardized EU labeling to guide consumers on disposal and recycling. Digital identification (QR codes, data carriers) will also become part of traceability systems.
Ask your suppliers:
Efficient packaging isn’t only about weight — it’s also about logistics. PPWR encourages minimizing empty space, optimizing transport, and reducing unnecessary protective materials.
Ask your suppliers:
For companies in food, beverage, or cosmetics, packaging must comply with EU food contact regulations in addition to PPWR. Changes in material composition, especially with PCR content, can affect safety and migration limits.
Ask your suppliers:
Even compliant materials can cause issues once recycled. Suppliers should understand how their packaging behaves at end-of-life to avoid contamination of recycling streams.
Ask your suppliers:
Packaging regulations and materials evolve quickly. Suppliers that anticipate changes — and communicate them early — reduce compliance risk for their clients.
Ask your suppliers:
Recycled material markets are volatile. Securing long-term access and cost stability will be essential for compliance and continuity.
Ask your suppliers:
Documentation will be the foundation of compliance under the PPWR. Suppliers should be transparent, auditable, and ready to share supporting evidence when requested.
Ask your suppliers:
The PPWR isn’t just a checklist of new rules — it’s a framework for how your packaging supply chain should operate going forward. Each conversation with a supplier is an opportunity to strengthen compliance, improve design, and future-proof your packaging portfolio.
Below are practical ways to use the key questions from this guide, supported by real examples from companies already taking proactive steps.
Start by categorizing your packaging based on material type, complexity, and supplier transparency. This helps you understand where compliance risks sit and where to focus first.
For example:
By mapping each material type (plastic, paper, composite, aluminum, etc.) and its supplier documentation status, you can identify where to begin supplier outreach.
Tip: Align your mapping with your sustainability reporting under CSRD or ESRS E5 (Resource Use and Circular Economy). Packaging data collected here can feed directly into your ESG disclosures later.
Once you’ve mapped suppliers, use a structured PPWR readiness audit to benchmark each one. You can do this via:
Example:
A European dairy brand recently sent a 30-question PPWR survey to its top ten packaging suppliers. The results revealed that only three could certify their recyclability “at scale.” That finding led to joint R&D projects to redesign the plastic bottle sleeves for improved separation in recycling streams.
Tip: Keep all answers and certificates stored in a single compliance database (e.g., within your ESG management system or supplier portal).
After identifying gaps, set shared milestones with your suppliers. These can be included in your contracts or supplier code of conduct.
For instance:
Example:
A beverage company created a “PPWR Readiness Roadmap” that each supplier must sign. One cap supplier committed to switching from mixed-material closures to mono-polypropylene ones by 2026. Another developed a take-back scheme for used PET bottles to support traceability and PCR targets.
Tip: Use performance-based contracts — rewarding suppliers who meet compliance milestones early with preferred supplier status or multi-year agreements.
PPWR compliance works best when it’s collaborative. Invite suppliers into discussions about your sustainability goals, and co-develop new packaging designs that meet both performance and regulatory needs.
Example:
A Dutch snack producer partnered with its film supplier to replace multi-layer foil bags with a mono-PE structure that can be recycled in the Netherlands’ existing system. The supplier provided LCA data, recyclability testing, and a certification for “recycling at scale.” The redesign reduced material weight by 12% and allowed the brand to make a verified “designed for recycling” claim.
Collaboration can also mean sharing testing results, co-hosting pilots, or participating in joint R&D grants.
Tip: Create a recurring supplier roundtable every 6–12 months to share updates, pilot outcomes, and evolving PPWR interpretations.
Documentation is the new compliance currency. Under the PPWR, both manufacturers and suppliers must maintain Declarations of Conformity (DoC) and supporting technical files for inspection.
Example:
A packaging converter supplying glass jars to multiple food brands developed an online portal where customers can download updated DoCs, test reports, and recyclability certificates. This saved brands weeks of document chasing during internal audits and upcoming CSRD reviews.
Make sure you:
Tip: If possible, integrate your packaging compliance data with digital traceability systems — this will make you ready for the upcoming Digital Product Passport (DPP) rollout.
Brands that treat PPWR compliance as part of innovation — not just regulation — will stand out in the market. Verified recyclability and transparency build consumer trust and open doors with major retailers demanding proof of compliance.
Tip: Use verified compliance as part of your sustainability marketing — but ensure all claims meet the EU Green Claims Directive. Transparency and data-backed statements will soon become the standard, not the differentiator.
The Packaging and Packaging Waste Regulation (PPWR) marks the most significant overhaul of EU packaging policy in three decades. It’s designed to bring consistency across Member States, accelerate the shift toward circular packaging, and cut packaging waste per capita by 15 % by 2040.
Below are the most important highlights and upcoming trends to monitor as you prepare for compliance — along with real examples of how leading companies are already adapting.
Unlike the old Packaging Waste Directive, the PPWR is a regulation, meaning it applies automatically and uniformly across all EU Member States. There’s no national transposition period or country-specific interpretation.
Why it matters: If your packaging is placed on multiple EU markets, you’ll now face one single rulebook — but also less flexibility.
All packaging placed on the EU market must be recyclable by 2030, and by 2035 it must be recyclable “at scale” using EU-wide infrastructure.
What this means for suppliers:
The PPWR introduces binding post-consumer recycled (PCR) content targets for plastic packaging:
Why it matters: These targets will tighten access to high-quality recyclate and drive up costs in the short term — making long-term supply agreements essential.
PPWR limits the use of hazardous substances, especially PFAS, heavy metals, and other Substances of Concern (SoC) that hinder recycling or pose health risks.
The regulation enforces minimization rules to reduce weight, empty space, and unnecessary layers in packaging. Producers must demonstrate that their packaging uses the minimum amount of material necessary for functionality.
The PPWR sets binding reuse and refill targets for specific sectors such as beverages, take-away food, and transport packaging. By 2030, a portion of packaging must be designed for reuse within closed-loop systems.
Digital traceability is a cornerstone of the PPWR. Each package may require a Digital Product Passport containing data on composition, recyclability, and recycled content — accessible via QR code or data carrier.
What this means:
Although the regulation entered into force in February 2025, most obligations start applying from August 2026 onward, with staged increases in recycled content, reuse quotas, and labeling obligations until 2040.
Example of a typical timeline:
The PPWR is more than a packaging regulation — it’s a shift in how businesses collaborate, share data, and prove sustainability claims. It demands that companies move beyond good intentions and toward traceable, verifiable compliance.
Success will depend on how well you work with your packaging suppliers: asking the right questions, collecting the right documentation, and keeping everything aligned with recyclability, traceability, and reporting requirements. For many teams, that means managing dozens of forms, technical files, and supplier updates — a process that can quickly turn into a full-time job.
