PPWR – What You Should Know About the Regulation

At the end of 2022, the draft of the Packaging and Packaging Waste Regulations, abbreviated as PPWR, was published. This encompasses requirements regarding packaging and packaging waste of materials, including specifications for packaging design, as well as requirements for reusable packaging and waste management. Unlike the currently applicable EU Packaging Directive 94/62/EC, the PPWR is a regulation whose provisions are binding for all 27 EU member states. This applies to both initial packaging providers and online retailers.

The EU Packaging Regulation PPWR aims to reduce the environmental impact of packaging. It stipulates that by 2030, all packaging in the EU must be recyclable. The regulation requires companies, including online retailers, to adapt their design and material usage to increase recycling and reuse. Key aspects include reducing packaging weight, promoting the circular economy, and complying with extended producer responsibility guidelines.

What is the current status of the EU Packaging Regulation PPWR?

The draft PPWR has been under review by the European Council since March 2024, with a preliminary voting date in the EU Parliament set for April 24. Finalization is anticipated in autumn 2024, followed by implementation, ensuring the new EU Packaging Regulation takes effect within 18 months. Begin addressing your obligations under the PPWR today. Deutsche Recycling GmbH is here to assist you, providing support to gain a competitive advantage.

What are the goals of the Packaging and Packaging Waste Regulations

The aim of the Packaging and Packaging Waste Regulations is to significantly reduce the environmental impact of packaging in the European Union. This is to be achieved by reducing resource consumption and packaging waste, as well as promoting the circular economy within companies. The PPWR targets EU-based companies as well as those importing packaging into the EU, applying to domestic and imported products alike. To establish a functioning circular economy for packaging, the PPWR includes specific target objectives:

1. Reduction of packaging waste: The regulation sets clear targets for reducing the quantity of packaging waste. For example, by 2025, 65% of all packaging waste must be recycled, increasing to 70% by 2030. Specific goals for materials such as plastic, glass, metal, and paper are also defined.
2. Design requirements for recyclable packaging: Specific design requirements are imposed to enhance the recyclability of packaging. This means companies are encouraged to eliminate unnecessary packaging and, where possible, use reusable packaging.
3. Use of Post-Consumer Recycled (PCR) materials: The regulation builds upon the EU Single-Use Plastics Directive and establishes stricter rules for the use of single-use plastic The draft includes a ban on certain single-use packaging.
4. Labeling and transparency: Packaging must be clearly labeled to inform consumers about recyclability and proper disposed packaging waste.
5. Promotion of more sustainable packaging solutions through EPR systems: The Extended Producer Responsibility obliges companies to consider the entire lifecycle of their packaging, including design, use, and disposal. Manufacturers must ensure their packaging is easily recyclable and bear the costs of collection, recovery, and recycling. Concurrently, businesses are encouraged to develop and utilize more environmentally friendly packaging solutions.

Impact of PPWR on Online Retail

The PPWR affects not only manufacturers and businesses but also online retailers, who must ensure their packaging complies with the new requirements. This includes selecting materials that are easily recyclable and reducing packaging sizes to avoid material waste. What does this mean specifically for packaging in e-commerce?

• Recycling-oriented design: Components of recycling packaging should be separable and recyclable as individual parts, following the familiar collect, sort, and recycle process.
• Minimization of weight and volume: The weight and volume of packaging should be limited to the necessary minimum. The goal is to ensure functionality while reducing material consumption.
• Prohibition of unnecessary enlargements: Packaging that artificially increases the perceived product volume through double walls, false bottoms, or similar elements is not permissible.
• Empty space ratio maximum 50%: The empty space in packaging, filled with materials such as air cushions or foam, must not exceed 50% of the total volume.

Additionally, the European Packaging Regulation PPWR stipulates that the amount of chemicals used, such as those in printing, must be limited to a minimum or excluded altogether.

EPR in Packaging and Packaging Waste Regulations for Online Retailers

The PPWR places significant emphasis on Extended Producer Responsibility (EPR), which mandates manufacturers to oversee not only the production and distribution of their goods but also the disposal of associated packaging. Online retailers, particularly those branding or influencing packaging design, must enroll in a national register, remitting corresponding fees and adhering to regular reporting of packaging activities.

In Germany, oversight falls under the LUCID packaging register. Another focal point of the new EU regulation pertains to merchants shipping across multiple European countries sans local presence, necessitating the appointment of an authorized representative (EU representative) for extended producer responsibility. This measure aims to ensure adherence to environmental obligations.

Implementation of PPWR with Deutsche Recycling GmbH

The EU Packaging Regulation PPWR applies across industries in all EU countries. As a manufacturer or online retailer, you are subject to binding regulations. This includes products you already package from a wholesaler. If you are unsure about compliance with the PPWR or specific packaging requirements in Germany, Deutsche Recycling GmbH is here to assist you. We will assess whether your business processes comply with legal requirements, conduct comprehensive compliance checks, determine if adjustments are necessary, and optimize costs within packaging guidelines.

FAQ on the PPWR

In which year was the EU packaging regulation PPWR introduced?

The current EU Packaging Regulation – also known as Directive 94/62/EC on packaging and packaging waste – was amended in 2018 by Directive (EU) 2018/85 and has since regulated the recycling of packaging in the EU member states. The new EU Packaging and Packaging Waste Regulations (PPWR) are now set to replace it. However, it has not yet finally come into force.

How does packaging waste affect the environment?

Packaging waste contributes significantly to the pollution of ecosystems both on land and in the oceans. The reason: many packaging materials are not biodegradable. The oceans in particular are already heavily polluted. According to estimates by the United Nations Environment Programme (UNEP), there are around 18,000 pieces of plastic of various sizes on every square kilometre of ocean surface. However, a good 90 % of all waste sinks to the seabed.

In addition, the production of packaging requires considerable amounts of natural resources, such as water and energy, and is therefore responsible for significant emissions of greenhouse gases, which further contribute to climate change.

Although recycling measures can mitigate some of these impacts, challenges remain as not all materials can be recycled effectively. This is precisely where the PPWR comes in.

How much packaging is thrown away every year?

With changing habits and lifestyles, the amount of packaging waste is also consistently increasing every year. Since 1991, when the total figure was 15.6 million tonnes per year, this has risen to 19.7 million tonnes by 2021. In addition to fill sizes and consumption habits, the increase in online retail also plays a significant role in the increase in packaging consumption. The PPWR will also be used here in future and define new guidelines for packaging material in the mail order business.

What are the legal obligations in relation to waste management?

In Germany, the Closed Substance Cycle Waste Management Act (KrWG), along with supplementary regulations, is the central law that governs waste management. The amended Closed Substance Cycle Waste Management Act, which came into force on 29 October 2020, updates German law in line with the EU Waste Framework Directive.

The primary objective of the KrWG and the forthcoming European Packaging Ordinance PPWR is to avoid the generation of waste in general. Companies and public institutions are required to design processes and products in such a way that waste is minimised from the outset. The core of the law is also product responsibility in accordance with Section 23 KrWG, which calls on manufacturers and retailers to design products in an environmentally friendly way. Waste separation and collection, waste disposal and documentation and verification are also key contents and obligations enshrined in the Closed Substance Cycle and Waste Management Act.

In addition to these legal requirements, there are specific ordinances that target certain types of waste, such as the Packaging Ordinance, the Electrical and Electronic Equipment Ordinance and the Battery Ordinance.

Why has the PPWR been revised?

In 2022, a new legal framework for packaging and packaging waste was introduced in the EU, known as the Packaging and Packaging Waste Regulations (PPWR). The legislative draft is intended to replace the previous EU Directive 94/62/EC and establish standardised, binding requirements for all 27 EU member states. The PPWR addresses both first-time distributors of packaging and online retailers.

The PPWR focuses on the optimisation of packaging designs and the promotion of reusable systems in order to minimise the consumption of resources and reduce the amount of packaging waste. In addition, the regulation emphasises protection against hazardous chemicals in packaging materials, particularly in plastic packaging.

Companies based in the EU or importing packaging into the EU are equally affected by the new regulations. These strict measures are intended to achieve a more sustainable use of packaging resources and significantly reduce the environmental impact.

When will the PPWR come into force?

The new EU packaging regulation PPWR, which is expected to be finalised in autumn 2024, will come into force 18 months after its adoption. It stipulates that all packaging sold in the EU must be recyclable by 2030. Most packaging must fulfil these requirements by 2035.

What does the EU packaging regulation PPWR say?

In 2020, the European Commission set the target of making 70% of all packaging reusable and recyclable by 2030. The Commission’s legislative proposal is intended to update the EU legal framework for packaging and is part of the European Green Deal. Measures are to be introduced to promote the reuse of packaging and restrict the use of harmful chemicals in food packaging.

Companies are obliged by the extended producer responsibility under the PPWR to bear the costs for the collection and recycling of their packaging. In addition, online retailers must ensure that their packaging fulfils the requirements.