How prepared are you for the Packaging and Packaging Waste Regulation (PPWR)?

Packaging Europe recently polled its audience with the question: How well does your company understand the data implications of the new PPWR?

These are demands and are unavoidable, which suggests there are going to be a lot of companies playing catch-up.

In this article we look at the huge task of data management looming now on the horizon, where to start, and how to sustain future reporting requirements when it comes to tackling it.

What is PPWR

PPWR refers to the Packaging and Packaging Waste Regulation. This is a key European Union regulation that aims to prevent and reduce the environmental impact of packaging waste. Sadly, it falls short on capturing carbon emission data in production (this time round) but will contribute to reduced emissions from less waste. All emissions contribute to global warming. Consistently both initiatives are driving the need for more granular data that needs to be accurately calculated and transparently reported.

The new PPWR was proposed by the European Commission in late 2022 to replace the older Packaging and Packaging Waste Directive (PPWD).

The PPWR includes several annual reporting obligations for obligated companies. Starting from January 1, 2025, companies need to report annually on:

1. Packaging placed on the market
2. Reusable packaging
3. Recycled content in plastic packaging
4. Packaging waste collection, recycling, and other recovery

These reports will need to be submitted to the relevant national authorities. The reporting obligations continue indefinitely as part of ongoing compliance.

Applicable across all EU member states without needing to be transposed into national law.

The PPWR includes several specific requirements across different areas:

Recyclability Requirements:

• All packaging must be recyclable by 2030
• Packaging must meet “design for recycling” criteria
• At least 95% of materials in packaging must be recyclable at scale
• Certain problematic materials will be restricted or banned

Recycled Content Minimums (for plastic packaging):

• Contact-sensitive plastic packaging: 30% by 2030
• Beverage bottles: 30% by 2030
• Other plastic packaging: 35% by 2030, 65% by 2040

Waste Reduction Targets:

• 5% reduction in packaging waste per capita by 2030 (vs 2018)
• 10% reduction by 2035
• 15% reduction by 2040

Reuse/Refill Targets:

• For business packaging: 10% by 2030, 25% by 2040
• For takeaway beverage/food containers: 10% by 2030, 40% by 2040
• For alcoholic/non-alcoholic beverages: 10% by 2030, 25% by 2040

Format-Specific Requirements:

• Elimination of single-use packaging for certain applications
• Restrictions on lightweight plastic bags
• Standards for packaging-to-product size ratios
• Ban on certain unnecessary packaging elements

Labelling Requirements:

• Clear recycling information
• Recycled content declaration
• Reusable packaging identification
• QR codes for additional information

PPWR will significantly impact material supply from outside the EU, particularly for:

1. Raw Materials and Packaging Components:

• Non-EU suppliers must ensure their materials meet the new recyclability criteria
• Materials must comply with recycled content requirements
• Documentation proving compliance will be required
• This may create supply chain bottlenecks as suppliers adapt

2. Finished Packaged Products:

• Any packaged products entering the EU market must comply with PPWR
• Foreign manufacturers will need to redesign packaging for EU compliance
• This includes meeting recycled content, recyclability, and labeling requirements

3. Supply Chain Implications:

• Increased demand for recycled materials globally
• Potential price increases for certain materials
• Need for new certification and verification systems
• May lead to preferential sourcing from suppliers who can demonstrate compliance

4. Market Access:

• Companies unable to meet PPWR requirements may lose access to EU markets
• Could create competitive advantages for EU-based suppliers
• May incentivize non-EU suppliers to develop parallel product lines (EU-compliant vs non-EU)

The regulation is expected to create ripple effects throughout global supply chains as suppliers adjust their operations to maintain access to the EU market. This could potentially influence packaging standards in other regions as well.

The EU Packaging and Packaging Waste Regulation (PPWR) does not directly apply in the UK since Brexit. The UK has its own packaging regulations, primarily through:

1. The UK Packaging Waste Regulations
2. The Packaging (Essential Requirements) Regulations
3. The upcoming Extended Producer Responsibility (EPR) scheme

However, UK businesses may still need to comply with the EU PPWR if they:

• Export packaged goods to the EU market
• Have operations in EU member states
• Are part of supply chains that serve the EU market

To give you the most accurate current information about specific requirements and implementation dates, I’d recommend checking:

• The UK government’s website (www.gov.uk)
• The Environment Agency guidance
• Professional packaging compliance schemes

Businesses will need to report their compliance data under PPWR. The reporting requirements apply through the European Registry for Extended Producer Responsibility (EPR).

Key reporting aspects:

1. Primary Reporting Body:

• Data reported to national authorities
• Data then transferred to the EU Commission
• Reporting through Extended Producer Responsibility (EPR) schemes

2. Data Requirements:

• Packaging volumes placed on market
• Recycled content percentages
• Reuse/refill rates
• Waste collection and recycling data
• Compliance with recyclability requirements

3. Who Must Report:

• Producers
• Importers
• Online sellers to EU customers
• Packaging manufacturers
• Companies exceeding certain size thresholds

4. Verification:

• Third-party verification required for certain claims
• Independent audits of recycled content claims
• Regular compliance checks by authorities

Benchmark‘s digital package is a game-changer:

• A sophisticated CO2 e commercial cost and PPWR content calculator
• Providing carbon certification for packaging
• Precise cost modelling and price setting for packaging materials
• Commercial performance calculation and analysis
• Granular data accurately and consistently calculated & transparently reported.
• Verified to ISO14067
• Supported by a team of packaging material, Life Cycle Assessment and Data analysis experts.

What sets Benchmark apart, is also our ability to convert complex data, often many thousands of rows of data in a spreadsheet format with different units of measure (area and weights, metric and imperial and volumes, multilayer specifications and currencies) – all uploaded stored and returned in granular templates and bespoke Key Performance Dashboards in a matter of minutes.

For more information about our software solutions, speak to the team T +44 (0)115 697 5500 or click on the website: www.benchmark-consulting.co.uk