The Paperisation of PPWR Rules in Europe: A New Era for Packaging

One of the longest-running stories in the packaging industry finally moved on to its next chapter in April, when the EU Parliament and European Council agreed on a preliminary deal for its Packaging and Packaging Waste Regulations (PPWR). This deal represents a significant shift for the entire packaging industry, impacting every business looking to sell into the European market.

PPWR is an evolution of the existing Packaging and Packaging Waste Directive (PPWD) and aims to address the packaging waste problem in Europe. It sets phased waste reduction targets that increase every five years, while also harmonising packaging and recycling standards across member states to make these targets more feasible. The legislation is complex, aiming to guide the packaging industry for decades into the future and its impact is already being felt as proactive brands make significant changes to their packaging portfolios.

What is the PPWR?

The PPWR is a proposed piece of legislation revising the current packaging and packaging waste rules applicable in the European Union (EU). The main regulatory framework for packaging and its end of life in the European Union is currently governed by the Packaging and Packaging Waste Directive (PPWD), adopted in the 1990s and revised several times since. However, after finding that the PPWD was not efficiently preventing the growth of packaging waste and reducing the environmental impact of packaging, the European Commission proposed to overhaul the PPWD in 2022. The result is the Packaging and Packaging Waste Regulation (PPWR), which has greater ambition than the Directive previously adopted.

Timeline for enforcement of PPWR

The PPWR was recently adopted by the European Parliament, but it is not in force yet. The final text is expected to enter into force and become law in the last quarter of 2024.

How will PPWR affect your business

Absolutely. The PPWR will considerably change how we design, consume, and dispose of packaging in the EU across all value chains. It will bring a revolution to the EU packaging landscape. Most packaging categories are affected by the measures contained in the PPWR, so all businesses should prepare for what is coming.

Key Objectives of the New Regulation

The Regulation aims to reduce the environmental impact of packaging whilst harmonising packaging rules throughout the EU to facilitate the free movement of goods. The main objectives are:

• Preventing the Generation of Packaging Waste: The PPWR intends to reduce the amount of packaging waste generated in the EU, introduce restrictions on what packaging can be used, and promote reusable and refillable packaging solutions.
• Boosting High-Quality Recycling: The PPWR aims to make all packaging on the EU market recyclable in an economically viable way by 2030.
• Adopting Harmonised Rules: EU-wide rules on labelling, void space, and mandatory recycled content will promote a level-playing field across the EU, with the same rules applying to all.

Changes Compared to Existing Rules

The PPWR aims to address the continued growth in packaging waste in the EU. This translates into obligations not only for EU countries, such as waste reduction targets, but also for businesses, including mandatory reuse targets for packaging categories, bans on some types of single-use packaging, and packaging minimisation requirements.

The shift from a Directive to a Regulation is expected to bring greater harmonisation to packaging rules in the EU. Directives give greater leeway to European countries when implementing EU rules, allowing for national divergence. Conversely, regulations promote a "one-size-fits-all" approach and set rules to be implemented everywhere in the same way. The Commission has decided to replace the Packaging Waste Directive with a Regulation to ensure greater harmonisation and enforceability of packaging rules across Europe, which is positive news for businesses operating across the EU.

Opportunities and Challenges

While pivoting to a future of PPWR compliance naturally poses some challenges, it also presents many opportunities for businesses that are flexible enough to seize them. As a result, news of the PPWR deal was particularly exciting for companies investing in paperisation.

PPWR's goal is, ultimately, to solve the packaging waste problem in Europe. In short, it aims to do this by setting phased waste reduction targets that increase every five years, while also harmonising packaging and recycling standards across member states to make these targets more feasible. In order to achieve these targets, a raft of new restrictions and bans are being put in place on plastic packaging in particular. Any packaging containing polyfluoroalkyl substances (PFAS) – so-called 'forever chemicals' that are also subject to scrutiny from the European Chemicals Agency – will be banned entirely. In addition, single-use plastic packaging for certain fresh produce applications will also be banned.

These bans will be complemented by measures aimed at incentivising high-quality recycling. While the exact legal definition of what constitutes high-quality recycling is yet to be decided (a date of 1 January 2028 has been set to enact new definitions around quality grades, design for recycling guidelines, and other details), the text of the preliminary agreement indicates that packaging materials must be able to be recycled into materials of at least equivalent value.

Paper Packaging: The Beneficiary of PPWR

So, what do all these measures, aimed at plastic packaging, have to do with paperisation? The answer is: nothing. And that’s the point. Paper packaging has been exempted from all these measures, meaning that companies switching to paper-based solutions can simply sidestep all of this legislation entirely.

Paper – The Material of the Future?

Paper has many benefits as a packaging material. It is easy to recycle and has much higher recovery rates than plastic. Provided it is made with fibres from a sustainably managed forest, it is a renewable resource. Perhaps most importantly, consumers know this, and increasingly prefer it to other materials as a result.

Paper does degrade as it is recycled, as paper fibres shorten with each cycle through the recycling loop – although recent studies have indicated this process does not happen as quickly as previously thought. However, as it uses a renewable resource that is significantly easier to recycle than most plastics, paper packaging is not subject to any market restrictions.

This places paper as the front runner in the race to be the packaging material of the future – at least, in the European market. It also sets up an exciting few years of investment and innovation as the industry strives to scale up its paper packaging use. These innovations could offer benefits across the whole packaging industry and the wider economy. For example, new high-performance water-based barrier coatings could help create a new generation of easily recyclable packaging that does not compromise product shelf life. It could even be that these coatings have applications outside of packaging.

Industry Innovations

Innovations in paper packaging are already taking place, with companies investing heavily in sourcing and developing new barrier coatings that improve the functional qualities of paper packaging without affecting its recyclability. For instance, thin layers of water-based coatings can create flexible paper laminates that meet stringent paper recyclability testing standards.

Other breakthroughs can help fulfil the many aesthetic requirements that modern consumers demand. Paperisation does not have to mean downgrading the look of packaging – far from it. Advanced techniques like using vapour deposition of aluminium or metallic pigments in ink to create recyclable metallic effects are increasingly common, while new water-based varnishes that add intriguing finishes and tactile effects to labels and packaging are emerging constantly. There are huge opportunities for businesses willing to be proactive and embrace these technologies ahead of the PPWR implementation date.

A Critical Viewpoint

Despite the excitement around paperisation, there are critical voices in the industry. Some argue that the paper-based packaging lobbyists have managed to get a "free-ride" in the PPWR by escaping from market restrictions and some of the reuse targets at the expense of the environment and the public interest. When it comes time to implementing the PPWR, there is concern that it may lead to regrettable material substitution and instead encourage real packaging waste reduction through well-designed reuse systems.

Conclusion

In this sense, PPWR is reinforcing paperisation in more ways than one, embedding it as an increasingly standard practice within the packaging industry while also incentivising creative new innovations. Paperisation was already happening, driven by the purchasing preferences of today’s consumers. The tide was already turning, and legislators are just now catching up. Brands now have a choice – they can either embrace the opportunities that come with PPWR or continue to swim against the tide.