PPWR 04 - What Do I Need to Change About My Packaging?

“My packaging is recyclable.”
We will probably hear this statement thousands of times over the coming years. The packaging supplier says it. The material producer says it. We find it in technical data sheets. Sometimes it is even printed on the packaging itself.

But PPWR fundamentally changes the question. It will no longer be enough to say:
“This packaging is recyclable.”

We will need to answer much more specific questions:
• How is it recycled?
• Can it be identified and sorted?
• Are its components compatible with the recycling process?
• What is the quality of the recycled material produced?
• Is there infrastructure capable of actually recycling it?
And ultimately:
• Will it meet the recyclability criteria established under PPWR?

This is one of the major changes the Regulation brings to the packaging industry.


The first question: what is my packaging actually made of?

At first glance, the answer may seem simple.
PET.
PE.
PP.
Paperboard.

But packaging rarely consists only of its main material. Take a PET bottle.
- We have the bottle.
- But we also have the cap.
- The label or sleeve.
- The adhesive.
- The ink.
- The pigments.
Possibly other components.

Or consider flexible packaging. It may appear to be a simple pouch. In reality, its structure may contain several polymer layers, barriers, adhesives, inks or even aluminium.

PPWR requires us to start looking at the entire packaging unit, not just its main material. This is the logic behind Design for Recycling.


What does Design for Recycling mean?

In simple terms:
Packaging must be designed with consideration for what will happen to it after it becomes waste.

It is not enough for the main material to be theoretically recyclable. The packaging must be capable of entering a real collection, sorting and recycling process, and the resulting material must be of sufficient quality to substitute primary raw materials. Article 6 and Annex II of PPWR establish the basis for this new assessment system.

There is, however, an extremely important point to understand.
Today, we cannot say with certainty which PPWR grade every package will receive.
The Regulation establishes the thresholds. However, the detailed technical assessment methodology still needs to be completed through the delegated act provided for under Article 6(4), which the Commission is required to adopt by 1 January 2028.

So we can already identify potentially problematic packaging.
- We can test.
- We can talk to suppliers and recyclers.
- We can prepare alternatives.
But we should not present a current assessment as a definitive legal PPWR classification.


A, B or C?

PPWR establishes three recyclability performance grades:
• Grade A – at least 95%
• Grade B – at least 80%
• Grade C – at least 70%

An important clarification is necessary here. Various presentations and commercial tools may refer to Grades D or E.
PPWR does not legally define Grades D and E.
Below the 70% threshold, packaging is considered technically non-recyclable under the system established by the Regulation. From 2030, the minimum threshold will be Grade C, according to the timetable and conditions laid down in Article 6.

From 2038, Grade C will no longer be sufficient. Only Grades A and B will remain acceptable. Suddenly, packaging design is no longer only about cost, appearance, protection or marketing. It also becomes a question of market access.


But what can make packaging difficult to recycle?

We need to look beyond the main material. Apparently simple packaging can become problematic because of:
• multilayer structures;
• barrier layers;
• metallisation;
• adhesives;
• labels;
• sleeves;
• caps and closures;
• inks;
• pigments;
• fillers;
• additives;
• combinations of materials that are difficult to separate.

This does not mean that every one of these elements will automatically make packaging non-compliant. We need to be very careful here. The final technical criteria have not yet been established. But these are precisely the types of elements that companies should start examining now.


A very simple example: the PET bottle

Suppose we have a clear PET bottle. At first glance: PET – recyclable. Problem solved. Not necessarily.
- The bottle may have a sleeve covering almost its entire surface.
- The sleeve may be made from another material.
- Its density may create problems during separation.
- It may prevent the bottle from being correctly identified by automated sorting equipment.
- The adhesive may create problems.
- The inks may contaminate the recycling stream.
- The cap may introduce another material combination.

From a PPWR perspective, the question is no longer:
“Can PET be recycled?”
It becomes:
“Is this bottle, with all its components, designed so that it can be efficiently recycled?”

The difference is enormous.
Does mono-material automatically mean compliant?
No.

This will probably be one of the first traps the industry may fall into. Mono-material structures are generally more favourable to recycling than complex combinations of materials. But “mono-material” is not an automatic guarantee of compliance.

Packaging may have a body made from a single polymer and still present problems because of the sleeve, label, adhesive, pigment, closure or other components. That is why the assessment must be made at the level of the entire packaging unit.


“Recyclable” can mean five different things

This may be the most important distinction the industry needs to understand.

1. Technically recyclable
The material can, in principle, be recycled or processed in a laboratory-scale recycling process.
That is all.

2. Designed for recycling
The packaging has been designed so that its materials and components are compatible with recycling.

3. Recyclable within existing infrastructure
The packaging is actually collected, identified, sorted and accepted by existing recycling facilities.

4. Recycled at scale
There is a sufficiently large industrial stream in which the packaging is actually collected, sorted and recycled. This condition becomes particularly important from 2035.

5. Recyclable under PPWR
The packaging meets the applicable legal and technical criteria established under PPWR.

These five concepts are not the same. And this is precisely where one of the biggest changes in mindset introduced by the Regulation can be found.


Packaging can be perfectly recyclable in theory and still create a problem

Yes.
Suppose we develop a new material. It performs very well in recycling trials. The results are excellent.
But sorting facilities cannot identify it.
Or there is no separate collection stream.
Or recyclers do not accept it.
Or the volumes are so small that no viable industrial recycling process exists.

Technically, we might say that the material is recyclable. From a PPWR perspective, that may not be enough. And this brings us to an actor who, until now, has often been consulted too late. The recycler joins the design team.

In the traditional model, the flow was relatively simple:
brand owner → packaging manufacturer → material supplier → consumer → waste → recycler.
The recycler appeared at the end of the chain.

PPWR begins to change this logic. If we need to know whether packaging can be sorted, whether certain labels create problems, whether an adhesive contaminates the material, or what quality of recyclate is ultimately produced, who has some of the best information?
The recycler.

The recycler sees what actually happens to packaging inside a real industrial facility. That is why discussions between packaging manufacturers and recyclers should begin before the design is finalised, not after the product has become waste. For many companies, this will represent a significant change in the way they work.


The second major change: we need to use less packaging

This is where another common misunderstanding appears. Many companies will say:
“We are already lightweighting.”
Good.
But lightweighting and PPWR-compliant packaging minimisation are not exactly the same thing.

Article 10 requires packaging to be designed so that its weight and volume are reduced to the minimum necessary to ensure its functionality.

And there is an essential difference:
the company must be able to justify this.

Annex IV establishes criteria relating, among other things, to product protection, manufacturing and filling processes, transport, handling and other functional requirements.

In other words, it is not enough to say:
“We cannot make the packaging smaller.”
Companies must be able to explain why.

Be careful: less material does not automatically mean better packaging

Suppose we reduce the thickness of flexible packaging. We save material. Excellent. But to maintain the necessary mechanical properties or product barrier, we need to introduce another layer. The packaging becomes lighter. But its structure becomes more complex and more difficult to recycle. We have solved one problem and created another.

PPWR requires the industry to start considering:
functionality + minimisation + recyclability
at the same time.
Not as three separate projects.


And then there is empty space

Here, the rule is much easier to understand. For grouped, transport and e-commerce packaging covered by Article 24, PPWR introduces a maximum 50% empty-space ratio, according to the timetable laid down by the Regulation.

There is also an important detail. Materials used to fill empty space – such as air cushions, bubble wrap, foam, polystyrene chips, paper or similar materials – count as empty space, not as product.

We all know the classic example:
you order a small item online and receive an enormous box filled with protective material.

PPWR targets exactly this type of situation. The precise calculation methodology, however, still needs to be established through the implementing act provided for by the Regulation.

Once again:
the direction is clear, but not every technical detail is final yet.


So, what should I do now?

This is where we get to the part that matters. If you are a packaging manufacturer, converter, brand owner or a company using significant quantities of packaging, you should not start by changing everything. Start by finding out where your potential problems are.

Take each important packaging family and ask:

MATERIAL
What is it made from?
Is it mono-material or multilayer?
What other materials does it contain?

STRUCTURE
Are there barrier layers?
Adhesives?
Coatings?
Metallisation?
Sleeves?
Labels?
Pigments?

RECYCLING
Is this packaging actually collected?
Can sorting systems identify it?
Is it accepted by recyclers?
What quality of recycled material does it produce?

MINIMISATION
Can its weight be reduced?
Can its volume be reduced?
Is there material that does not perform a necessary function?
Is there unnecessary empty space?

SUPPLIERS
Do you have the technical information you need?
Do you know the exact composition?
Do you have documentation regarding recycled content?
Do you have reliable information about recyclability?

If the answer to many of these questions is:
“We don't know.”
then that is the first problem to solve.


Not all packaging has the same level of urgency

We can already create a simple internal classification. This is not a legal PPWR classification. It is simply a management tool.

LOW RISK
Simple structure, well-established recycling stream, compatible components and good documentation.
Monitor the development of the final criteria.

MEDIUM RISK
The main material is favourable to recycling, but there are questions surrounding components such as sleeves, labels, adhesives, barriers or pigments.

Start discussions with suppliers and recyclers.

HIGH RISK
Complex multilayer structures, difficult-to-separate material combinations, components known to create recycling problems, absence of an established industrial recycling stream or insufficient technical information.

These packaging formats should be investigated now. That does not mean they need to disappear tomorrow. It means companies cannot afford to discover the problem in 2029.


What should I ask my supplier?

PPWR will also change the relationship between customers and suppliers.
“Is it recyclable?” is no longer a sufficient question.

Companies should start requesting information such as:
• exact material and layer composition;
• polymer types;
• barrier materials used;
• adhesive types;
• label or sleeve material;
• ink systems;
• percentage of recycled material;
• origin of recycled material;
• traceability;
• existing recyclability tests or assessments;
• available technical documentation.

And this is where one of the most important changes brought about by PPWR becomes visible:
information needs to start flowing throughout the entire value chain.
Material supplier.
Converter.
Packaging manufacturer.
Brand owner.
Customer.
Recycler.

No single actor will be able to solve this problem alone.


What should we NOT do now?

There is also the opposite extreme.
Panic.
“PPWR is coming. We need to change everything.”
No.

Some important technical criteria are still under development. It makes little sense to invest heavily in a new mould or an entirely new packaging format simply because someone has said that the existing package will “probably be Grade C”.

Today, no one can legally assign a definitive PPWR grade to packaging using the final methodology because the methodology required under Article 6(4) has not yet been adopted.

The right strategy therefore lies somewhere between the two extremes:
Do not wait.
But:
Do not invest blindly.

Analyse.
Classify the risk.
Request information.
Talk to suppliers.
Talk to recyclers.
Prepare alternatives.
And monitor the technical criteria as they are adopted.


What Should Be Done Now – 2026

If we had to reduce this entire article to a few actions for companies, they would be:
• Build an inventory of your packaging.
• Identify complex structures and potentially high-risk packaging.
• Request much more detailed technical data from suppliers.
• Start discussions with recyclers.
• Identify where material and volume can be reduced without compromising functionality or recyclability.
• Document why the packaging has its current weight and volume.
• Prepare alternatives for high-risk packaging.
• Do not make irreversible investments based on assumptions about PPWR criteria that are not yet final.
• Monitor the delegated acts, implementing acts and standards that will complete the Regulation.


In Brief

• PPWR transforms recyclability from a general claim into a measurable condition for market access.
• A recyclable material does not automatically mean compliant packaging.
• The entire packaging unit must be assessed: material, layers, label, sleeve, adhesive, cap, ink, pigment and other components.
• PPWR defines Grades A, B and C. Below 70%, packaging is considered technically non-recyclable under the grading system.
• From 2038, Grade C will no longer be sufficient.
• “Recyclable in a laboratory” and “recycled at industrial scale” are two different things.
• Recyclers need to become partners in packaging design.
• Minimisation does not simply mean lightweighting.
• Less material is not always better if the result is packaging that is more difficult to recycle.
• We do not need to redesign everything today. But today we do need to know what we may be forced to redesign tomorrow.


Coming Next

We have looked at how packaging needs to be designed. But this immediately raises the next question:
What material will we make it from?
And here PPWR introduces one of the most important changes for the plastics industry:
mandatory minimum recycled content.

In Part 05, we will examine which percentages will become mandatory, for which types of packaging, when they will apply and, most importantly, what this change could mean for manufacturers, converters and recyclers.


Sources

• Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – EUR-Lex
• European Commission – Packaging and Packaging Waste Regulation (PPWR)
• European Commission – PPWR guidance and interpretative documents
• Joint Research Centre (JRC) – technical background work supporting the development of Design for Recycling criteria
• Complementary technical sources used for Design for Recycling context: RecyClass, European PET Bottle Platform (EPBP) and Petcore Europe.