PPWR: current state, immediate impact and what happens next

Following the approval of the PPWR provisional agreement on April 24, 2024, brands and label converters are wondering how this will impact their decisions and what it means for the rest of the packaging value chain. At Avery Dennison, we know how important it is to choose the right labeling solutions for your packaging, and our team of experts has already done the legwork for you.

This article dives deeper into the PPWR's ramifications, immediate effects, and prospects for sustainability leadership and innovation. Insights into these updates will help you understand what these changes mean for the existing measures and how they will affect your labeling decisions.

The current state of the PPWR

The journey to finalize the PPWR has been lengthy and complex, largely due to its ambitious goal to fully transform the packaging industry across multiple sectors and geographies. Numerous stakeholders' diverse interests added to the challenges of creating a regulation that affects value chains within and outside the EU. These included EU member states, industry leaders, environmental groups, etc., each bringing unique perspectives and demands to the table.

While the provisional agreement has been reached, it will not obtain full legal status until it's published in the Official Journal of the European Union in Autumn 2024. Once published, it will take 18 months to become applicable. This offers a strategic window for businesses to align their practices with these new standards, ensuring compliance and building on the opportunities it offers.

Packaging value chain impacts and actions

From individual member states to recycling associations, manufacturers, suppliers, and brands, the PPWR is expected to bring about major changes across the entire packaging ecosystem. Among the immediate changes the industry will have to deal with are stringent requirements for recyclability, recycled content, and ambitious reuse targets. Even though they are intended to be fully implemented by 2030, the early adoption of some measures shows a decisive shift towards more sustainable practices. Additionally, the biggest immediate impact will be the enforcement of strict sustainability mandates, which include bans on harmful substances such as PFAS in food contact materials above minimum thresholds, set to go into effect as early as mid-2026, just 18 months after the regulation comes into force.

Within the various stakeholders, packaging manufacturers are facing the most immediate pressure to adapt. They are expected to swiftly revamp their production processes to meet the new sustainability criteria, which involves not only changing how products are made but also ensuring that all materials used meet the new standards.

But while these changes might seem overwhelming, they also offer great opportunities within the packaging sector. By rethinking and optimizing existing processes, companies can develop solutions that not only adhere to the regulatory framework but also reinforce their positioning as innovative sustainability leaders.

There are already some immediate actions you can start taking now to prepare for the upcoming milestones:

Analyze the impact the measures outlined in the PPWR will have on your packaging. For example, is your label compatible with the upcoming requirements?
Determine if your organization is prepared to develop frameworks for reporting and registrations. Some businesses may have to submit proposals on how they intend to achieve specific goals.
Assess if any of your packaging will be impacted by the immediate compliance obligations. The most immediate requirements are as follows:

a. A ban on PFAS in food contact packaging is expected to be
implemented in mid-2026

b. Sticky labels for fruits and vegetables will be required to be
industrial compostable by Q4 2027

All eyes on the Design for Recycling guidelines

The crucial next steps involve the finalization and dissemination of Design for Recycling guidelines, scheduled for publication by 2028, alongside specific technical requirements that complement the overarching goals of the PPWR. While 2028 might seem distant, the preparation work is already in motion. For example, CEN CENELEC (the European Standards Association) is actively developing standards for the Design for Recycling of plastic packaging. This is an essential step as it lays the groundwork for uniformity and clarity in recycling practices across the EU.

The Design for Recycling guidelines will be particularly influential for the labeling industry as they will specify which solutions are suitable for different types of packaging, ensuring that labels support rather than hinder recycling processes. In addition to compliance, these guidelines will also influence labeling solutions that are aligned with sustainability standards while effectively communicating information about packaging recycling, recycled content, and other environmental factors. We will continue to monitor the progress of these guidelines and provide you with more information as this evolves.

PPWR is not just a regulatory challenge.
It is an opportunity to redefine what it means
to be a leader in sustainable packaging.

It’s time for proactive engagement and strategic planning

As we look to the future, one thing is clear: stakeholders have to remain proactive and engaged. But ultimately, it's important to remember that the PPWR is not just a regulatory challenge. It is an opportunity to redefine what it means to be a leader in sustainable packaging.

At Avery Dennison, we have long advocated for and implemented sustainable practices within the labeling sector. Our ongoing collaboration with various stakeholders and associations across the value chain—from manufacturers to end-users—reflects our efforts to genuinely shape sustainable packaging and labeling decisions. Among them, Recyclass, 4evergreen, and Brussels-based associations will play an important role in shaping future legislation and standards, and we will be ready to play our part in these discussions, bringing along our upstream and downstream partners.

Ultimately, we're here to guide and support our clients through this transition, ensuring that together, we not only meet the new standards but also set new benchmarks in sustainability. With experts in every packaging format (PET, HDPE, paper, etc.), you can rest assured that we have the right team to meet your specific needs.

Learn more

Visit our dedicated PPWR webpage for the latest insights, or contact us directly to discuss how we can help you turn these regulatory challenges into opportunities for growth and leadership in sustainability.

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PPWR: current state, immediate impact and what happens next

PPWR is not just a regulatory challenge.
It is an opportunity to redefine what it means
to be a leader in sustainable packaging.