The European Union’s Packaging and Packaging Waste Regulation (PPWR) represents a huge change in how packaging is managed on the continent. It covers all packaging placed on the European market, ‘whether it is used or released at industrial, commercial, office, shop, service, household or any other level.’
It will directly impact UK businesses trading with the EU. It doesn't matter if a businesses is importing or exporting, compliance with the new rules is legally required for market access.
This article will detail exactly what the EU’s PPWR is, a timeline for its implementation and exactly how it will impact businesses in the UK over the coming years.
Source: Eurostat
Explaining the EU's Packaging and Packaging Waste Regulation (PPWR)
The EU's PPWR replaces the Packaging Directive 94/62/EC for EU countries and will be phased in over the coming decades.
Its core objectives are entirely centred around sustainability. They include reducing packaging waste, mandating the recyclability of packaging materials, introducing recycled content targets for plastics, and increasing the overall responsibility of producers for managing the lifecycle of packaging.
The key goals include packaging reduction targets of 5% by 2030, 10% by 2035 and 15% by 2040 and a maximum empty space ratio of 50% for logistics, grouped, sales, and e-commerce packaging.
For a full list of the EU Packaging and Packaging Waste Regulation aims see here.
The regulation applies to all businesses trading with the EU. So, that obviously includes those exporting and placing packaging on the EU market. But it will also have ramifications for businesses importing from the EU, as suppliers will need to adhere to packaging regulations.
For example, consider the recent change to plastic bottle tops in the EU and UK. You may have noticed they are now attached. Now this is only EU regulation, but it’s simpler and cheaper for manufacturers to produce just 1 type of bottle cap for the European market. So although not legislatively required, it has been widely adopted in the UK.
"The EU's PPWR is yet another added complexity for UK trade with the EU. The policy is very detailed and confusing, it can be difficult to establish your exact requirements. However, with adequate planning ahead and guidance there's no reason why businesses can't meet the deadlines comfortably."
Liam Launders, Head of Sales, WTA Group
Timeline of deadlines for businesses
The EU’s PPWR is huge regulation, to be rolled out over the next 15 years. Here is a timeline of key deadlines under the PPWR that UK businesses should be aware of:
- 1st January 2025: Member states are required to have Extended Producer Responsibility (EPR) schemes, for businesses placing packaging on the market.
- 1st January 2030: All packaging sold in the EU must be recyclable, with minimum recycled content requirements for plastics.
- Packaging may only be placed on the market if it is recyclable according to grades A (higher or equal to 95% recyclability), B (higher or equal to 80% recyclability) or C (higher or equal to 70% recyclability).
- Lower than 70%, the packaging will be considered technically non-recyclable, and its placing on the market will be restricted.
- 1st January 2035: Packaging must be recycled at scale (widely collected and recycled across the EU).
- “At scale” means annual quantity of recycled material equal or greater than 55%, or 30% in the case of wood.
- “At scale” means annual quantity of recycled material equal or greater than 55%, or 30% in the case of wood.
- 1st January 2038: Packaging may only be placed on the market if it is recyclable according to grades A or B.
- 1st January 2040: Increased recycled content requirements for plastic packaging.
Impact of PPWR on UK businesses exporting to the EU
UK businesses exporting to the EU will need to comply with the new PPWR standards to ensure their goods can continue to be sold in the EU market. Here are the main requirements:
- Compliant with Extended Producer Responsibility (EPR) schemes in 2025: These vary depending on the member state. But the deadline for their implementation is January 2025. So, any exporter needs to be compliant, including financial implications, either through their buyer or directly. The UK has a similar scheme in place already, so businesses should already be aware of their requirements.
- Recyclability by 2030: All packaging used for products sold in the EU, including in the logistics, must meet recyclability requirements by 2030. Exporters need to redesign packaging, where necessary, to meet EU standards.
- Recycled at scale by 2035: Packaging must meet requirements for being recycled at scale, according to the EU's definition, by 2035.
Put simply, UK businesses exporting to the EU will need to re-evaluate their packaging processes and ensure compliance with the incoming legislation.
Sourcing recyclable materials, redesigning packaging, and registering with various EU authorities are all likely to increase costs.
Impact of PPWR on UK businesses importing from the EU
UK businesses importing products from the EU will also be affected by the PPWR, particularly if they are responsible for placing the goods on the UK market:
- Alignment with new EU regulation: UK importers may notice changes to packaging in the goods received from the EU, as suppliers adapt to new regulations. It’s likely for exporters to adopt the same packaging for their entire distribution network, regardless of destination country.
- Compliance with packaging rules: Imported products must also meet the UK’s packaging regulations. However, given the alignment between UK and EU on sustainability goals, many EU-compliant packaging materials will likely be accepted in the UK. This includes the UK EPR scheme. UK businesses may need to collaborate with their EU suppliers to ensure that imported packaging meets UK standards.
- Customs and border considerations: Importers may need to deal with border checks and declarations regarding new packaging compliance. Failure to meet the rules could lead to delays or penalties.
Importers will need to understand the packaging materials used by their EU suppliers and ensure that they are compliant with UK rules if they are ending on the UK market. This could involve liaising with suppliers on design changes and managing the administrative burden of registering packaging.
Five key takeaways for UK businesses
- Mandatory recyclability by 2030: UK businesses exporting to the EU must ensure that their packaging is recyclable by 2030. Specifics of this vary by packaging type. Non-compliant packaging will face sales bans.
- Extended Producer Responsibility (EPR): Businesses will need to register packaging and contribute financially to national waste management systems where required in the EU.
- Stay ahead of deadlines: Take a proactive, rather than a reactive approach to incoming deadlines on packaging. Ensure compliance in advance of deadlines to avoid delay.
- Packaging minimisation requirements: Packaging must use the minimum amount of material necessary. Businesses that rely on excessive or oversized packaging will need to adjust their designs to comply. This applies to all packaging related to the supply chain of a product, notably logistics.
- Communication is key: Speak to relevant stakeholders in depth about incoming regulations. Ensure that all parties understand the requirements and legal responsibilities are clear.
The PPWR introduces complex and far-reaching changes for packaging used in goods traded with the EU.
UK businesses must take action soon to ensure compliance, whether they are exporting to or importing from the EU. If necessary, consult with experts to ensure that your packaging processes are prepared for the transition, ensuring continued access to the EU market while managing costs and sustainability goals effectively.
