Packaging Waste Compliance Under EPR Regulations

The EU just published its official guidance on the Packaging & Packaging Waste Regulation (PPWR) and more businesses than expected are impacted. The European Commission has released a 57-page guidance document clarifying how Regulation (EU) 2025/40 will work in practice. With the regulation applying from 12 August 2026, the clock is ticking. Here's what businesses should know: → What counts as "packaging" is broader than you think. IV bags, candle containers, and adhesive process films may be excluded but dust bags for shoes and garments, flower pots sold with plants, and beverage cups filled at point of sale are likely in scope. → Know whether you're a "manufacturer" or a "producer." These are two distinct roles with very different obligations. Manufacturers are responsible for sustainability and labelling compliance across the EU. Producers handle extended producer responsibility (EPR) fees in whichever Member State the packaging becomes waste. → PFAS in food-contact packaging is banned from August 2026 with no transitional period for existing stock placed on the market after that date. → Re-use targets kick in from 2030, covering transport, beverage, and sales packaging. At least 40% of transport packaging must be reusable by then. For beverages, final distributors must offer at least 10% in reusable packaging. → Deposit Return Systems must be operational by 2029, targeting 90% separate collection of plastic bottles and metal cans. → Labelling rules are being harmonised and national sorting labels will no longer be permitted alongside EU harmonised labels from August 2028. The guidance is non-binding but reflects the Commission's interpretation. Businesses that move early will be far better placed when enforcement begins. #ppwr #packaging #sustainability #circulareconomy #euregulation #esg #compliance

Millions are spent on optimising the product. But not to optimise the packaging, this is all about to change. Packaging has been just a marketing expense. But in August 2026, the EU’s Packaging and Packaging Waste Regulation (PPWR) officially turns it into a legal liability. The EU is executing the most sweeping overhaul of packaging law in 30 years. ↳ Void Rule: Under the new rules, packaging cannot have more than 50% empty space. The times of shipping a USB cable in a shoebox-sized carton is over. ↳ Recyclability Baseline: By 2030, all packaging on the EU market must be recyclable in an economically viable way. If a package falls below the 70% recyclability threshold, it is banned from the shelves entirely. ↳ Reuse Mandate: The EU is attacking the B2B supply chain. By 2030, 40% of transport, industrial, and e-commerce packaging must be reusable (rising to 70% by 2040). ↳ Content Quota: You are going to be forced to buy back your own trash. By 2030, there is a 30% mandatory recycled content floor for all plastic packaging (scaling to 65% by 2040). Packaging waste in the EU grew 20% over the last decade. Regulators are now fighting back and regulating the design phase. When the 30% recycled plastic mandate kicks in for all packaging, the demand for food-grade recycled plastic will skyrocket. Are brands prepared for recycled plastic to become significantly more expensive than virgin plastic?

🚨 𝗧𝗵𝗲 𝗣𝗣𝗪𝗥 𝗴𝘂𝗶𝗱𝗮𝗻𝗰𝗲 𝗵𝗮𝘀 𝗮𝗿𝗿𝗶𝘃𝗲𝗱 Today the European Commission published its guidance document for the PPWR, alongside a comprehensive set of FAQs addressing the questions raised by stakeholders since the Regulation entered into force in February 2025. The FAQs are published in their first edition and will be updated on a rolling basis. On definitions, the guidance clarifies who is a manufacturer and who is a producer, two concepts that serve entirely different legal functions under the PPWR. The manufacturer, typically the brand owner or the entity that decides on packaging design specifications, is responsible for conformity with the sustainability and labelling requirements, and there is only one per packaging unit across the EU. The producer is identified market by market and carries the EPR obligations in the Member State where packaging is first made available. On branches: a branch without separate legal personality cannot qualify as an importer under the PPWR. Non-EU companies relying on EU branches will need to incorporate a subsidiary or, where required by the relevant Member State, appoint an authorised representative. On the definition of packaging, inclusion in Annex I is not sufficient and the functional test under Article 3(1) always prevails. IV bags and pre-filled syringes are excluded as they form an integral part of the medicinal product. Beverage cups sold empty to consumers are not packaging, but become service packaging when filled at a refill station. Dust bags for shoes and garments may qualify depending on their intended use. On PFAS, the guidance introduces a three-step enforcement approach for food-contact packaging: total fluorine quantification first, followed by pyrolysis-GC/MS analysis if needed, and then TOP analysis to verify compliance with the 25 and 250 ppb concentration limits. There is no stock exhaustion period: food-contact packaging placed on the market after 12 August 2026 must comply, regardless of when it was manufactured. On recyclability and substances of concern, the FAQs confirm that EN 13428:2004 will no longer create a presumption of conformity with the SoC minimisation requirements after 12 August 2026. The harmonised eco-modulation framework for EPR fees based on recyclability performance grades is still being developed through a delegated act. On reuse targets, the guidance addresses the HORECA sector's obligations on beverages, the scope of national exemptions, the position of custom-designed transport packaging, and the reuse targets in international trade. On deposit and return systems, it covers retailer obligations to accept deposit-bearing containers, the conditions for existing systems to qualify, and the relationship between the 2026 separate collection obligation and the 2029 DRS implementation deadline. Link to the FAQs: https://lnkd.in/eFM82C3B Guidance below 👇

The EU published its official interpretation of the Packaging Regulation today. Read it this afternoon. One thing kept coming back to me. Most commentary will focus on the packaging redesign requirements. That's not where I'd focus. It's a data project. To hit recycled content targets you need verified material data from your packaging suppliers. To prove PFAS compliance you need documented evidence from upstream. To calculate EPR fees accurately you need to know what packaging you're placing on which market, in what volumes. To sign your EU declaration of conformity, you, the brand, are solely legally responsible. Even if a supplier drafted it. And the Commission has been explicit about something else. The manufacturer isn't whoever physically makes the packaging. It's whoever owns the trademark on it. You cannot outsource this. You cannot point upstream if something is wrong. The obligation sits with the brand. You can't sign off on data you haven't verified. This is the same pattern we've seen with FLPA. With EUDR. With DPP. The regulation sets the deadline. The data infrastructure takes time to build. Circularity without traceability is just aspiration. Links to the full guidance document in the comments. #PPWR #PackagingRegulation #SupplyChainTransparency #Traceability #Circularity #Sustainability #Fashion #EUDR #DPP

𝐓𝐡𝐞 𝐄𝐔 𝐏𝐚𝐜𝐤𝐚𝐠𝐢𝐧𝐠 𝐒𝐡𝐚𝐤𝐞-𝐔𝐩: 𝐖𝐡𝐚𝐭 𝐘𝐨𝐮 𝐀𝐜𝐭𝐮𝐚𝐥𝐥𝐲 𝐍𝐞𝐞𝐝 𝐭𝐨 𝐊𝐧𝐨𝐰🧑⚖    ❎ The Big Deadlines 🔹By 2030: All packaging placed on the EU market shall be designed for recycling (Design for Recycling criteria to be adopted for each packaging category by end of 2027) and categorized according to recyclability performance grades A, B and C. 🔹By 2035: Recycled-at-scale requirements take effect; focusing on separate collection, sorting into specific waste streams and leading to recycling at scale for defined waste streams. That means packaging must be recyclable at scale across the EU, not just in theory. 🔹By 2038: Only recyclability performance grades A and B will be allowed. ❎ Minimum Recycled Content Targets in Plastics: 🔹By 2030: 30% for PET bottles and contact sensitive packaging from PET, 10% for contact-sensitive packaging other than PET, and 35% for other plastic packaging.  🔹By 2040: Targets will be increased, eg. to 50% recycled content in contact sensitive packaging from PET. ❎ Reusable Packaging Targets: 🔹Not only for beverage distribution but also for transport packaging, which will have big impact on all stages of the value chain.          ❎ Restrictions (“bans”) from 2030: 🔹Think mini hotel toiletries, very lightweight plastic bags, single-portion condiment packs for on-site consumption. ❎ Harmonised Labelling: 🔹One EU-wide disposal label on packaging + matching bin labels from 2028 (reuse labels from 2029).      And here’s the kicker for food producers... For the first time, the compliance burden doesn’t sit with packaging suppliers - it sits with you (the brand owner/manufacturer/importer who places packaging on the market).  That means:  ✅ YOU must prove your packaging meet PPWR requirements.   ✅ YOU will need supplier data, to assess recyclability performance grades for YOUR packaging unit, and to declare achievement of recycled content targets.   ✅ Technical documentation and EU declarations of conformity are mandatory for YOU.      What this means for business?   ✨ You can’t “design pretty” first and think about recycling later.   ✨ “Recycle-ready” isn’t enough if the infrastructure doesn’t actually exist.   ✨ And for beverage and transport packaging? Reuse targets are no longer optional.  ✨ Single-use portion formats in HORECA and accommodation sector, and other formats, will get restricted.  ✨ Marketing claims must match law, not vibe.      This is the biggest packaging shake-up in decades.   If your packaging strategy isn’t already aligned with PPWR… you’re not behind schedule. You’re behind reality.      We’ll be at FACHPACK (23.-25.9.2025). Come find the Wipak stand (Hall 4, Stand 4-312) and ask us the hard questions. Bring your toughest PPWR worries - we’ll bring the answers. Don’t forget to ask about DigitalChoice. Trust me, you want to get in on this!😉 #PPWR #sustainability #plastic #circulareconomy

PPWR guidance 2026: More clarity, more harmonization… but not less complexity The EU Commission has published its long-awaited guidance on the PPWR, providing more clarification for its application. While the final text largely confirms the interpretation already hinted at in the leaked version, it also reveals a broader regulatory direction: the Commission is determined to strengthen harmonization across the EU, and preserve limited flexibility for Member States in specific areas. Here are five takeaways: 1. The distinction between “manufacturer” and “producer” The guidance clarifies that the manufacturer responsible for ensuring compliance with PPWR sustainability and labelling requirements is not necessarily the same economic operator as the producer responsible for EPR obligations. The producer is the entity that places packaging on a Member State market where it is expected to become waste and is therefore responsible for registration, reporting and EPR fee payments. For companies operating across multiple EU markets, this clarification has significant implications for compliance strategies and reporting systems 2. Reporting obligations The guidance reinforces the importance of identifying where packaging is first made available, where it becomes waste and which economic operator carries the EPR obligation. 3. Harmonized sorting labels are coming, and national labels may be reaching their limits One of the most consequential interpretations concerns Art 12. The Commission clearly states that harmonized sorting labels will be exhaustive and fully harmonised across the EU. Once applicable, Member States should no longer maintain parallel national sorting instructions alongside the EU label. This position is particularly noteworthy in light of recent developments. The Commission has challenged aspects of France’s Triman/Info-tri scheme and recently issued a detailed opinion under the TRIS procedure regarding Germany’s proposed PPWR implementation measures. Both cases signal increased scrutiny of national initiatives . 4. Compostability remains harmonized, but not entirely The guidance confirms that certain packaging formats must be compostable under PPWR. At the same time, Member States retain flexibility to require additional packaging applications to be compostable where appropriate bio-waste collection systems and treatment infrastructure exist 5. Harmonization does not mean uniformity Perhaps the most important message from the guidance is that PPWR creates a common EU framework, not a fully centralised system While the Commission is pushing for harmonized rules on labelling, producer identification and sustainability requirements, Member States continue to retain flexibility in areas such as compostability, waste collection systems and enforcement approaches In short, the guidance shows that PPWR is not just about packaging rules. It’s also about finding the right balance between EU-wide harmonization and national flexibility

Five major German food retailers (Lidl in Germany, REWE Group, Aldi Nord, Wasgau, and Norma) have just written to their private-label suppliers telling them that the suppliers, not the retailers, are the "producers" under PPWR. The text of Article 3 does not support this, and if these letters end up holding contractually, around 42% of Germany's licensed packaging volume loses its clear EPR funder from the second half of 2026 onwards. The story broke today in Lebensmittel Zeitung, reported by Hanno Bender, Gerrit-Milena Falker, Tanja Fries and Hans Jürgen Schulz. Each retailer used slightly different wording, but the substance is identical: they are stepping back from producer status and pushing the obligations down to whoever is contract-manufacturing for them. 🤐 Well, in PPWR Article 3(1)(13), "manufacturer" is set to include any entity that has packaging "designed or manufactured under its own name or trademark, regardless of whether any other trademark is visible." That is the textbook description of how private-label products work. Zentrale Stelle Verpackungsregister (ZSVR), the German regulator that runs the packaging register, has put it in equally plain language: if you have a contract packager design or manufacture packaging under your own brand, you are the manufacturer. Article 3(1)(15) then makes that manufacturer, when based in the relevant Member State, the producer for EPR purposes. Whether you call yourself a distributor in your supplier contract is, on the face of the regulation, beside the point. The timing and the power dynamic is honestly worrying! Lidl is asking suppliers to confirm "PPWR-compliant producer labelling" by 8 June, two months before PPWR even applies, while the regulator has not issued guidance and no court has reviewed any of this. Lidl, Rewe and Aldi Nord have the contractual leverage to make their interpretation stick whether it is correct or not, and a mid-sized supplier saying "we disagree" risks losing one of its biggest accounts in the same year PPWR starts. 😬 The bill at the back of all of this lands on the dual systems. Peter Feller of the BVE, in the LZ piece, called it a "fundamental" issue, and he is not exaggerating. Forty-two percent of licensed packaging in Germany is private-label. If the retailers walk away from that share of the EPR contribution and the suppliers also resist, the collection and recycling infrastructure that PPWR itself depends on to hit its targets quietly loses its financing base in the same quarter the regulation goes live. A regulation that took years of EU negotiation should not, 75 days before its application date, leave room for the largest retailers in its biggest market to stake out a position that the verbatim text and the competent national regulator both contradict. Folks, this is not an interpretation problem, and it might draft problems with very German consequences. #PPWR #PackagingCompliance #EPR #VerpackG #VerpackDG

Sometimes doing the right thing means making a really tough choice… You know when you read a Sunday paper article that makes you nod so hard you nearly spill your coffee? That was me this weekend reading (and actually contributing to!) The Sunday Times column about the chaos surrounding EPR (Extended Producer Responsibility) regulations. Now, in principle, I’m 100% behind the idea. We all have to work together to reduce the impact of packaging waste. Totally agree. But the implementation? Let’s just say it’s been about as smooth as a giraffe on roller skates. The system sounds simple, make producers responsible for the cost of collecting and recycling their packaging. But in reality, it’s a labyrinth of tonnage thresholds, admin nightmares, and fees that can suddenly turn a small ethical brand into a “large producer” overnight. For us, it had a very real impact. We had to make the really tough call to move one of our products from glass to recycled plastic. Now before anyone grabs a placard, hear me out. I’m not about to start a glass vs plastic debate (that one’s reserved for people armed with total life cycle spreadsheets). But here’s the simple maths for EPR: • Glass is typically 6–7 times heavier than recycled plastic. • Yet EPR fees for glass are only about 2x higher. • That extra weight tipped our total packaging tonnage over the 50 tonne threshold, which turned us from a small producer into a large producer. By switching to recycled plastic, we move back into small-producer status; which means no EPR fees (well, after a year, but that’s a different rant). The decision wasn’t about changing our principles. It was about survival. We couldn’t absorb those fees and stay competitive, especially when we’ve already lost business to cheaper competitors using lightweight plastic bottles filled mostly with sugar, chemicals, and water, which we refuse to do. We also didn’t want to hike prices for consumers already struggling with cost-of-living pressures. We’ve quietly absorbed so many hits recently (cocoa prices, National Insurance changes, energy costs) because we know every penny counts for people right now. So yes, we made the move. Not because we wanted to, but because sometimes sustainability isn’t black and white , it’s fifty shades of compromise and carbon maths. Huge thanks to Stu Macdonald and the ManiLife | B Corp™ team, Katie Jewitt at MOMO Kombucha , and Jim Bligh at The Food and Drink Federation for keeping this conversation alive, and to Hannah Prevett The Sunday Times for shining a light on how these policies, however well-intentioned are hitting small ethical businesses hardest. Now if you’ll excuse me, I’m off to calculate next year’s EPR data submission… and possibly cry into a cup of recycled coffee. ☕️💸 #EPR #Sustainability #CircularEconomy #SmallBusiness #FoodAndDrink #Packaging #SweetFreedom #Bcorp #SundayTimes

If your packaging can't prove it belongs on the EU market by August 12, 2026, it won't be there on August 13. That is the hard reality of the EU's Packaging and Packaging Waste Regulation, known as PPWR. This is directly applicable framework across all 27 EU member states. There is no national transposition. There is no grace period. Non-compliance by a single supplier creates immediate exposure for brand owners and importers across the entire value chain. Here is what makes this a supply chain story, not just a regulatory one: only about 10% of companies currently meet PPWR requirements. For CPG and retail, the operational implications are massive. Optimized packaging under PPWR targets could unlock annual savings of roughly 20 to 50 billion euros across the EU. Yet the compliance burden is immense: PFAS restrictions on food-contact packaging take effect in August 2026, every packaging type placed on the EU market will require a signed Declaration of Conformity, and Extended Producer Responsibility registration must be active in each member state where products are sold. The question for US companies is not whether they operate in the EU but whether their packaging reaches an EU consumer. For American brands selling through importers, distributors, Amazon FBA, or direct-to-consumer e-commerce, PPWR compliance is becoming a major priority because obligations depend on how the packaged product enters the EU market, not where the company is headquartered. A large number of US-based multinationals will directly or indirectly need to comply. The supply chain implications run deep. Supplier relationships are becoming contractually data-intensive, as suppliers are now legally required to provide all documentation necessary for manufacturers to prove compliance. IT systems, master data, supplier relationships, quality management, and compliance processes must all be structured so that information can be consistently recorded, updated, and verified. This means PPWR is not a packaging redesign exercise alone. It is a governance task that touches market access, cost control, reputation, and end-to-end supply chain visibility. For brands operating across borders, the biggest risk is fragmented, reactive compliance, while the biggest opportunity is unifying packaging strategies now by using the EU's high bar as a design baseline to reduce long-term costs, complexity, and regulatory exposure. The companies that treat PPWR as a catalyst for supply chain intelligence rather than a checkbox exercise will be the ones that maintain market access, reduce EPR costs, and build competitive advantage in a world where packaging is no longer an afterthought. It is a regulated product. If you're struggling with PPWR, reach out to me! What is your organization doing to prepare? I would love to hear how supply chain, procurement, and sustainability teams are approaching this. Drop your thoughts below. 👇

Sometimes an email hits your inbox, and you know instantly: Most founders are about to get blindsided. KeHE Distributors sent out a notice this morning about EPR—Extended Producer Responsibility—and I want to give you the context most people won’t. EPR laws weren’t created to make your life harder. They exist because states are overwhelmed with packaging waste, recycling systems are underfunded, and taxpayers have been footing the bill for decades. So states like California, Colorado, Oregon, and Washington finally said: “If you put packaging into our state, you’re responsible for tracking it, reporting it, and helping pay for the cost of managing it.” But here’s the part the email makes painfully clear: You are the Producer. Not KeHE. Not UNFI. Not the retailer. If your name is on the label, the responsibility belongs to you. And most emerging brands are completely unprepared for what that actually means. You’re now required to: • register with Circular Action Alliance • report your packaging by state • pay the fees • and absorb any fines if something goes wrong Deadlines in CA, CO, and OR have already passed. And yes—distributors will pass penalties through as deductions. They have no choice. I’m sharing it because I’ve watched too many founders get hurt by things they didn’t even know existed. If you run a brand, here’s what you should do today: 1️⃣ Register with CAA 2️⃣ Pull your “brand sales by state” report in KeHE CONNECT 3️⃣ Identify which SKUs are landing in EPR states 4️⃣ Build a simple internal process for packaging data 5️⃣ Assign one owner—someone has to hold it Don’t let this be a landmine that takes you out. You’re building something that matters. Protect it. Stay ahead of it. And if you need clarity, ask for it—this is exactly the work my team at Vdriven does every day. Stay proactive. Stay informed. This is one of those moments where doing the right thing early saves you a lot of pain later.