PPWR Regulation: what are the impacts on waste management and ESG reporting?

The European packaging industry is undergoing an unprecedented transformation. Officially entered into force on February 11, 2025, Regulation (EU) 2025/40, more commonly known as the PPWR (Packaging and Packaging Waste Regulation), is completely redrawing the rules of the game for all economic stakeholders. This new regulatory framework has been generally applicable since August 12, 2026, the date from which no non-compliant packaging may be placed on the European market, barring transitional exceptions.

This is a highly technical piece of legislation that goes far beyond minor adjustments to existing standards. The European Union's objective is clear: drastically reduce packaging waste production, accelerate the transition to a circular economy, harmonize requirements across the 27 Member States, and limit the use of virgin resources and substances of concern.

In this article, we provide a comprehensive breakdown of the PPWR, from its impacts on eco-design to its major consequences for Extended Producer Responsibility (EPR) and your non-financial reporting.

From end-of-life to eco-design: a fundamental paradigm shift

To fully grasp the scope of the PPWR, it must be viewed within its historical and regulatory context. Under the former Directive 94/62/EC, the focus was primarily on recycling and end-of-life packaging management. The PPWR regulation mandates a radical paradigm shift. Legislation now addresses the packaging life cycle holistically by integrating prevention, reuse, design-for-recyclability, the incorporation of recycled content, and the strengthening of extended producer responsibility.

The PPWR covers absolutely all packaging placed on the EU market, regardless of the material used (plastic, cardboard, glass, metal, wood) and the final application (food, industrial, logistics, e-commerce, or pharmaceutical). This includes sales (or primary) packaging, grouped (secondary) packaging, as well as transport packaging such as pallets or IBCs.

Who is actually affected by the PPWR? The European Commission's clarification

The packaging value chain involves many stakeholders: manufacturers, industrial market players, importers, distributors, e-retailers, and logistics providers. To avoid any ambiguity regarding individual responsibilities, the European Commission published a crucial guidance document on June 10, 2026.

This document stipulates that there is only one "packaging manufacturer" in the supply chain within the meaning of the PPWR. For example:

• Sales and grouped packaging: The manufacturer, as defined by the regulation, is the person who fills the packaging, which is most often the product brand owner.

• Packaging bearing no trade name or brand:  The manufacturer is either the material supplier or the person who places the packaged products on the market. The deciding factor is who placed the order and defined the technical design specifications.

• Imported packaging: Importers and distributors assume responsibility when they place packaging on the market under their own brand, or if they modify packaging in a way that affects its compliance.

The four pillars of action: Reduce, Reuse, Recycle, Incorporate

The PPWR regulation is based on quantified and binding targets that will transform the manufacturing, consumer goods, agri-food, and logistics industries.

1. Prevention and eco-design: reducing at the source and limiting single-use formats

The EU aims to reduce packaging waste per capita by 5% by 2030, 10% by 2035, and 15% by 2040 (compared to the 2018 baseline). This requires strict eco-design: reducing weight and volume, eliminating unnecessary packaging, and strictly limiting empty space to a maximum of 50%. Furthermore, a targeted ban on avoidable single-use formats will come into effect on January 1, 2030 (examples: packaging for fresh, unprocessed fruits and vegetables under 1.5 kg, miniature hotel cosmetic bottles, individual sauce packets in restaurants, etc.). Starting in 2026, the concentration of heavy metals and PFAS (per- and polyfluoroalkyl substances) will be formally limited.

2. Mandatory recyclability: the introduction of performance classes (A, B, and C)

Recyclability is becoming a design requirement. The PPWR introduces a performance system based on recyclability classes (A, B, and C). By 2030, all packaging must be designed to be recyclable. From 2038, requirements will tighten: packaging must reach at least class B, effectively excluding class C from the European market.

3. Circular economy: the obligation to incorporate recycled plastic materials

To close the loop of the circular economy, the PPWR mandates the incorporation of recycled plastic based on contact sensitivity (food, cosmetic, technical). From January 1, 2030, companies will be required to incorporate between 10% and 35% recycled plastic. For example, this rate will be 30% for single-use plastic beverage bottles and contact-sensitive PET packaging. These targets will rise to 65% by 2040.

4. Transition to reusable packaging: new European reuse quotas

For the first time, the PPWR sets quantified targets for reuse at the European level. Stakeholders must strive to reach 40% reusable transport packaging by 2030, and 70% by 2040. However, a delegated decision from February 2026 exempts certain operators from the 100% reuse requirement for pallets and straps.

Impacts on waste management and the transformation of EPR

The PPWR imposes binding requirements at every stage of the packaging lifecycle, from design to material recovery. Regarding waste management, it introduces new rules:

• Market placement: You will need to register as a producer in each Member State. No registration, no market access. Crucially, contribution to the EPR (Extended Producer Responsibility) scheme will now be modulated based on the packaging’s recyclability class (A, B, or C). This framework integrates directly with each Member State's existing national packaging laws and domestic EPR registries.

• Collection and Treatment: Separate collection will be mandatory across all territories and for all materials, with bins labeled according to a unified EU standard by 2028. Finally, incineration and landfilling will be prohibited for packaging designed for recycling, requiring a 70% overall recycling rate for packaging waste by 2030.

Concrete impacts on ESG reporting and the CSRD

The PPWR is no longer just a matter of environmental compliance; it has become a strategic issue for ESG reporting, particularly for companies subject to the CSRD.

As part of the double materiality assessment, the issues related to this regulation can be analyzed through both impact materiality and financial materiality. On one hand, the text addresses environmental impacts (plastic pollution, resource depletion) and offers opportunities (new reuse models, product innovation). On the other, it can create significant financial and operational risks: redesign costs, massive industrial investments, or dependence on recycled material supply chains.

Under the CSRD directive, the PPWR directly informs the disclosure requirements of two standards ESRS key points:

• ESRS E2 (Pollution): Companies will be required to disclose the use of Substances of Very High Concern (SVHC) present at concentrations above 0.1% by weight, in accordance with REACH. This applies to components historically used in packaging, such as HBCDD in polystyrene foams, certain phthalates (DEHP, DBP) in plastic blister packs, and BPA, which has been banned in food packaging at the European level since July 2026.

• ESRS E5 (Resource Use and Circular Economy): Reporting will require full transparency regarding the weight of key materials used, the percentage of secondary resources (recycled materials) incorporated, and the recyclability rate planned at the design stage. Companies must also detail the proportion of their waste diverted from disposal or, conversely, sent for disposal.

Penalties: The technical file as your first line of defense

The timeline is tight and the risks of non-compliance are real. Regulation (EU) 2025/40 requires each Member State to establish penalties by February 2027 that are "effective, proportionate, and dissuasive".

The most critical point to watch: In the absence of a technical file, your packaging is presumed non-compliant. Inspections will systematically rely on documentation. The PPWR declaration of conformity and the associated technical file will serve as your first and primary line of defense in the event of an audit.

In conclusion, given the unavoidable lead times for product design, supply chain transformation, and supplier contracting, companies must begin their compliance efforts today. The PPWR is not just a regulatory update; it is a fundamental overhaul of the packaging economy in Europe.