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PPWR - Packaging and Packaging Waste Regulation

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The European Union’s Packaging and Packaging Waste Regulation (PPWR) marks one of the most consequential shifts in environmental regulation affecting packaged goods in decades. Designed to eliminate waste, transform packaging sustainability and harmonize standards across Europe, PPWR will impact every step of the product lifecycle and almost all steps in the value chain, from design and sourcing to production, labelling and go-to-market execution. 

PPWR replaces the long-standing Packaging and Packaging Waste Directive with a directly applicable EU regulation, meaning the same rules apply uniformly across all EU member states without national interpretation or delay. Its overarching ambition is clear: To decouple economic growth from packaging waste, ensure packaging is fit for a circular economy, and improve transparency across the (packaging) value chains. 

Cost management - By anticipating (changing)EPR schemes, especially brand owners can better plan for costs related to packaging waste management, potentially leading to reduced or mitigated operational expenses in the long term. 

Market differentiation - Manufacturers can differentiate themselves by exploring and implementing innovative sustainable technologies and materials. This can lead to improved product performance and customer satisfaction. Regulatory compliance - Non-compliance of local and international packaging regulations can lead to significant fines, legal repercussions, and damage to the company’s reputation. 

Sustainability /circularity goals - Utilize regulations to align packaging practices with environmental goals. This can enhance brand image and loyalty among environmentally-conscious consumers.

With a phased implementation from 2026 and multiple targets towards 2030 and beyond, PPWR is not a one-off compliance exercise. It is a structural shift that demands long-term operational and digital readiness, particularly for companies with a large and complex portfolio. Companies must realise that non-compliance isn’t just a regulatory risk, it’s a business continuity risk.

A critical milestone is the Declaration of Conformity (DoC) required by August 2026, which obliges companies to demonstrate at product and packaging level that (future) PPWR requirements are met based on verifiable data.

PPWR introduces binding requirements around:

  • Packaging (waste) reduction over the packaging lifetime, e.g., restricted packaging sizes, and reusability targets
  • Improved material circularity, e.g., recyclability, recycled or biobased materials, and restriction of hazardous substances
  • Harmonized labelling and reporting, e.g., Declaration of Conformity and harmonized standards
  • Increased economic responsibility, e.g., harmonized EPR schemes and fee eco-modulation

At Deloitte, we can support you every step of the way. We bring a cross functional lens, combininglegal advice with business implications and a technology view. ​

Contact us today to learn more! 

Our thinking

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Helene Geijtenbeek

Helene Geijtenbeek

Partner
+31882888962
Dieuwertje Ewalts

Dieuwertje Ewalts

Director | Circularity lead Deloitte NL
+31882886048
Rozemarijn Bloemendal

Rozemarijn Bloemendal

Partner | Legal
3188 288 3661