Navigating the Packaging Landscape: Preparing for PPWR and Beyond

• France introduced the Triman, a mandatory sorting label which aims to help the consumer to identify the packaging material with its designated receptacle.   

• Italy and Bulgaria have mandated the alphanumeric material system (Decision 129/97/EC). Producers must indicate the packaging material using the relevant identification code. The system is recognised across Europe and can voluntarily be applied to packaging in all other EU member states.  

• Spain implemented a mandatory labelling system from January 1 2025. It applies to all consumer packaging and is expected to reflect Spain’s “Punto Limpio” consumer packaging disposal network. The labelling format is flexible but must inform consumers of how to dispose of their packaging – typically using a colour coding system identifying material type with the correct bin.  

• The Green Dot has not been a mandatory label since January 1 2023, with Spain being the last country to revoke the mandatory status.  

However, these systems are changing to align with the newly implemented Packaging and Packaging Waste Regulation (PPWR), which is due to take effect from August 2026 (implemented in February 2025 and superseding PPWD) introducing an array of packaging requirements for producers, importers, and manufacturers alike.   

PPWR – Timeline for Implementation  

PPWR was implemented in February 2025 and will take effect from August 2026. 

Changes to packaging takes time, on average a minimum of 2 years, so businesses need to begin preparing for PPWR now. 

• Map where SKUs are sold and complete EPR registrations.
• Redesign packaging and labelling, plan for EU harmonised labels by 2028, validate recycled content, assess recyclability, and account for eco-modulation costs.
• Collect detailed packaging data for compliance and cost optimisation.
• Model EPR fee scenarios to budget effectively; testing material choices early will support greater circularity and savings. 

Ways that businesses can improve their practices to become more sustainable and meet regulatory targets 

Despite the sometimes-overwhelming levels of packaging regulation, businesses can get ahead of the requirements, meet stakeholder needs, and gain the competitive advantage through targeting packaging sustainability. 

Life cycle thinking: designing with the end in mind

Life cycle thinking is a critical skill when it comes to packaging and reducing environmental impact. Around 80% of a product’s environmental impact is determined at the design stage, making this the single most influential moment in a package’s life. A life cycle perspective goes beyond recyclability and asks a broader question: What is the total footprint of this packaging system from raw material to end of life? Design teams should evaluate not just material choice, but also production energy, sourcing, logistics, consumer use, and disposal as well as review ‘the true purpose’. Design decisions must always balance functionality, safety, and circularity. 

In an industry where freight and storage are major contributors to a product’s carbon footprint, packaging efficiency often delivers quick wins. Maximising the ratio of product to packaging, for example, through efficient palletisation, lighter secondary packaging, or optimised pack shapes, can dramatically cut emissions, while also cutting EPR costs due to lighter packaging.

Regulations like PPWR will increasingly encourage this broader lens beyond just recyclability, as discussed above, with other criteria such as carbon intensity, recycled content, and reusability all shaping compliance costs. Taking a holistic view now helps future-proof packaging strategies as the definition of “environmentally preferable” evolves.

Prioritise waste prevention: Reuse 

Under the waste hierarchy, reuse sits above recycling as the more sustainable option. Although not always straightforward, reuse and refill models are gaining traction as consumer attitudes shift, reverse logistics improve, and business rethink strategy. From small scale longstanding milk bottle reuse to trials by major UK retailers such as Asda with a range of brands across different sectors, real-world examples demonstrate that reuse can deliver both carbon and cost savings. The Belgian beer bottle system is a great example of reuse, which for years has demonstrated effective reuse, achieving multiple refill cycles with minimal material loss resulting in a significantly lower life cycle footprint than single-use equivalents.

Reuse could take different forms:

• Closed loop models within controlled environments such as hospitality or events where containers can be easily returned and washed. 
• Open loop refill schemes for concentrated or bulk products, reducing packaging per serving. 

Growing research, supported by organisations like WRAP, is mapping the environmental and business benefits of refill. The key is to align reuse design with logistics capability and consumer convenience while investing in durable packaging materials and formats that can withstand repeated cycles and keeping transport emissions in check.

Design for recyclability 

For now, designing for recyclability remains the most direct and measurable way to reduce packaging impact and meet emerging targets. The aim is simply to ensure that a pack can be readily collected, sorted, and reprocessed within existing infrastructure. Free and widely recognised tools such as RecyClass provide a valuable starting points and will likely form the basis of recyclability definitions adopted by PPWR. Its guidance translates the science behind collection, sorting, and recycling into clear design rules such as discouraging, for example, full-body sleeves on PET bottles due to sorting challenges or incompatible multilayer materials for reprocessing issues. Applying these frameworks early in the design process can help companies achieve the recyclability grades that future regulation and EPR schemes will demand.

Innovation remains essential, but it must be anchored in circular design principles. Biodegradable or bio-based alternatives, for example, can offer some environmental benefits but may not yet fit within established recycling systems, and are therefore only suitable in some scenarios. 

Enabling circularity: recycled content

Incorporating recycled content is another tangible step toward circularity, although challenges remain, particularly in securing consistent food grade supply and managing costs. Using recycled material can significantly lower carbon footprint and demonstrate visible commitment to sustainability.

For PET bottles, rPET availability is improving across Europe, driven by Deposit Return Schemes and clearer quality standards. Even modest percentages of recycled material can reduce lifecycle emissions and enhance a brand’s sustainability credentials. Examples of sandwich or A-B-A structures in packaging can enable recycled content while meeting food safety standards. As regulatory targets tighten, for 30% rPET mandated in beverage bottles by 2030 under the PPWR, early adoption helps smooth the transition and strengthen supply chain relationships.

Thoughts on the rules or practices outside of Europe 

It is widely considered that the EU is generally leading the way with regards to packaging practices and requirements, and it is likely that PPWR requirements will have a global impact on packaging. 

Looking to America and Canada, EPR for packaging is moving through a state-by-state roll-out with the likes of California, Oregon, Colorado, Minnesota, Maryland, and now Washington leading the way. Registration, reporting, eco-modulation, and recyclability assessments are all set to be regulated at state level. For businesses selling or planning to sell into the US, mapping EPR exposure and tracking developments in other states should be prioritised.

Canada similarly has EPR systems for packaging in place already which are regulated at provincial and territorial levels. EPR costs are set to rise, and data reporting obligations are expected to become more granular. A DRS system is also in place in many provinces.

Australia has a mandatory Container Deposit/Refund Scheme (CDS) which is administered nationally. Since 1 May 2025 when Tasmania’s scheme began, Australia reached national coverage. If your business is the first to supply eligible drinks (generally 150ml-3l, including PET, glass, LPB cartons, cans) into a jurisdiction, you must register SKUs, pay the deposit and scheme fees, report your volumes, and keep your labels compliant. The labelling requirements are mandatory and require businesses to display a compliant barcode and a refund mark stating: “10c refund at collection depots/points in participating State/Territory of purchase”.

On the EPR front, Australia does not yet have a fully mature EPR scheme for all packaging. The Australia Packaging Covenant Organisation (APCO) is operating a voluntary industry-led scheme which is following EPR-style principles. Reform work is ongoing with a mandatory EPR scheme and/or mechanisms gaining support.

Expectations for packaging in the future: what is to come?

The future of packaging will be shaped by data, innovation, and collaboration. Comprehensive data collection is becoming non-negotiable, and businesses must establish baselines, track progress, and measure performance across their packaging portfolios. Companies that build strong data systems and engage suppliers early will adapt more easily to changing EPR and sustainability regulations. Robust data systems will underpin best-practice reporting, helping companies demonstrate accountability while gaining a competitive advantage through proactive compliance and transparency. 

As regulations tighten, costs increase, and environmental expectations grow, the sector will need to continue to move up the waste hierarchy, prioritising waste prevention and reuse. Future strategies will likely emphasise innovative reuse solutions, with packaging designed for circularity and minimal waste. Wider developments such as the inclusion of waste incineration within the Emissions Trading Scheme (ETS) will further drive the need for recyclable or reusable materials to further mitigate waste management costs. In addition to this, a collaborative supply chain will be essential, leveraging tools like digital product passports to enhance transparency and traceability.

Success will require a cross-functional approach, aligning sustainability, packaging design, marketing, and supplier expertise. By integrating environmental goals with functionality from the design stage, producers can meet both regulatory demands and consumer expectations, creating packaging that protects the product while minimising environmental impact.

Beyondly is an environmental compliance scheme and sustainability specialist, offering UK and international packaging compliance services and guidance, as well as a range of bespoke sustainable packaging services to help your business get ahead of regulation, stakeholder requirements, and achieve best practice in the world of packaging.

From PPWR readiness assessments, to packaging screening and analysis; our team of compliance, packaging and data experts are here to help you navigate the complexities and prepare as the legislation evolves. Take a look at our expert solution to PPWR readiness and get in touch with our friendly team at [email protected] or 01756 794951 to discover how Beyondly can support you on your journey to PPWR compliance.