The PPWR in 2026: Uncertainties and the Path to Practical Implementation

With the PPWR, the new EU Regulation on Packaging and Packaging Waste, the industry faces profound changes whose full impact is only gradually becoming visible.

In his keynote speech at the Future Packaging Day hosted by Greiner Packaging, Dr. Dennis Bankmann, Managing Partner at Emerging Motif, provided a comprehensive overview of what the PPWR already regulates, the unresolved technical details regarding recyclability assessment, and the role that European standardization will play in this context. His analysis made one thing clear: the regulation has been adopted, but its concrete implementation is only just beginning.

The PPWR is part of the European Green Deal and replaces the previous directive, the PPWD. It becomes applicable in August 2026 but includes various requirements and obligations that will be phased in at later dates, including 2030, 2035, and 2038.

Due to its broad applicability to nearly all packaging placed on the EU internal market, the large number of technical requirements, and the gradual implementation timeline, the PPWR is considered one of the most complex legislative projects ever undertaken by the EU.

The regulation pursues the following objectives:

• Reduce packaging waste
• Promote reuse
• Improve recyclability and
• Increase the use of recycled materials

It introduces a wide range of new rules: from packaging design, minimization obligations, and reuse requirements, to recycled-content targets and compostability, all the way to the handling of substances of concern.

Bankmann highlighted that while the broad contours of the regulatory framework are set, such as requirements for heavy metals and PFAS limits, compostability, or restrictions on certain single-use items, key technical details are still missing. These include:

• Criteria for Design for Recycling
• Test methods and protocols for assessing recyclability
• Methodology and metrics for determining recyclability
• Procedures for recycling-at-scale assessment
• Requirements for calculating and verifying recycled content
• Specifications for reusable packaging

These open points will only be clarified through secondary legislation and European standards - a process that will unfold over the coming years.

The technical foundations are currently being developed by several actors. On the EU side, these include the European Commission, particularly the Directorates-General ENV and GROW, and the Joint Research Centre (JRC). In addition, agencies such as ECHA and EFSA are working on individual regulatory aspects and their implementation.

A key role is also played by the European standardization landscape, above all CEN. It develops technical foundations that may later feed into secondary legislation, though they are not automatically legally binding. Final decision-making authority remains with the Commission.

CEN is currently working on a broad set of specific projects: from sorting and recyclability test methods to material-specific criteria for plastics, paper, glass, metals, and composite packaging. Particularly active are the committees TC261 (Packaging) and TC249 (Plastics), as well as their working groups, such as TC261/SC4/WG10 for plastic packaging and TC261/SC4/WG3 for cross-material recyclability assessment.

Many documents are already in the formal voting process; initial publications are expected in 2026. However, Bankmann emphasized that although these standards will provide significantly more clarity, they will not be perfect from the outset, simply due to the technical and systemic complexity, so further revisions are expected.