Sustainable Packaging in the EU: How the CEN Standards Implement the PPWR in Practice

The Packaging and Packaging Waste Regulation (PPWR) is the most comprehensive reform of European packaging legislation in almost three decades. It replaces the previous PPWD from 1994, whose national interpretations and implementations had resulted in a patchwork of differing rules. The PPWR resolves this: as an EU regulation, it applies directly and uniformly in all Member States, with little room for national deviations.

Its ambition is high: packaging must be designed in a way that it

• avoids waste,
• conserves resources, and
• enables true material circularity.

The PPWR therefore combines EU-wide uniform requirements with a fundamental realignment of the entire value chain, from packaging design to material use and disposal. It applies to all economic actors who manufacture, import, or place packaging on the EU market: raw material suppliers, converters, brand manufacturers, and importers.

To achieve this transformation, the PPWR is built on three structural pillars:

1. New and clearer definitions

   The regulation refines and updates many fundamental terms in the packaging sector. This creates a common language for all market participants, increasing transparency and ensuring that requirements are understood and applied consistently across the EU.

2. Concrete requirements, targets, and prohibitions

   The PPWR introduces specific obligations that will transform packaging design and material use across Europe. These include waste-reduction targets, recyclability requirements, mandatory recycled-content quotas, packaging minimisation rules, and uniform labelling obligations. At the same time, packaging formats deemed unnecessary or non-circular will be gradually restricted or banned. Important requirements already apply from August 2026, such as limits for substances of concern, identification markings, and the obligation to provide a Declaration of Conformity.

3. Harmonized procedures, documentation duties, and market surveillance

   To make these requirements effective, the PPWR specifies how companies must document and demonstrate compliance. This includes harmonised assessment methods, standardised technical documentation, and a common framework for market surveillance and enforcement. Many technical details will be defined step-by-step through supplementary legal acts.

While the PPWR sets the legal framework and objectives, the supplementary legal acts provide the details. 

In short: the PPWR defines WHAT must be achieved; the secondary legislation defines HOW it must be done. 

The European Commission has tasked the European standardization body Comité Européen de Normalisation (CEN) with developing harmonized standards that define how the sustainability requirements for packaging are to be implemented. These cover, in particular, requirements for recyclability, compostability, packaging minimization, and reuse. 

CEN works with experts from industry, research, and public authorities to develop technical standards that reflect the requirements of EU legislation. 

The CEN-Guidelines thus form the technical foundation for implementing sustainability goals in day-to-day practice. 

Why These Guidelines Are So Important

• They define objective technical criteria and test methods.
• They establish harmonized assessment procedures, enabling companies, laboratories, and authorities to reach consistent results.
• They facilitate conformity assessment by showing how the PPWR’s legal requirements can be tested and documented based on clear technical criteria.
• They enable European harmonization by reducing technical discrepancies and national deviations.

Practical Relevance

For manufacturers, brand owners, and packaging converters, the CEN Guidelines are not merely recommendations, but an essential reference that:

• already serves as a basis for internal design decisions,
• provides the technical foundation for future conformity assessments,
• enables consistent interpretation of PPWR objectives.

The PPWR structures the requirements for packaging into several key articles. Each article addresses a specific topic that determines what companies must comply with in the future. Together, these articles influence a company’s entire packaging strategy. 

The PPWR will not take effect all at once but will unfold in several stages over the coming years. The goal is to give companies sufficient time for planning and implementation while still setting clear deadlines. 

• 11 February 2025: Entry into force of the PPWR
• 12 August 2026: PPWR rules fully apply in all EU Member States
  Entry into force of:
  • Limits for substances of concern (SoCs)
  • Conformity assessment & Declaration of Conformity
  • Reuse systems for reusable packaging
  • Labelling and information requirements
  • Producer registration obligations
• 12 February 2028:
  • Obligations for compostable packaging
  • Restrictions on empty space in sales packaging
• 12 August 2028:
  • Harmonized labelling obligations (sorting pictograms)
• 1 January 2030: Implementation of core requirements
  • Recyclability
  • Minimum recycled content
  • Packaging minimization requirements
• 2035: Introduction of “recycled-at-scale” assessment for actual recyclability
• 2038: Only packaging with recyclability grades A or B is permitted
• 2040: Further tightening of recycled-content targets