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The EU’s Packaging and Packaging Waste Regulation is changing how packaging is designed, manufactured, and evaluated. For brands and manufacturers, the transition introduces new compliance requirements and a broader shift in the economics of packaging.
On 12 August 2026, the European Union's Packaging and Packaging Waste Regulation (PPWR), formally known as Regulation (EU) 2025/40, began applying across the EU.
The regulation represents one of the most significant changes to European packaging legislation in decades. Replacing the previous Packaging and Packaging Waste Directive, it establishes a more harmonised regulatory framework covering packaging design, material composition, recyclability, waste prevention, and producer responsibility.
The scale of the challenge is considerable. According to the European Commission, without additional intervention, packaging waste in the EU was projected to increase by 19% by 2030, with plastic packaging waste potentially growing by 46%.
The PPWR aims to reverse this trajectory by addressing packaging throughout its life cycle. Its implications extend well beyond European manufacturers. International packaging suppliers, exporters, and brands placing packaged products on the EU market must also consider the applicable requirements.
For the global packaging industry, regulatory compliance is becoming an increasingly important factor in material selection, product development, and long-term supply chain planning.
Although the PPWR began applying in August 2026, many of its major provisions will take effect progressively over the coming years.
Recyclability by 2030
One of the regulation's central objectives is to improve the recyclability of packaging placed on the European market.
Under the PPWR, packaging will be assessed against harmonised design-for-recycling criteria, with performance grades ranging from A to C.
The regulation establishes a minimum Grade C threshold, corresponding to a recyclability performance of at least 70%, from 2030, subject to the timing of relevant secondary legislation. By 2038, the minimum permitted grade will increase to B.
Importantly, recyclability will be evaluated through defined technical criteria rather than relying solely on material descriptions or manufacturers' environmental claims.
Minimum Recycled Content
The PPWR also establishes minimum post-consumer recycled content requirements for certain plastic packaging categories.
The initial targets include:
A separate 30% requirement applies to single-use plastic beverage bottles.
These requirements are generally scheduled for 2030, or three years after the relevant implementing act enters into force, whichever is later. Exemptions and specific calculation rules also apply.
Restrictions on PFAS
Another important development concerns per- and polyfluoroalkyl substances (PFAS), chemicals historically used in certain packaging applications for their resistance to grease, moisture, and other substances.
Since 12 August 2026, food-contact packaging containing PFAS at or above the regulation's specified limits cannot be placed on the EU market.
This restriction places additional emphasis on chemical composition, material traceability, and testing throughout the packaging supply chain.
Flexible packaging occupies an important position in global food, beverage, coffee, and consumer goods markets.
Its relatively low material consumption, lightweight structure, and protective properties offer clear advantages in transportation efficiency and product preservation.
However, conventional flexible packaging frequently incorporates multiple material layers to achieve specific functional requirements.
A typical coffee pouch, for example, may combine polyester, aluminium, and polyethylene to provide oxygen and moisture barriers, mechanical strength, and heat-sealing performance.
These combinations can be difficult to separate and recycle through existing waste management infrastructure.
The PPWR therefore creates a significant technical challenge: manufacturers must improve packaging recyclability while maintaining the performance required to protect packaged products.
Mono-material structures, particularly polyethylene- or polypropylene-based alternatives, are attracting increasing attention.
Nevertheless, replacing a conventional laminate with a mono-material structure is rarely straightforward.
Changes in material composition can affect oxygen transmission, moisture resistance, printing performance, sealing temperatures, and shelf life.
For coffee packaging, where preservation of aroma and freshness is essential, these trade-offs require careful evaluation.
The industry must also distinguish between packaging designed to be recyclable and packaging that can be effectively collected, sorted, and recycled in practice.
This distinction is fundamental to the PPWR's longer-term approach, which introduces recycled-at-scale assessments from 2035, subject to the applicable implementation timetable.
The PPWR is likely to influence packaging procurement decisions across several dimensions.
First, material selection will increasingly involve regulatory considerations alongside price, appearance, and functional performance.
Second, packaging specifications may require more frequent review as technical standards and implementing legislation develop.
Third, documentation and supplier transparency will become more important. Brands will need reliable information concerning packaging composition, technical characteristics, and applicable compliance requirements.
These changes may also influence supplier relationships.
Manufacturers capable of supporting material evaluation, technical documentation, and product development could become more valuable partners as brands navigate the transition.
However, sustainable packaging alternatives do not automatically deliver lower environmental impacts in every application. Material efficiency, product protection, transportation, and end-of-life treatment must all be considered.
Effective packaging development will therefore require a more comprehensive approach to environmental performance.
As a manufacturer of custom flexible packaging serving international brands, Holden Pak recognises the importance of adapting packaging development to evolving European regulatory requirements.
Our preparation centres on strengthening the relationship between material selection, product performance, quality management, and sustainability.
Material Development and Evaluation
Holden Pak is placing greater emphasis on evaluating packaging structures with improved recyclability potential, including mono-material alternatives where appropriate.
For applications such as coffee and food packaging, particular attention is given to balancing barrier performance, durability, sealing reliability, and material compatibility.
Quality Management and Technical Documentation
Supported by established quality management practices and certifications including BRCGS and ISO 9001, Holden Pak continues to strengthen its approach to manufacturing consistency and quality control.
These systems provide an operational foundation for assessing materials, maintaining product specifications, and supporting customer documentation requirements.
However, management-system certification alone does not establish PPWR compliance for individual packaging products.
Regulatory Awareness and Customer Support
Holden Pak is incorporating developments in European packaging regulation into material evaluation and customer discussions.
This includes monitoring evolving requirements concerning recyclability, recycled content, and restricted substances, while working with customers to identify packaging solutions appropriate to their products and target markets.
Our objective is to help brands make informed packaging decisions as the regulatory framework develops.
The PPWR is unlikely to transform the packaging industry overnight.
Its implementation will unfold over several years, and important technical details will continue to be clarified through delegated and implementing legislation.
Nevertheless, its direction is clear.
Packaging development is moving towards greater material accountability, more rigorous recyclability assessment, and closer cooperation across the supply chain.
For manufacturers, this transition will require sustained investment in technical knowledge, material innovation, and quality management.
For brands, it presents an opportunity to reconsider packaging specifications and build more resilient relationships with suppliers.
At Holden Pak, we see this evolution as an important part of the industry's long-term development.
The future of packaging will depend on our ability to bring regulatory requirements, environmental responsibility, and product performance into closer alignment.
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