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Understand how the EU Packaging and Packaging Waste Directive (PPWD) impacts UK producers

This is a combined article written by Root’s sustainable packaging experts and Ecosurety. The EU PPWD is set to impact all producers placing goods on the market in the EU. Together we explain what it is and how UK producers could be impacted.

The proposal for a Packaging and Packaging Waste Regulation is an update to the Packaging and Packaging Waste Directive (1997) and was published on 30th Nov 2022. By changing the Directive to a Regulation, the Commission is aiming to homogenise the roll out of the legislation across member states and prevent some nations from interpreting the regulations in a way that hinders the free movement of goods across the EU. The regulation is likely to be enacted by the end of 2024.

EU regulation will go beyond the current UK packaging EPR requirements, and producers placing packaging on the market in the EU need to be aware of this.

Key goals of the revisions include:

– Boosting the secondary material market through mandatory recycled content requirements
– A ban on non-recyclable packaging through recyclability assessments
– Reducing the amount of packaging on the market through minimisation and excessive packaging guidelines
– Mandating reuse, deposit return schemes, and further EPR
– Mandating the use of compostable materials for specific applications, including coffee capsules

The EU regulation will go beyond the current UK packaging EPR requirements, and UK producers placing packaging on the market in the EU need to be aware of this.

Impact of the PPWD on producers

The soon-to-be reformed PPWD was originally transposed into pre-Brexit UK law in the late 1990s. Being a Directive meant a certain amount of discretion in its implementation – for instance, the UK introduced market-based recycling evidence notes (PRN/PeRNs), which was at odds with most of its European counterparts.

Once the new PPWD regulation is passed in the EU, however, the differences in EU packaging policy compared to the UK will become even more pronounced, especially considering the UK’s current transition to a unique Extended Producer Responsibility (EPR) framework.

Until the PPWR has been ratified, it is hard to pinpoint the impacts on producers trading in the EU and the UK. That said, we can assume that businesses will need to prepare for aspects of the regulation, such as:

  • Waste reduction targets for EU member states and measures to tackle ‘over-packaging’. This may include rules surrounding the amount and material use of packaging around certain products.
  • Further bans on single-use plastic packaging products in the EU, in addition to the Single-Use Plastics Directive. These may include single-use plastic, composite and other packaging for fruit and vegetables, such as trays and single-use hotel miniature packaging, such as shampoo bottles.
  • All packaging to be fully recyclable, ‘designed for recycling’ by 2030, and ‘recycled at scale’ by 2035. Although there is limited information on this currently, this might include limits on multi-material formats or use of recycling disruptors such as carbon-black plastics.
  • Harmonised eco-modulation EPR fees in all EU member states based on recyclability and recycled content.
  • Introduction of minimum recycled content targets for 2030 and 2040 and specific targets for reusable and refillable packaging. The exact targets will be written in a separate delegated act.
  • Harmonised labelling schemes and mandatory deposit return schemes for all single-use plastic and metal beverage containers up to 3L by January 2029.

All packaging to be fully recyclable, ‘designed for recycling’ by 2030, and ‘recycled at scale’ by 2035

Impact of the PPWD on the UK

Because the existing directive was transposed into UK law before exiting the EU, under the Northern Ireland Protocol the changes resultant of the PPWD being enacted into a regulation will likely need to be implemented there. The European Scrutiny Committee asked the environment minister to explain the impact of the PPWR on Northern Ireland and the rest of the UK in more detail later this year.

This is because government believes that UK manufacturers and producers of packaging will almost certainly ensure all of their packaging products conform with the new EU legislation, regardless of where it is sold, to ease financial and administrative burdens.

Although some of the proposed reforms may align with developing UK regulations, many will not, meaning government and the devolved administrations should consider how the two sets of legislation interact.

What should you do now?

The impact of the PPWD will depend on the final details in the enacted regulation and the activities of any given organisation. It is likely to have varying degrees of impact within a supply chain.

As a minimum, producers should take steps now to fully understand their packaging portfolio via robust data collection to provide the insights necessary to drive their packaging strategy. This will put them in the best position to analyse the impacts of UK packaging EPR legislation and the upcoming EU PPWR on their business.

You can find a range of resources about the PPWD on the official website of the EU.

How can Root help?

Root Packaging Audit is a great first step to help identify the risks across your packaging portfolio. The audit will give you the tools to build a policy-proof and commercially viable packaging strategy that will ensure you remain compliant across every territory your business operates within.

If you would like to discuss the challenges facing your business, schedule a call with a Root sustainability experts who can advise you on the steps you need to take.