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Key talking points from the proposed EU Packaging and Packaging Waste Regulation
by Aaron Sarah at 16:23 in Circular Economy, Emerging, Packaging

​After much speculation and anticipation, the EU has released its proposed Packaging and Packaging Waste Regulation, a revision to the Packaging and Packaging Waste Directive (PPWD). One of the key changes within the proposal is a change in legal standing, turning it into a 'Regulation' and not a 'Directive'. This means that if implemented, the new regulation will be binding and will be applied across the entirety of the EU. A directive, on the other hand, sets goals that EU member states must achieve through producing their own legislative framework.


The proposal sets out three main objectives, covering the entire life cycle of packaging;

  1. Reduce the generation of packaging waste

  2. Promote a circular economy for packaging in a cost-efficient way

  3. Promote the uptake of recycled content in packaging

To achieve these objectives, the proposal introduces new legislative measures, building upon and improving upon the current PPWD.

Recycled content targets:

Perhaps one of the most talked about elements of the proposal is the introduction of recycled content targets for all packaging. The EU has already introduced recycled content targets for PET bottles in the Single-Use Plastics directive. However, this proposal will now seek to introduce recycled content targets for all types of plastic packaging. From 2030, all plastic packaging must contain a minimum percentage of recycled content. Including:

  • 30% for contact sensitive packaging made from polyethylene terephthalate (PET) as the major component

  • 10% for contact sensitive packaging made from plastic materials other than PET, except single use plastic beverage bottles

  • 30% for single use plastic beverage bottles

  • 35% for all other packaging

These targets will then be increased again in 2040 to:

  • 50% for contact sensitive plastic packaging, except single use plastic beverage bottles

  • 65% for single use plastic beverage bottles

  • 65% for all other packaging

Reuse and Refill:

The proposal also introduces minimum targets for packaging reuse or refill. Minimum targets are set for 2030 and 2040, for the refill and reuse of packaging used for beverages, non-food e-commerce, transport protection and large household appliances. The proposal specifies that producers will need to ensure that any refillable packaging meets relevant hygiene and safety standards. The introduction of these targets feeds into the objective of promoting a circular economy for packaging and reducing the levels of packaging waste seen across the European Union.

Chemical Recycling:

Another key talking point of the proposal is mention of chemical recycling (please see our previous blog to learn what chemical recycling is). This is important as it shows how the EU believes that despite its challenges, chemical recycling could potentially be a key instrument in being able to achieve recycled content targets across all packaging. However, the proposal is stringent in suggesting that chemical recycling should only be used to reprocess waste materials into products, materials or substances for the original or a similar purpose and not to be used as fuel, generate energy or be incinerated, backfilled or landfilled.


Across the EU there are a variety of different ways in which member states require packaging to be labelled to inform consumers on the correct way to dispose of the packaging. However, another key talking point of the proposal is the EU's desire to harmonise packaging labelling. The nature of this proposed labelling system will be decided within 18 months of the entry into force of the regulation.

The proposal does also include other labelling requirements, such as labelling and a QR code on reusability and labelling on material composition of the packaging.

If you would like to keep track of the new EU Packaging and Packaging Waste Regulation, or how it may affect your business, contact us at Lorax EPI today, and speak with one of our experienced consultants.

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