PPWR Recyclability and Recycled Content Requirements
PPWR Recyclability and Recycled Content
Recyclability and the use of recycled material are central elements of the EU’s Packaging and Packaging Waste Regulation (PPWR).
The Regulation establishes a progressively developing framework intended to increase the recyclability of packaging and the use of recycled content, particularly in plastic packaging.
For organisations placing packaging on the EU market, these requirements can have implications for packaging specifications, material selection, supplier information, product development and compliance evidence.
The challenge is that the framework develops over time. Businesses therefore need to distinguish between the general requirements that apply now and the more detailed criteria that will apply in future.
PPWR recyclability requirements
PPWR requires packaging placed on the market to be recyclable.
The more detailed design-for-recycling requirements apply from 2030, or later where provided for by the Regulation depending on the timing of the relevant delegated acts.
Under the developing framework, packaging recyclability will be assessed against performance grades based on the proportion of packaging that is recyclable by weight.
The Regulation establishes grades A, B and C.
From 2035, or later depending on the timing provisions in PPWR, the assessment will also take account of whether packaging is recycled at scale.
These requirements mean that recyclability increasingly becomes a regulatory consideration rather than solely a packaging-design or sustainability objective.
Design for recycling
Detailed design-for-recycling criteria are being developed for different packaging categories.
These criteria are expected to influence how packaging characteristics affect recyclability and the recyclability performance grade achieved by particular packaging.
For organisations developing or procuring packaging, this creates an important forward-looking question.
Packaging decisions made before all of the detailed criteria apply may affect the organisation’s ability to meet future requirements.
Businesses may therefore need to consider how emerging criteria could influence:
- packaging materials;
- components and combinations of materials;
- coatings, inks, adhesives and labels;
- closures and other packaging elements;
- packaging formats;
- recyclability evidence; and
- supplier specifications.
The implications will vary between packaging categories and materials.
Recyclability performance grades
The PPWR framework introduces recyclability performance grades.
Packaging will be assessed according to the proportion of the packaging that is recyclable by weight, with grades ranging from A to C.
The detailed methodology and design-for-recycling criteria are being developed through secondary legislation.
This means organisations should be cautious about assuming that existing recyclability claims or assessments will automatically demonstrate compliance with the future PPWR criteria.
Understanding the regulatory methodology and the evidence needed to support an assessment will become increasingly important as implementation progresses.
Recycled content in plastic packaging
PPWR also establishes minimum recycled-content requirements for relevant plastic packaging.
The first targets apply from 2030, or later depending on the timing provisions associated with the relevant implementing act.
Different targets apply to different categories of plastic packaging, with further increases provided for from 2040.
There are also exemptions and specific provisions that may affect whether particular packaging is subject to the targets.
For businesses, determining the applicable requirement may therefore involve understanding the packaging category, material, intended use and any relevant exemptions.
Evidence and supply-chain information
Both recyclability and recycled-content requirements create potential evidence requirements.
Organisations may depend on packaging manufacturers, converters, recyclers, material suppliers and other organisations for information needed to support compliance.
Businesses may therefore need to consider:
- what packaging data they currently hold;
- how materials and components are specified;
- what evidence suppliers can provide;
- how recycled content is demonstrated;
- how recyclability assessments will be documented; and
- how packaging information is maintained when suppliers or specifications change.
These are not solely technical packaging questions. They can also affect procurement, regulatory compliance and supply-chain management.
How RPA can support organisations
RPA can help organisations understand the developing recyclability and recycled-content framework and its implications for their packaging.
Our support can include:
Regulatory interpretation
Assessing which recyclability and recycled-content requirements are relevant to particular packaging.
Packaging portfolio assessment
Reviewing packaging portfolios to identify where future PPWR requirements may create compliance considerations.
Evidence requirements
Identifying the information and documentation that may be needed to demonstrate compliance.
Supply-chain engagement
Helping organisations identify the information that may need to be obtained from packaging and material suppliers.
Regulatory monitoring
Monitoring the delegated and implementing acts that will establish further technical detail and assessing their implications as they are adopted.
Preparing for developing requirements
Not all of the detailed recyclability and recycled-content rules are yet finalised.
However, this does not necessarily mean organisations need to wait before considering their implications.
Understanding packaging portfolios, improving packaging data and identifying dependencies on suppliers can help organisations prepare while avoiding premature assumptions about requirements that are still being developed.
Speak to RPA
If you need to understand how PPWR recyclability or recycled-content requirements could affect your packaging, RPA can help you assess the regulatory requirements, identify evidence needs and consider the practical implications for your organisation.