From functional paper-based packaging and new producer responsibilities to the Declaration of Conformity – three developments that manufacturers of flexible packaging need to understand now.
For years, the packaging industry has been discussing the same questions.
How ambitious will recycled content targets become? Which mono-material structures will prevail? Which barrier properties will remain essential? And how can Design for Recycling be successfully implemented?
At Future Resources 2026 in Cologne, however, I increasingly had the impression that this discussion has already moved one step further.
Not because recycling is becoming less important.
But because the real challenge is shifting.
While many companies are still working to make their packaging PPWR-compliant, policymakers, authorities and international organisations are already focusing on the next question:
How should the entire packaging system function in the future?
Three presentations illustrated this shift particularly well.
The Ellen MacArthur Foundation Is Already Thinking in Systems
Anyone who wants to understand where packaging markets are heading can hardly ignore the Ellen MacArthur Foundation.
More than 1,200 organisations—representing around 20% of the global packaging market—are now working within the Foundation’s network to accelerate the transition towards a circular economy.
What impressed me most was not the size of the network, but its strategic direction.
The Foundation has identified three key priorities for the coming years:
- Reuse
- Flexible packaging
- Recycling infrastructure
These are described as systemic barriers—challenges that no single company can solve on its own.
For manufacturers of flexible packaging in particular, this roadmap deserves close attention.
Its strategic focus is surprising.
Rather than placing new plastic solutions at the centre of innovation, the Foundation’s stated objective is:
“Accelerate innovation in alternative materials for flexible packaging.”
The current emphasis is clearly on functional fibre-based alternatives.
This is far more than a collection of pilot projects.
The Foundation announced a multi-year programme designed to accelerate the development and scaling of fibre-based packaging solutions through collaborative research, policy engagement, economic assessments and international partnerships.
One statement at the end of the presentation stood out to me in particular:
“Now is the time to join the many dozens of organisations already involved.”
To me, this does not mean plastics are disappearing.
But it clearly indicates where international innovation budgets, political attention and major consumer brands are currently directing their efforts.
Anyone developing flexible packaging should be watching this trend closely.
Perhaps the Most Important PPWR Question Is: Who Is the Producer?
While the Ellen MacArthur Foundation looked towards the future, the law firm Cattwyk brought the discussion back to everyday business reality.
With the PPWR, Europe will, for the first time, introduce a harmonised definition of the “producer.”
What may initially sound like a legal detail is likely to have significant implications across the packaging industry.
The producer will no longer be just another participant in the supply chain.
The producer carries responsibility.
The producer signs the Declaration of Conformity.
The producer provides the technical documentation.
And the producer becomes the primary point of contact for market surveillance authorities.
Especially in private-label business, contract packing operations and complex packaging development projects, one question suddenly becomes business-critical:
Who actually assumes this role?
The answer is not automatically:
The packaging manufacturer.
Depending on the supply chain, brand owners or companies defining essential packaging specifications may also become legally responsible.
This is precisely why the presentation resonated with so many participants.
The PPWR is not only changing technical requirements.
It is fundamentally changing responsibilities.
Packaging Alone Will No Longer Be Enough
Most discussions surrounding the PPWR focus on materials.
The German Central Agency Packaging Register (ZSVR), however, placed its emphasis elsewhere.
Its focus was on data.
On evidence.
And on documentation.
This brought a topic to the forefront that still receives surprisingly little attention in many companies: the Declaration of Conformity.
In the future, it will be much more than a formal document.
It will serve as the key proof that packaging complies with all applicable PPWR requirements.
This declaration is based on the technical documentation required under Annex VII of the Regulation, covering aspects such as material composition, recyclability, recycled content and other regulatory requirements.
The implications are substantial.
Not only must the packaging itself comply with the Regulation.
Every piece of information supporting that compliance must also be complete, traceable and readily available.
For many companies, this represents a genuine paradigm shift.
Until now, packaging development has largely focused on materials and product performance.
Going forward, data management, documentation and compliance will become equally important parts of the packaging development process.
The Real Transformation Happens Behind the Packaging
After a full day at Future Resources 2026, one thought stayed with me.
Our industry still spends much of its time discussing materials.
PE.
Paper.
Mono-material structures.
Barrier properties.
All of these topics remain important.
But the real transformation is now happening somewhere else.
It is happening in responsibilities.
In regulatory requirements.
In data structures.
In international innovation programmes.
And in the ability to demonstrate compliance with increasingly complex legislation.
For me, that was the single most important takeaway from this event.
The PPWR is no longer simply a regulation about packaging materials.
It is evolving into a regulatory framework that is reshaping the entire packaging value chain—from the development of new packaging concepts and the allocation of responsibilities across the supply chain to technical documentation and regulatory compliance.
For manufacturers of flexible packaging, this ultimately means one thing:
The packaging of the future must do more than perform.
It must also withstand regulatory scrutiny.
And that may well become the industry’s greatest challenge over the coming years.
