PPWR and FlexPack: What Manufacturers and Converters Need to Do Now

The European Packaging and Packaging Waste Regulation (PPWR) has been in force since August 2026 and presents companies in the packaging industry with far-reaching new requirements. In our web seminar PPWR and FlexPack B: Obligations, bans & design scope – What lies ahead for manufacturers and converters, Dr. Daniel Wachtendorf (Innoform Testservice GmbH) provided a practical overview of the new producer obligations, material bans, and design requirements for flexible packaging.

From packaging manufacturer to overall responsibility

A key element of the PPWR is Extended Producer Responsibility (EPR). Companies that manufacture, import, or place packaging on the market will in future have to assume significantly more responsibility for the entire life cycle of their packaging. This includes registration, data reporting, labeling, documentation, and the financing of collection, sorting, and recycling structures.

A particularly important question in this context is: Who is actually considered a producer? The answer is not always clear-cut and depends on the respective role within the supply chain. Converters, distributors, and importers in particular will therefore benefit from a detailed review of their own responsibilities.

Flexpack faces particular challenges

Flexible packaging faces special challenges when implementing many PPWR targets. While other packaging types often still have significant potential for material savings, flexible packaging has already been heavily optimized in recent years. At the same time, it must meet high requirements for product protection, barrier properties, and food contact.

In addition, there are further challenges:

• increasing recyclate contents
• requirements for mono-material solutions
• restrictions on PFAS
• higher requirements for recyclability
• reduction of packaging weight and empty space

This creates significant development tasks, particularly for manufacturers of laminated films.

Registration, labeling, and documentation

Companies are already required today to register their packaging in the respective national registers and report the required data. Further labeling obligations will follow step by step. From 2028, for example, harmonized labeling regarding material composition, recycling routes, or compostability is to be introduced. Looking ahead, digital solutions such as QR codes and digital product passports will also play a larger role.

At the same time, the importance of technical documentation is growing. In the future, companies must be able to verify how their packaging is constructed and how requirements regarding recyclability, recyclate content, or material restrictions are met. A transparent supply chain and close cooperation with raw material and packaging suppliers are therefore becoming increasingly important.

Recyclates become mandatory

Another key focus of the PPWR concerns the mandatory use of recyclates. From 2030, different minimum quotas will apply depending on the packaging type. For contact-sensitive plastic packaging outside the PET sector, for instance, a 10 percent recyclate content is mandatory. For other plastic packaging, significantly higher shares are required. By 2040, these quotas will rise even further.

Whether the required quantities and qualities of recyclates will be available in time remains one of the major challenges for the industry. Accordingly, many companies are closely following the announced implementing acts and further details from the EU Commission.

PFAS and further material restrictions

The web seminar paid special attention to the new specifications for PFAS in food packaging. Since the PPWR came into force, specific limit values apply to these. Companies must be able to document and verify compliance with these requirements. In the subsequent discussion, it became clear that many companies currently still face practical questions regarding analysis and assessment of such materials.

Design for Recycling becomes the standard

The PPWR aims to systematically design packaging for recyclability. In future, packaging will be evaluated based on how well it can be collected, sorted, and recycled. Mono-material solutions, easily separable components, and designs with minimal non-recyclable fractions gain significant importance as a result.

Laminated materials, metallization, heavy coloration, or hard-to-separate components may negatively impact recyclability assessments in the future. Companies should therefore already assess today whether existing packaging concepts will meet future requirements in the long term.

Setting the course now

Even though many detailed regulations are currently still being finalized, the web seminar made one thing clear: now is the time to prepare. Compiling technical documentation, coordinating within the supply chain, and reviewing existing packaging systems often require significantly more time than expected.

Daniel Wachtendorf’s conclusion: Companies should not wait for the final implementing acts, but start collecting data, testing their packaging, and establishing the necessary verification documentation today. Taking action early creates the foundation for a successful and legally compliant implementation of the PPWR.

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Do you have questions about the PPWR or would you like to have your packaging evaluated regarding recyclability, recyclate use, or compliance? The experts at Innoform will be pleased to support you in classifying the new requirements and implementing them in practice.