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Artwork Management

Beyond Basic Compliance: Navigating the New Era of Packaging Sustainability

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Imagine if you will, the current landscape of packaging regulations across the European Union as a network of roads. Each country’s roads have their own rules, speed limits, and signage, resulting in confusion and potentially leading to multiple fender benders. Or in this case, regulations and, especially changes in regulations, create traffic jams and impede the efficient flow of goods and materials.

For example, the Packaging and Packaging Waste Regulation (PPWR) is akin to the opening of a new, comprehensive European highway system for packaging.

It isn’t about patching up a few potholes; it’s a fundamental redesign that will lay down rules for everyone involved, from the raw material suppliers to the final distributors.

The PPWR represents a significant shift towards a harmonized and more sustainable approach to packaging across the EU.

This article is based on the recent Esko webinar, “Redefining Packaging: Sustainability Beyond Compliance,” which featured expert insights from Esko’s Geert De Proost, Jenny Walther-Thoss of BP Consultancy GmbH, and Dominic Harris of CarbonQuota. The experts provided an in-depth overview of the upcoming EU Packaging and Packaging Waste Regulation (PPWR), its implications across the value chain, and the urgent need for data-driven compliance.

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In this blog, we highlight key takeaways from the webinar and expand on how packaging professionals can respond proactively to these evolving requirements.

Understanding the Shifting Global Regulatory Landscape

The surge in sustainability regulations reflects a global push to tackle the growing problem of waste as well as to foster a more circular economy.

In fact, global municipal solid waste volumes are projected to double by 2050.

This has resulted in a significant increase in packaging-related legislation globally, including the rise of Extended Producer Responsibility (EPR) systems and plastic taxes.

Health and safety are also paramount, with bans and limitations on single-use plastics and substances of concern (SoC) like PFAS becoming increasingly common.

The focus of these laws is clear: reduce waste and over-packaging and foster a circular economy by emphasizing recyclability and the use of recycled content, especially in plastic packaging.

While compliance is necessary, aligning with these regulations also presents a strategic business opportunity—meeting growing consumer demand for eco-friendly products, improving brand reputation, and achieving cost efficiencies through material and energy savings.

Regulatory Landscape by Region

It would be an understatement to say the regulatory landscape varies across different regions. For instance:

North America (US & Canada)

While there isn’t mandatory federal packaging legislation in the U.S., states like California, Oregon, and Maine have implemented their own Extended Producer Responsibility (EPR) laws.

Canada has a national action plan to reduce plastic waste, with provinces like Ontario and British Columbia implementing their own EPR programs.

This fragmentation presents a challenge for companies operating across different jurisdictions.

Asia/Pacific

Regulatory momentum is growing, with a focus on health and safety. China has introduced recycling targets and banned non-degradable packaging. Japan maintains a sophisticated system, while South Korea, Australia, and India are advancing laws around waste management, recycling targets, and mandatory recycled content.

Europe

The PPWR regulation will be effective on August 12, 2026. It aims to reduce overpackaging and empty space, promote recyclability through design for recycling and restrictions on SoCs, and harmonize labeling and EPR systems.

This will impact the entire supply chain from raw material producers to brands and retailers. The first major impact will be the technical conformity assessment required for all packaging by August 2026.

Key targets include recycled content quotas for plastic packaging and reuse targets for various applications starting in 2030 and 2040. It also introduces sustainability reporting obligations.

These packaging regulations also impose sustainability reporting obligations. However, collecting and organizing accurate sustainability data remains one of the biggest challenges for companies. As a result, many are turning to digital tools to streamline data collection, aggregation, and management.

Sources: BP Consultants auf Basis von Roland Berger & Yash Research

The EU PPWR: A Game Changer for Packaging in Europe

As the PPWR implementation date is rapidly approaching, let’s look at the upcoming changes and their timelines.

August 12, 2026, marks the end of an 18-month transition period. Key aspects include:

Technical Conformity Assessment

  • By August 2026, all packaging in the EU market must comply with Article 5 (health and safety) through a formal technical conformity assessment.
  • EU certificate of conformity required.

Recyclability Requirements

  • From January 1, 2030, all packaging must be recyclable based on Design for Recycling (D4R) criteria.
  • Criteria to be set by the European Commission starting January 1, 2028.

Harmonized Labeling and Marking

  • Expected mid-2028, most packaging will require standardized material composition labels to aid consumer sorting.
  • Packaging with substances of concern (SoCs) must have digital markings by Q1 2027.
  • Reusability labels will be required on reusable packaging.

Reuse Targets

  • Reuse targets begin in 2030 and 2040 for transport, grouped, and beverage packaging.
  • Take-away sector will face reuse and refill obligations.

Restrictions on Certain Packaging Formats

  • From January 1, 2030, certain formats — like single-use plastic grouped packaging (Annex V) — will be restricted.

Extended Producer Responsibility (EPR)

  • Producers must register in national registers (to be established by mid-2027) before placing packaging on the market.
  • EPR fees will be adjusted based on packaging recyclability (grades A, B, C).

Amendments to the SUPD

  • PPWR will amend the Single-Use Plastics Directive (SUPD), repealing some recycled content targets by January 1, 2030.

Compliance and Enforcement

  • Economic operators must provide technical documentation to demonstrate compliance.
  • Penalties to be defined by Member States by Q1 2027.
  • Early adoption offers brand and market leadership advantages.

Secondary Legislation and Reviews

  • Further requirements will be defined through delegated and implementing acts by the EC.
  • PPWR will fully repeal the Packaging and Packaging Waste Directive (PPWD) from mid-2026, with transitional measures lasting to 2029.

Preparing for Initial Compliance: The Technical Conformity Assessment

The technical conformity assessment is a critical first step for all packaging placed on the EU market, with the requirement for an EU Declaration of Conformity beginning on August 12, 2026.

This initial assessment will prioritize health and safety. Specifically, the sum of concentrations of lead, cadmium, mercury, and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg.

Furthermore, food-contact packaging will face strict limits on per- and polyfluorinated alkyl substances (PFAS).

These limits include 25 ppb for any single PFAS, 250 ppb for the sum of targeted PFAS (where applicable with precursor degradation), and 50 ppm for PFASs (including polymeric PFAS).

The Growing Importance of Sustainability Reporting and Data

Beyond the specific requirements of the PPWR, there is a clear global trend towards mandating sustainability reporting.

This reflects a broader focus on environmental, social, and governance (ESG) factors.

Companies are facing growing pressure to disclose their environmental impacts, which extends beyond packaging to encompass their overall operations.

This includes reporting on the following:

  • Greenhouse gas (GHG) emissions, covering scope 1 (direct emissions), scope 2 (indirect emissions from purchased energy), and increasingly scope 3 (all other indirect emissions in the value chain)
  • Climate-related risks and opportunities, governance related to climate issues, and targets and transition plans

The data required to demonstrate compliance with PPWR, and broader sustainability reporting obligations, often overlaps significantly.

For instance, data on material composition, recyclability, recycled content, and substances of concern are relevant to both.

This interconnectedness highlights the necessity for companies to adopt an integrated data management strategy.

In fact, during the “Sustainability Beyond Compliance” webinar, the results of the first poll showed that 54% of over 200 packaging professionals indicated that collecting and organizing accurate sustainability data is currently the biggest challenge in meeting sustainability regulations, followed closely by keeping up with evolving global regulations.

Furthermore, one third of those respondents indicated they use manual processes such as spreadsheets and ad hoc reports to manage current sustainability data.

This underscores the importance of establishing effective data management systems now to prepare for both current and future regulatory demands.

Extended Producer Responsibility (EPR)

Extended Producer Responsibility (EPR) is a cornerstone of the PPWR and a central mechanism for driving packaging sustainability.

EPR operates on the principle that producers (manufacturers, suppliers, importers, etc.) bear the responsibility for the end-of-life management of the packaging they place on the market. This includes the costs associated with the collection, sorting, and recycling or other recovery of used packaging.

Packaging industry professionals must thoroughly understand the specific requirements and operational designs of EPR schemes in each EU Member State where they operate or export to.

While the PPWR aims to harmonize rules, the implementation and specific details of EPR schemes have historically differed across Member States. Almost all Member States have assigned responsibility for meeting recycling targets to producers through EPR schemes.

Under the PPWR, EPR fees are expected to be modulated based on the recyclability performance grades of packaging (grades A, B, and C). This incentivizes producers to design packaging that is easier to recycle.

The European Commission will establish the framework for this EPR fee modulation through delegated acts by January 1, 2028.

The EPR fees paid by producers will also cover additional costs beyond waste treatment, such as the costs of waste receptacles’ labeling and the costs of compositional surveys of collected mixed municipal waste.

The EU aims for harmonized minimum requirements for packaging EPR schemes to help raise recycling rates across the EU.

Moving Beyond Basic Compliance Through Design for Sustainability

The packaging industry’s role extends beyond mere regulatory compliance by actively integrating design for sustainability (D4R) principles.

This proactive approach involves a fundamental shift in how packaging is conceived and developed.

A key aspect is reducing packaging weight and volume to a minimum while ensuring functionality. This directly impacts palletization efficiency and reduces emissions associated with transportation (lightweighting).

By designing packaging with logistics in mind from the outset, packaging professionals can ship less air and maximize the number of products per pallet and truck. This leads to substantial reductions in CO2 emissions.

Just as importantly, these efficiencies can reduce costs and increase profitability, offering a competitive edge in a marketplace where customers and investors are increasingly prioritizing ESG performance.

Leveraging Efficient Production Processes

Adopting resource-efficient production processes helps achieve meaningful sustainability goals beyond basic compliance. A prime example is expanded gamut printing.

This technology allows for the use of the same set of inks for various print jobs, which dramatically reduces ink consumption, minimizes press changeover times, and therefore decreases material waste associated with these changeovers.

The reduced material and energy usage directly translates to lower greenhouse gas emissions across all scopes.

Moreover, minimizing waste and optimizing production flow leads to significant cost savings for packaging producers. The packaging industry must actively explore and implement technologies to simultaneously enhance operational efficiency and improve overall sustainability performance.

In a landscape where Margins are tight and scrutiny is high, sustainability-driven efficiencies can deliver meaningful ROI while helping companies meet their environmental commitments.

Adapting to Harmonized Labeling for Improved Recycling

The PPWR necessitates changes in packaging artwork and printing processes to clearly communicate material composition and proper disposal instructions. The EC will establish the specific label specifications, including when provided through digital methods, in secondary legislation.

The PPWR also includes a prohibition to provide or display labels, marks, symbols, or inscriptions that are likely to mislead or confuse consumers regarding sustainability requirements for packaging. The packaging industry must stay informed of specific label designs and specifications to ensure compliance by the relevant deadlines. As noted during the webinar, consumers will need clear labeling informing them of how to put the right packaging in the right recycling stream.

The Importance of Collaboration and Data Sharing

Achieving true sustainability in packaging necessitates strong collaboration and transparent data sharing across the entire value chain, including material suppliers, designers, converters, brands, retailers, waste management operators, and recyclers.

Leveraging platforms and partnerships to streamline data exchange and guarantee accuracy will be non-negotiable. As highlighted during the webinar, the entire packaging supply chain is affected by these regulations and will need to provide the right data.

The move towards a digital product passport (DPP), part of the upcoming regulations, will further emphasize the need for data collection and aggregation across the supply chain. This will require retailers to obtain information from brands, and brands to gather data from packaging converters, substrate manufacturers, and ink manufacturers.

Wrapping it Up

The packaging industry is at a pivotal moment in its sustainability journey. The PPWR and increasing global pressures demand a move beyond basic compliance.

Proactive engagement with regulations, a focus on data collection and digitalization, embracing design for sustainability, and fostering collaboration across the value chain are critical for success.

By viewing sustainability as an integral part of their operations, not just a compliance requirement, packaging industry professionals can meet regulations, drive innovation, enhance efficiency, and contribute to a more circular and sustainable future.

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