PPWR: Legal gray areas slow down implementation - need for action increases

The new EU packaging regulation (PPWR) is often associated primarily with the target year 2030. associated with this. However, the first requirements will actually come into effect much earlier: a declaration of conformity will be mandatory from 12.8.2026. This confirms that packaging complies with the currently valid directives. Without a declaration of conformity, companies risk having items withdrawn from the market and incurring high penalties. At the same time, many companies are confronted with legal gray areas.

Terms “manufacturer”, “producer” and “distributor” lead to legal gray areas in PPWR

“Above all, there is a lack of a clear definition of terms: Who is a manufacturer, who is a producer, who is a retailer? Each of these terms is associated with certain obligations under the PPWR. Due to the lack of clarity, many questions cannot be answered one hundred percent, especially in complex supply chains “, explains Thomas Glatz, Managing Director Interzero Austria.

In addition, it has not yet been fully clarified what will count as packaging in the future and what will not.
“For example, it is currently still unclear how coffee capsules will be classified and discharged. This makes planning difficult and may delay the necessary changes for companies, but also for providers of collection and recycling systems. Rapid clarification of these points would be helpful for the entire economy “, Glatz continues.

Act early: Stay PPWR compliant in 3 steps

Even if not all legal issues have been fully clarified yet, it is crucial for affected companies to act now in order to be prepared for the redesign of processes, the conversion of systems or the development of compliant Packaging.

Interzero recommends proceeding in three steps:

1. Create transparency and establish a clear database on the Packaging used.
2. Analyze the packaging portfolio for recyclability and identify problematic material combinations.
3. Test new packaging solutions at an early stage in order to combine innovation with brand strategy and cost optimization.

Strategic PPWR consulting for your company by Interzero

As Europe’s leading provider of circular economy solutions, we support companies with a wide range of services to meet the requirements of the PPWR.

These include strategic PPWR consulting as well as specific, customized solutions. “Check for Recycling” is a digital tool that can be used to check the recyclability of existing packaging and create automated declarations of conformity.

With “Made4Circle” we accompany companies through the entire process: from the recyclability of the packaging analyzed in the laboratory to direct recommendations for action regarding design and material selection to the use of the recyclate developed in our in-house competence center for recycled plastics.