Today is Global Recycling Day. In less than five months, the EU’s Packaging and Packaging Waste Regulation (PPWR), the most ambitious packaging law ever enacted, begins application. It demands all packaging to be recyclable by 2030 and introduces “Recycled at Scale” targets requiring a minimum 55% recycling rate for all materials by 2035. Elopak supports these goals. On a day dedicated to recycling, however, it is worth being honest about a gap that no amount of packaging redesign can close: the gap between what the regulation demands and what Europe’s recycling infrastructure can deliver.
The European Court of Auditors found last November that only nine of 27 EU member states are meeting recycling targets. Since 2023, plastics recycling facilities with a combined capacity of more than 600,000 metric tons have closed across Europe, and more than 100 recycling stakeholders have warned the European Commission of outright industry collapse, despite €5 billion of private investment since 2020. The European Environment Agency estimates a €29 billion annual investment shortfall in the circular economy, with most spending still directed at basic waste management rather than the collection, sorting and reprocessing upgrades the PPWR demands.
The packaging industry has not stood still. At Elopak, our products already score above 95% recyclability. We co-own a recycling plant in Germany and 50% of liquid packaging cartons are now sent for recycling across Europe. The bottleneck is not product design. It is what happens after the consumer puts the packaging in the bin. Collection coverage is patchy and sorting accuracy varies wildly between jurisdictions. Germany recycles 70% of its municipal waste; Croatia achieved less than half that in 2022. The European Investment Bank has estimated a shortfall of €7-9 billion for plastics recycling infrastructure alone, concentrated in Central and Eastern Europe. The Recycled at Scale target of 55% by 2035 will not be met by design mandates. It will be met by collection trucks, sorting facilities and reprocessing plants that do not yet exist in enough of Europe.
But there is a second problem with the way the PPWR has been designed, and it is one of proportion. Not of intent, but of policy focus. Eurostat’s latest data shows that paper and cardboard account for 40.4% of all packaging waste generated in the EU, the largest single waste stream in 26 of 27 member states, while plastic accounts for 19.8%.
Yet the PPWR’s headline support measures — its recycled content mandates, deposit‑return triggers and single‑use restrictions — are overwhelmingly directed at plastic. While plastics clearly require further improvements in circularity, this concentration of regulatory support leaves little policy attention for the material that dominates Europe’s packaging waste stream and already achieves an 83% recycling rate, compared to 42% for plastic. This is particularly a problem when it comes to protecting, scaling and replicating that performance across member states.
This matters because of emissions. Europe has set legally binding targets to become climate neutral by 2050. In 2019, greenhouse gas emissions from plastics totalled 1.79 billion tonnes of CO2 equivalent, more than the entire annual emissions of Brazil. Around 36% of all plastics produced globally are used for packaging. Meanwhile, a meta-analysis of lifecycle assessments found that beverage cartons made mostly from paperboard have a carbon footprint of 83g of CO2 per litre, compared to 156g for PET bottles and 430g for single-use glass. Any packaging regulation that encourages investment and support for the highest-carbon material while overlooking the lowest-carbon alternative is not aligned with Europe’s broader climate goals.
The forthcoming Circular Economy Act is the opportunity to correct course. Europe needs a regulatory framework that sees packaging through a climate lens, not just a waste lens. That means ring-fenced EU funding for collection and sorting infrastructure, particularly in the member states furthest behind. It means material-neutral EPR fee modulation that rewards the lowest-carbon formats, not just the most recyclable. It means harmonised landfill and incineration taxes. It means accelerating the PPWR’s secondary legislation, because recycled content verification rules are not due until the end of this year and industry cannot invest responsibly without knowing the rules. And it means recognizing that the biggest packaging waste stream in Europe is also the one with the lowest carbon footprint and the highest recycling rate. Building policy around that fact would bring the PPWR into line with Europe’s own net zero commitments.
On Global Recycling Day, the message from our side is simple. The packaging industry has invested in recyclability, in fiber innovation, in infrastructure partnerships. Now we need governments to match that ambition: in the collection systems, the sorting plants, and the policy architecture that will determine whether Europe’s most ambitious packaging regulation delivers on its promise.