In 2025, brand owners and packaging manufacturers face a whole alphabet of regulations and legislation – from SUPD to PPWR, and understanding the why, how and what next is becoming increasingly complex to manage around the globe.
For European Union Member States, the Packaging and Packaging Waste Regulation (PPWR) entering into force in February 2025 is a significant step in the direction of harmonising eco-modulation of extended producer responsibility (EPR) fees across markets according to recyclability grades. But many of the stipulations from the legislation won’t take effect until 2030 or later.
Until then, companies operating in the European packaging industry face a varied landscape when it comes to a range of rules surrounding collection, sorting, recycling along with EPR fees and other levies. So how can businesses and brand owners not only grapple with this behemoth of divergent legislation but also thrive amidst the changing tides?
A patchwork of rules
For packaging producers, ensuring recyclability goes far beyond the materials themselves. National governments and local waste management systems determine how packaging is collected and sent for reprocessing, meaning that compliance is not a one-size-fits-all approach. The PPWR aims to create a more consistent structure by harmonised recyclability requirements and consistent eco-modulation rules across EU member states. Until then, companies will continue to grapple with fragmented EPR fee structures and recyclability requirements across different countries.
Italy offers a particularly stark example of this challenge. Unlike other countries which have standardised national guidelines for waste disposal, Italy’s system provides operational flexibility at the municipal level, with individual regions setting collection rules. This means that the same packaging may be collected for recycling differently in different parts of the country. In Milan, for instance, what could be disposed of in the paper stream, could in Florence be considered part of the multi-material waste stream, which includes plastics and metals.
One package, many realities
One company that has encountered these challenges firsthand is Hörauf, a German packaging machinery & packaging system specialist introducing its CartoCan® beverage packaging into Italy. While the product had already been validated as recyclable at the European level, the reality of how it would be classified, collected, and processed in Italy was more complex. The company’s experience provides a case study in how packaging producers can assess local waste infrastructure, navigate regional regulatory differences, and optimise their approach for both sustainability and cost management.
To support Hörauf’s expansion, Stora Enso conducted a circularity assessment focused on Italy’s collection, sorting, and recycling infrastructure.
Beyond the difficulties in waste stream classification, the assessment also identified Italy’s PolyAl (polyethylene and aluminium) recycling capacity, which plays a growing role in improving circularity of food and beverage cartons. This insight was crucial in understanding circularity of CartoCan® and in ensuring that it was positioned for compatibility with local systems. Besides, having insights of the EPR fees in Italy supplemented value proposition of CartoCan®.
For businesses like Hörauf, circularity assessments are more than just insights. They offer strategic advantages. By understanding the regional waste landscape, businesses can optimise their market entry strategy, ensure clear disposal guidance for consumers, and manage EPR costs effectively. As Europe moves toward greater packaging standardisation, the ability to anticipate and navigate local complexities remains a key competitive advantage.
Designing for circularity
For companies looking to expand their packaging solutions across multiple European markets, the experience of CartoCan in Italy underscores the need for a proactive and strategic approach. Circularity assessments should not only verify that a package meets technical recyclability standards but also ensure that it aligns with local collection systems and regulatory frameworks.
Material selection is now, more than ever, a sustainability decision as well as a financial one. In many cases, the difference in recyclability can translate into a difference between lower and higher EPR fees. These fees are also to projected increase in the coming years to support reaching ambitious targets set out by the regulations. Businesses that do not factor these evolving costs into their packaging decisions may find themselves facing unexpected financial burdens.
Regulatory requirements are also tightening. By 2030, all packaging placed on the EU market must be at least 70% recyclable, increasing to 80% by 2038. This is not just a guideline but a legal requirement, and packaging that fails to meet these requirements could be subject to market restrictions. Companies that anticipate these changes and adapt their packaging now will be best positioned to remain compliant and competitive.
Packaged for success
Even with regulatory harmonisation efforts, packaging producers will face national and regional differences in waste management for the foreseeable future.
By investing in circularity assessments, optimising materials for local waste systems, and staying ahead of EPR fee structures, businesses can turn regulatory challenges into competitive advantages. A thoughtful, well-planned approach to circularity does more than ensure compliance, it creates cost efficiencies, strengthens sustainability credentials, and positions companies as leaders in an increasingly regulated and sustainability-driven industry.
As Europe’s packaging landscape continues to evolve, the companies that anticipate these shifts and adapt accordingly will be the ones best positioned for long-term success.