As of 12 August 2026, the EU’s Packaging and Packaging Waste Regulation (PPWR) generally applies to all its member states. It provides answers to questions that have been posed to packaging businesses in recent years, but it also asks several new ones.
Converters and brands now know the general direction to take as regulations become more demanding. However, many of the specifics are still not set.
In short, this is the beginning of a new chapter rather than the end of the PPWR story. PPWR isn’t a single checkpoint for businesses to reach. Instead, it should be viewed as one part of a broader evolution of the value chain, and packaging design decisions should be considered in the same way. Not as a series of individual decisions taken one after the other, but as a more holistic, fluid process.
A dynamic approach to packaging regulation
One of the headline targets set by PPWR is that all packaging placed on the EU market must reach a certain recyclability score by 2030. This sounds cut-and-dry, but as those in the industry will know, the reality is anything but.
Material choice, design, technical performance, recyclability, carbon impact, consumer communication, and end-of-life outcomes all influence each other. A change made to improve recyclability can simply shuffle environmental impact elsewhere when the aim should be to reduce it. A lighter structure may reduce material use, but it still has to protect the product. A new barrier solution may support shelf life, but it must be assessed against recyclability. A sustainability claim may help consumers make better choices, but only if it is accurate, substantiated, and relevant to the system the packaging actually enters.
This last point is critical, because just as packaging design decisions don’t exist in isolation, neither does packaging itself. Its circularity is influenced by the infrastructure around it and the behaviour of the consumers who interact with it. And all of this must be considered from the very first conversations when beginning a packaging project.
And this entire process is just one cog in a much larger system. PPWR has change and evolution baked into its foundation, incorporating incrementally shifting targets and entirely new measures – such as official design for recycling guidelines – to be introduced at a later date. It represents a more dynamic approach to packaging regulation, and the response needs to be equally dynamic if businesses are to adapt and thrive in a more complex market.
Material differences
This demands a shift in mindset when thinking about packaging, and specifically packaging circularity. PPWR heavily incentivises recyclable packaging, but it has to be developed with real-world outcomes in mind. A pack may be technically recyclable but still end up in a landfill if it isn’t designed with existing infrastructure in mind. It must be designed for the recycling process, collected in the market where it is sold, sorted into the correct stream, and processed into valuable secondary material. If one part of that chain fails, so does the desired circular outcome.
Eurostat data shows that the EU generated 79.7 million tonnes of packaging waste in 2023, equal to 177.8 kg per inhabitant. Paper and cardboard represented the largest share at 40.4%, while plastic accounted for 19.8%. In the same year, the EU recycled 42.1% of plastic packaging waste1 and 87% of paper packaging waste2. The figures show both progress and the distance still to travel.
The obvious cue to take from these numbers is to focus on paper and board packaging, as it is made from a material that is already widely recycled, with cross-industry initiative 4evergreen targeting a 90% recycling rate by 20303. But that ambition depends on more than material substitution. Collection, sorting, contamination control, coatings, adhesives, barriers, inks, and consumer behaviour all affect what happens after use, meaning circularity can’t simply be retrofitted onto an existing design.
The same is true of performance. Packaging can’t only be recyclable. It has to protect the product, run efficiently through production, meet packing and logistics requirements, communicate clearly on shelf and support the customer’s brand. A recyclable pack that fails in the supply chain, increases product damage, or creates waste through consumer confusion is not a sustainable solution.
Moving collaboration upstream
The key to solving these challenges is collaboration. At MM Group, we see the strongest results when our partners begin the collaborative process as early as possible.
And here is where the connections between the MM Group divisions become relevant. We understand the value of linking substrate expertise with finished packaging application knowledge and market-specific technical capabilities, helping customers consider board performance, structural design, converting behaviour, recyclability, regulatory requirements, and consumer communication in one connected process.
This doesn’t mean every packaging question has one comprehensive answer. In many cases, the right solution depends on the product, market, supply chain, shelf-life requirements, recycling route, brand objective, and many other factors. Both virgin and recycled fibres also have important roles in a functioning fibre-based packaging ecosystem. The priority should be application-led material selection, supported by evidence and aligned with the specific needs of the pack.
This approach also supports better communication. New EU rules on empowering consumers for the green transition will apply from 27 September 2026, increasing scrutiny of environmental claims and helping to address greenwashing. For brands, this means packaging claims must be clear, accurate, and supported by transparent data. Design, compliance, and communication are now part of the same process.
PPWR, burdensome though it will be, is now reality. Businesses should therefore look for opportunities to improve how packaging is developed in order to minimise disruption. This will ultimately help the industry move toward smarter development, stronger communication, better design decisions, and packaging that performs in the real world.
PPWR is rewriting the rules of packaging design. Compliance is mandatory, but opportunity only presents itself to businesses taking a smarter approach to packaging design.