The international magazine for the pet food packaging industry
For many companies, this is a date they’ve jotted down—somewhere between summer vacation and annual planning. But anyone who thinks that way is underestimating the impact of the Packaging and Packaging Waste Regulation (PPWR).
Because the critical issues don’t begin when the regulation takes effect. They start now: in databases, in development departments, in discussions with suppliers.
The PPWR is not a regulation that you simply “implement” when the time comes. It is an intervention in existing systems—and systems cannot be overhauled at short notice.
The Deceptive Deadline
Formally speaking, the PPWR creates a uniform legal framework across the EU as of its entry into force. In practice, however, many of the specific requirements will not take effect until the coming years: recyclability, recycled content targets, labeling requirements, and packaging reduction mandates.
The problem: Those who wait until deadlines take effect to react will be too late.
Because packaging development takes time. Supply chains are slow to adapt. And data that does not exist today cannot simply be conjured up tomorrow.
What’s Really Changing
The PPWR is not a set of detailed regulations, but a restructuring of the entire system. In the future, it will no longer be enough to declare packaging theoretically recyclable. What will matter is whether it can actually be recycled within the existing system—in practice, not just on paper.
At the same time, the use of recycled materials is shifting from the voluntary to the mandatory sphere. Companies will be judged by the extent to which they use secondary materials and whether their packaging is even suitable for this purpose.
Added to this is growing pressure on the volume and weight of packaging. What is considered standard today may already be deemed oversized tomorrow. At the same time, reusable solutions will gain importance in certain segments—not as an option, but as a regulatory expectation.
Finally, requirements for labeling and transparency are becoming stricter. In the future, consumers, authorities, and market participants should be able to better understand what packaging is made of and how it should be disposed of.
Taken together, these changes mean one thing above all: packaging is shifting from a downstream issue to a strategic variable.
The Real Gap: Lack of Transparency
Discussions with companies reveal a recurring pattern: The biggest challenge is not the regulation itself, but the lack of an overview.
Packaging data is scattered—across purchasing, development, and external suppliers. Material compositions are often only partially known. Recyclability is assumed but rarely systematically verified.
In short: Many companies do not know with certainty how PPWR-compliant their current portfolio actually is. And this is precisely where the real work begins.
Five steps that are crucial now
1. Build a packaging inventory
The first step is a task that seems unspectacular and is therefore often underestimated: creating transparency.
Companies must first of all know what packaging they are using. That sounds trivial, but it rarely is. In many cases, information is scattered across different departments, supplemented by data from suppliers that is not always complete or up to date.
A robust packaging inventory therefore goes beyond simple lists. It includes materials, weights, and individual components such as closures or labels. Ideally, it also includes their origin. Only when this data is consolidated can a realistic picture of the company’s own portfolio emerge. Without this foundation, any further action is like flying blind.
2. Realistically Assess Recyclability
Taking stock alone is not enough. The crucial question is what actually happens to this packaging after it is used.
The PPWR shifts the focus away from theoretical recyclability toward the reality of existing systems. A piece of packaging may be technically recyclable, yet never actually enter a corresponding material stream. It is precisely this discrepancy that will become a problem in the future.
Companies must therefore begin to evaluate their packaging in relation to real-world collection, sorting, and recycling structures. This requires not only internal know-how but often also external expertise. The result of this analysis is more than a snapshot: it shows where there is an urgent need for action.
3. Identify and Prioritize Risks
Based on this assessment, it becomes clear that not all packaging is equally critical. This is precisely where the next step lies: differentiation.
Certain designs, such as multi-material solutions or composites that are difficult to separate, come under particular pressure. Others can be adapted relatively easily. The key is to systematically identify these differences and use them to establish priorities.
Companies that try to solve everything at once waste time and resources. Those who set clear priorities, on the other hand, can focus their efforts where regulatory risk and the cost of transition are greatest.
4. Initiate redesign processes
At this point, at the latest, analysis turns into implementation. This is precisely where it becomes clear just how slow many systems actually are.
Packaging cannot be changed overnight. Material changes, new suppliers, adjustments in production—all of these follow their own timelines, which are often longer than regulatory deadlines suggest.
That is why the most important step is not finding the perfect solution, but starting the process. Companies must begin to scrutinize, simplify, and gradually adapt their packaging. Those who wait until all requirements are clarified in detail will find that the real challenge was not the regulation itself, but their own reaction time.
5. Clarify responsibilities within the company
Perhaps the most underestimated hurdle lies not in materials or technologies, but in the organization itself.
The PPWR affects a wide range of areas: procurement, development, sustainability, logistics, and in some cases, marketing. Without clear lines of responsibility, friction and inefficiencies arise. Or simply stagnation.
Companies must therefore define who bears responsibility and how decisions are made. In many cases, there is no way around cross-functional structures. Because the PPWR is not an isolated issue that can be delegated. It forces companies to reorganize their internal processes.
A particular challenge: importers
For importers and internationally positioned brands, the Packaging and Packaging Waste Regulation significantly complicates the situation. This is because responsibility generally lies not with the manufacturer, but with the party that first places a product on the market in the European Union.
This creates a structural tension: regulatory responsibility lies in Europe, but actual control over materials and packaging design often rests with producers in other markets.
In practice, this means that many companies must meet requirements without being able to make the relevant decisions entirely on their own. Packaging specifications are dictated, material changes cannot be easily enforced, and adjustments along the supply chain take time—often more time than regulatory deadlines allow.
This is precisely why coordination with manufacturers becomes a key lever. Companies must clarify early on which requirements will apply in the future and how these can be integrated into existing production processes. In many cases, this will not be possible without contractual adjustments.
The PPWR thus forces importers into a role that goes beyond traditional trade functions. They become active shapers of packaging—whether they are prepared for it or not.
What Won’t Help Now
Despite growing clarity about the direction of the regulation, many companies are still reacting hesitantly. Often, they wait for final details to be clarified, as if uncertainty could be completely avoided. Others rely on individual measures that, while well-intentioned, come to nothing without an overarching strategy.
Particularly common is the attempt to address the issue through communication—with sustainability messages that do not stand up to technical reality. Yet this is precisely where a fundamental misunderstanding lies.
The PPWR is not a PR issue. It impacts real material flows and thus the substance of products and business models.
The competition has long since begun
While part of the industry is still waiting for guidance, other companies have already begun to prepare systematically. They are building data structures, testing their packaging under real-world conditions, and initiating initial adjustments.
This gives them a head start that will be nearly impossible to catch up with later. Because those who start early can iterate. Those who start late must react.
August is coming. The only question is whether it will be a starting point for companies—or a moment when it becomes clear what has been missed.
Official EU Sources on the PPWR
For companies wishing to delve deeper into the subject, these are the key references:
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