With the Packaging and Packaging Waste Regulation (PPWR) in application since 12 August, the first weeks of real-world experience are revealing where the mandate is proving difficult to implement. Its objectives remain broadly supported: reducing packaging waste, improving recyclability and creating a more consistent framework across Europe. The frustration is increasingly about how those objectives translate into day-to-day business.
One immediate pressure point is Extended Producer Responsibility (EPR). In simple terms, EPR makes the producer responsible for the packaging it places on the market, including its collection, sorting and recycling, with associated registration, reporting and financial obligations.
This is particularly significant for private label. The Commission's updated FAQs have clarified that a retailer's own brand packaging will generally make the retailer the relevant producer/manufacturer, even where standard packaging is selected and production is outsourced. The practical difficulty is that legal responsibility and access to information do not necessarily sit in the same place. Contract manufacturers and packaging suppliers may hold much of the detailed material and component data needed to demonstrate compliance.
The cross-border administration of EPR adds another layer of complexity. Businesses selling packaged goods in multiple EU countries can face separate national registrations, reporting requirements and, in relevant cases, the appointment of authorised representatives in individual Member States. In practice, this means navigating what can feel like 27 different systems, with different procedures, languages and data requirements. Recent European debate has focused particularly on the burden this creates for smaller and cross-border businesses.
The result is a system that is intended to harmonise Europe's packaging rules and make the Single Market easier to navigate, but which can be difficult and costly for businesses to manage in practice. The Economist, reporting in September on the early impact of the regulation, highlighted smaller retailers that had paused deliveries to some EU countries because of the costs and uncertainty involved.
There is also the question of whether the supporting framework is keeping pace. Some methodologies and detailed rules are still being developed, while businesses are already expected to demonstrate compliance.
So, the first signs are not simply indicating that PPWR creates more work. They point to the fact that responsibility, data and compliance capability are often held by separate businesses within the supply chain. For private label in particular, packaging is becoming a much more significant commercial and supplier-management issue, not simply a technical or sustainability matter.
PLMA's second Private Label Packaging Conference will be held 27 January 2027 in Rotterdam, bringing together private label manufacturers, retailers, and packaging experts to explore the working of the PPWR as well as the latest trends, challenges, and opportunities shaping the future of packaging. For more information click here.