Manufacturers in the EU are required to adhere to the Packaging and Packaging Waste Regulation. This is a law that mandates all packaging to be:
- Recyclable
- Reusable
- Compostable.
This should be in effect by 2030. It applies to manufacturers of packaged goods and packaging components.
As a producer, here is how to incorporate this regulation into your production cycle.
Perform a Comprehensive Packaging Audit
Write a systematic list of the packaging formats you employ. This includes:
- Primary, secondary, and tertiary packages.
- Material composition (including multilayer structures)
- Weight per unit and per pallet.
- Percentage of recycled content.
- Country of distribution.
You require a known material breakdown at the component level:
- Caps
- Labels
- Adhesives
- Inks.
Without such data, you will not be able to evaluate recyclability.
Redesign for Recycling Capacity
The regulation places more emphasis on design and recycling. PPWR implies that your packaging must be compatible with the EU's current collection, sorting, and recycling systems.
Focus on:
- Single material. Avoid multi-material laminates.
- Removable elements, e.g., labels and closures.
- Standard polymer types where applicable. Common examples are PET, HDPE, and PP.
- Avoiding problematic additives.
Suppose you apply barrier protection with multilayer materials. Consider the possibility of implementing functional coatings. Alternatively, use other structures that can perform equally well with better recyclability. At this point, engineering and compliance teams have to work together.
Maximize Packaging Volume and Weight
Minimization is one of the requirements of PPWR. You need to make sure that you package only the necessary amount needed to protect the product and facilitate logistics.
Practical steps include:
- Eliminating empty space in shipping containers.
- Reducing weight without risking mechanical stability.
- Optimizing palletizing patterns.
- Removing unnecessary secondary packaging.
Record your technical packaging specification. Law enforcement might insist on evidence that you are not using excess material.
Look for Recycled Content Supply
For plastic packaging, targets for minimum recycled content apply to specific categories. You must:
- Determine the types of packaging that are subject to quota.
- Secure long-term contracts for PCR material.
- Ensure supplier certification.
- Install quality checks for incoming materials.
The quality of recyclates may differ in terms of:
- Color
- Mechanical properties
- Contamination.
Conduct production testing and validation trials. This is important before ordering bulk supplies.
Update Technical Documentation
Compliance is also administrative. You should have technical records showing that your packaging complies with regulatory concerns.
This typically includes:
- Declarations of material composition.
- Recyclability assessments
- Verification of recycled content.
- Conformity declarations.
- Mechanical and functional performance test reports.
Have record retention policies. They should comply with regulatory timeframes. Also, standardize data management.
Explain the Extended Producer Responsibility Status
Manufacturers based in different countries tend to ignore country-specific duties.
As a producer, establish whether you are under legal responsibility to be regarded as the producer in every EU country where your products are introduced to the market. If so, you must:
- Register with the national authorities.
- Report packaging volumes.
- Pay EPR fees.
Select authorized representatives, where necessary.
Introduce Internal Compliance Governance
Lastly, distribute specific roles in departments:
- Engineering: design conformity.
- Procurement: compliant sourcing.
- Quality: documentation, control, and testing.
- Legal/compliance: regulatory oversight.
- Sales/logistics: market needs on a country basis.
Regular internal audits help minimize risk exposure.
