On 11 February 2025, the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, ‘PPWR’) entered into force, affecting companies selling and shipping products into Europe.
The PPWR relies on a number of implementing acts to flesh out aspects of the regulation. The 12 August 2026 was the deadline set for the publication of the Implementing Act which is set to confirm the EU’s harmonised packaging labelling system.
However, it’s still yet to emerge.
As Food Manufacture understands it, many stakeholders feel there is insufficient guidance and clarification around many aspects covered by the PPWR. Due to the Act’s complexity, additional time is required for further engagement with stakeholders to ensure the implementing act to be clear, comprehensive, pragmatic and robust.
Don’t panic
However, this additional time will not result in a reduction of the phasing-in time-period for the packaging industry and Member States.
The labelling requirements to be established under the implementing Act will only apply 24 months after the date of its entry into force, meaning that stakeholders will have two years to adapt to the new requirements.
“While any delay to the start of implementation leaves brands with a slightly longer period of uncertainty, the timeline – once the Act is announced – still allows two years’ implementation time. Once the EU’s plans are clear, the UK can also move forward with plans for its own mandatory label under pEPR,” added Jude Allan, managing director for OPRL.
“Like many areas of legislation, the final outcome may look simple, but OPRL’s experience over the last 17 years shows how complicated and nuanced the process can be. In the case of PPWR, legislators have had to consider areas like sorting capability across multiple members states, and how to address language issues.”
Convincing consumers
But for OPRL, the issue goes beyond industry compliance and into consumer behaviour: “Whatever the process, the bottom line is, that if we don’t communicate with consumers around recycling, we cannot expect them to do the right thing.
“Recent OPRL research demonstrates the importance of clear communication with consumers to achieve the necessary levels of recycling.”
Its survey shows conclusively that consumers respond positively to calls to action; with 78% of respondents saying they would be likely to rinse packaging that included a call to action, compared with 51% where no action was recommended.
He added that OPRL is therefore “pleased to see that brands are still likely to be able to include instructions next to the PPWR label”.
