November 21, 2025

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Team PCX

PPWR, explained: What Europe’s new packaging rules mean for U.S. brands

If you’ve been gearing up for California’s SB54, meet its bigger European cousin. With the EU’s Packaging and Packaging Waste Regulation (PPWR) now in force across the bloc, the rules extend beyond plastics to all packaging - and they’re more specific about design-for-recycling, reuse expectations, and minimum recycled content than most U.S. teams are used to.

Put simply, PPWR is Europe’s single playbook for packaging. It defines what your pack can be made of, how recyclable or reusable it needs to be in real systems, and how much post-consumer recycled (PCR) content you must build in, turning packaging choices into yes/no decisions about European market access.

In our recent webinar on what American brands need to know about European packaging regulations, we spoke with Martyn Tickner, Chief Advisor, Circular Solutions, at the Alliance to End Plastic Waste. In this post, we distill his insights on what American brands need to know about PPWR, how it stacks up against California’s SB54 laws, and what the implications are for circular system design.

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Why PPWR exists - and why it matters to you

Europe is tackling two headaches at once. First, circularity: too much packaging is collected but not returned to packaging applications at the quality brands need - especially for food contact. Second, fragmentation: 27 member states have been running similar but different rules. PPWR, which was published in January 2025 (most of its provisions will begin to apply on August 12, 2026), replaces the patchwork with a single, directly applicable regulation, so Berlin and Barcelona sing from the same hymn sheet.

Uniformity raises the bar and removes ambiguity. While there’s less room to interpret differing national rules, there’s far more clarity to standardize designs, plan PCR supply, and model EPR costs across the whole bloc. Treat it as product-market fit for Europe: you either meet the spec or you don’t.

Martyn’s take: PPWR’s purpose is not to “collect more stuff” - it’s to get more material back into packaging. Think of it as an engineering brief, not a press release.

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What’s actually covered by PPWR (minus the legalese)

The regulation aims to ensure all packaging is recyclable by 2030 and includes targets for reducing packaging waste per capita by 15% by 2040.

All materials are in scope. Plastic, paper/board, glass, metals - if it’s packaging, PPWR cares. A paper pivot won’t “escape” these rules.
Design for recycling is non-negotiable. Expect requirements that push you toward mono-material structures, compatible labels/inks/closures, and away from complex multilayer laminates that that create significant complexity for sorting and recycling systems.
Recycled content moves from nice-to-have to must-have. For many plastic applications (with special treatment for food contact), you’ll need minimum levels of post-consumer recycled (PCR) content on a set timeline. It’s Europe’s way of forcing demand for high-quality recycled resin.
Reuse is back on the table. In certain categories and channels, PPWR nudges (and in some cases requires) reuse systems to grow. It won’t fit every SKU, but the signal to test reuse where it makes sense is loud and clear.
Labeling and consumer communication are harmonized. You’ll see standardized marks for recyclability, material identification, and disposal - goodbye, “every country has its own sticker.”
EPR is universal, and fees are eco-modulated. You’ll still pay Extended Producer Responsibility fees, but under PPWR those fees increase or decrease based on how recyclable your pack is in real life. That turns design decisions into P&L decisions.

The subtext: PPWR is all about feeding high-quality material back into packaging markets. That means quality sorting, quality recycling, and - critically - quality-controlled design upstream.

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PPWR vs. California’s SB54: same destination, different road

California’s SB54 has been the U.S. reference point for many teams. It’s a great start, but it’s not Europe. Here’s the practical comparison we keep hearing from U.S. packaging leaders (and that Martyn underscored on our webinar):

1) Scope: plastic vs. everything

SB54 is plastic-focused. If you shift an SKU to paper, you may change your obligations dramatically in California.
PPWR is material-agnostic - it covers all packaging. A substrate swap doesn’t move you out of scope; it just changes which design rules you must meet.

2) The performance lever: recycled content vs. recycling rate

SB54 pushes system performance (recycling rates, source reduction) and funds infrastructure, producer responsibility, and end-market development across plastics.
PPWR keeps an eye on rates too, but its headline lever is mandatory recycled content for plastics. That’s huge. It forces the market to deliver high-quality PCR, which in turn pushes better sorting and higher-quality recycling. If your EU pack is food contact, you’ll need to plan early for the solutions to provide compliant feedstock.

3) The money signal: fee modulation at design level

SB54 brings serious revenues into the system (including environmental mitigation funding) and caps, but its core financial pressure is broad.
PPWR goes granular through eco-modulated EPR fees. Two otherwise similar packs can have very different annual costs purely because one is easy to sort and reprocess and the other is a nightmare. That makes the business case for redesign far easier to defend.

4) Regulatory architecture: one EU rule vs. one U.S. state

SB54 is a state law inside a patchwork of U.S. state policies that may converge over time - but you’re still juggling differences.
PPWR is one regulation for 27 countries. Once its secondary rules and guidance land, you’ll have a single, very prescriptive playbook for the whole bloc.

Martyn’s take: Optimizing only for SB54 risks undercooking Europe. If you aim for PPWR, you’ll generally be fine in California; the reverse isn’t guaranteed - especially where high-quality and food-grade PCR is required

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What a “PPWR-ready” packaging strategy looks like

Think of it as a three-lane highway: Design, Supply, and Data.

1) Design: ruthlessly simplify formats

Kill complexity wherever possible. Multimaterial laminates with incompatible polymers and barrier materials are going to be fee-heavy and face recyclability hurdles.
Specify sortability. Can an EU NIR scanner identify your pack as the right stream? Will your labels, adhesives, and inks wash off or contaminate?
Engineer for the system you actually have. Design to the EU reality - what MRFs and recyclers can sort and sell today and in the near term - not to an idealized future plant.

2) Supply: lock in future-grade PCR now

Segment your PCR needs by resin (rPET, rHDPE, rPP, etc.), by grade (food vs. non-food contact), and by tonnage per year.
Source strategically. Mechanical recycling will cover a lot of ground; chemical recycling may be relevant for hard-to-clean streams and food-grade constraints, but you’ll need to watch how Europe treats mass balance and claims. (You can also source recycled plastic from verified projects battling plastic pollution on the front lines of the crisis, helping accelerate the transition to a circular economy.)
Don’t get squeezed in 2028–2030. Everyone will be hunting for the same compliant PCR at the same time - early MOUs, offtakes, and quality specs beat panic buying.

3) Data: prove you’re doing what you say

Composition data (what’s in the pack and why), recyclability evidence (lab protocols, design guides), and PCR proof (audited chain of custody) will become table stakes.‍
EPR fee modeling belongs with your finance team. Design choices will swing costs up or down every single year - so run scenarios and make them part of product P&L.

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A simple sequencing plan you can start this quarter

Inventory your EU-bound SKUs. Flag food-contact items, multilayers, dark colors, metallization, and decorative elements that impede sorting.
Score each SKU’s recyclability. Use a recognized design guide (e.g., APR/CEFLEX equivalents) as a proxy for what EU systems accept and sort today.
Build a PCR roadmap. For each resin and application, outline your minimum viable PCR content by year, the plausible supply route, and any barriers (odors, migration, mechanical properties).
Run fee scenarios. Model EPR costs for “as is” vs. “redesigned" in the countries leading EPR fee development (e.g., Belgium, Netherlands, Germany). This reframes sustainability as cost leadership and helps cross-functional teams prioritize
Pilot one reuse or elimination move. Even if it’s not your core channel, piloting a targeted reuse or elimination initiative now will de-risk bigger moves later.

Martyn’s take: Don’t wait for perfect clarity and perfect solutions - pilot, develop, adopt. The teams that commit in 2026 won’t be scrambling in 2029.

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What to tell your CEO (and what to ask for)

This is market access, not a CSR project. If a SKU can’t legally be “placed on the market,” you’ve lost revenue, not just a green point.
Design and supply are the choke points. Approving a packaging spec in 2026 that requires food-grade PCR you haven’t procured is a recipe for missed launches.
Budget follows design. EPR fees will punish the wrong formats every single year; redesign is often the cheaper option over a 3–5-year horizon.
We need cross-functional ownership. Packaging, procurement, quality, legal, finance, and marketing all have real deliverables under PPWR.

Martyn’s take: Start where the tonnage and risk are. Fix the 20% of SKUs that drive 80% of EU volume and complexity - fast wins there buy time for the long tail.

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Two common misconceptions - cleared up

“We’ll just switch to paper.”
Paper is in scope, too. If it’s a composite, carries wet strength resins, or creates other recovery issues, you haven’t dodged the recyclability question - you’ve moved it. And green claims and carbon taxes will encourage onl truly beneficial substitutions.

“We’ll hit the recycling rate and call it a day.”
Rates matter, but Europe’s recycled content pull is what will pinch supply. You can’t buy your way out of physics; you need clean, consistent feedstock, which starts with smart design and disciplined sorting.

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TL;DR

PPWR is about closing the loop, not just collecting more material. If you wait until targets bite, you’ll discover high-quality PCR is scarce, recyclers are booked, and your engineers are scrambling.

Our own work with brands shows that fee-driven redesign often pays back faster than expected. Moving from a “problem” structure to a mono-material format doesn’t just help compliance - it reduces cost volatility, unlocks more suppliers, and simplifies operations.

If you’re U.S.-based and lightly SB54-fluent, treat PPWR as the higher bar. Start with design simplification, secure PCR like it’s a critical raw material, and bring finance into the room for EPR modeling. Get those three right and you’ll not only clear EU compliance - you’ll build a packaging system that’s cheaper to run and harder for competitors to copy.

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Watch the full webinar, CSRD and PPWR: What New EU Regulations on Plastic Packaging and Reporting Mean for American Brands, on the PCX YouTube channel here.

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Next up: a separate post on CSRD - how to prove what you’re doing, using the ESRS standards and double materiality lens, and how U.S. suppliers can stay in their EU customers’ “easy to buy from” list.

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Explore our EPR essentials series:

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