In-Depth Analysis of PPWR Chapter 1: General provisions


Over the coming weeks, I’ll be diving deep into the proposed PPWR and its various articles, focusing on the most critical aspects we need to consider in the packaging industry. My goal with this series is to help you understand the new regulations and their implications, so we can all stay informed and compliant.

Article 1: Subject Matter

  • Purpose: Establishes comprehensive requirements for the environmental sustainability and labelling of packaging throughout its life cycle, encompassing production, use, and disposal.
  • Scope: Emphasizes extended producer responsibility (EPR) and mandates measures for waste prevention, including the reduction of unnecessary packaging, promotion of reuse and refill, and ensuring effective recycling of packaging waste.
  • Goals: Seeks to harmonize national measures to eliminate trade barriers, avoid market distortion, and enhance competition within the EU. The regulation also aims to mitigate the environmental and health impacts of packaging waste.
  • Contribution: Aligns with the EU’s broader environmental objectives, supporting the transition to a circular economy and aiming for climate neutrality by 2050, as stipulated in Regulation (EU) 2021/1119.

Article 2: Scope


  • This regulation is applicable to all packaging and packaging waste, irrespective of the material used, including but not limited to plastics, paper, metal, and glass.
  • It encompasses packaging used across various sectors such as industry, manufacturing, retail, distribution, offices, services, and households.

Relation to Other Regulations:

  • Operates without prejudice to Directive 2008/98/EC concerning hazardous waste management and other Union regulatory requirements related to safety, quality, health protection, hygiene, and transport.
  • In cases of conflict, Directive 2008/68/EC on the transport of dangerous goods takes precedence.

Article 3: Definitions

Key Definitions:

Packaging: Defined comprehensively to include items intended for containment, protection, handling, delivery, or presentation of products. This encompasses several formats and functions, such as:

  • Take-away Packaging: Service packaging for immediate consumption off-premises.
  • Primary Production Packaging: For unprocessed primary production products.
  • Sales Packaging: Constitutes a sales unit at the point of sale.
  • Grouped Packaging: Groups sales units for sale or stock-keeping purposes.
  • Transport Packaging: Facilitates handling and transport to prevent damage.
  • E-commerce Packaging: Specific to online sales delivery.
  • Innovative Packaging: Utilizes new materials enhancing packaging functions and demonstrating environmental benefits.
  • Single-use Packaging: Non-reusable packaging.
  • Contact Sensitive Packaging: For products requiring specific regulatory compliance.
  • Economic Operators: Detailed definitions for all parties involved in the packaging lifecycle, including manufacturers, suppliers, importers, distributors, and authorized representatives.

Waste Management Key Definitions:

  • (24) Composite Packaging: Packaging made of multiple materials that cannot be separated manually, forming a single integral unit unless a material constitutes less than 5% of the total mass.
  • (25) Packaging Waste: Any packaging or packaging material considered waste as per Directive 2008/98/EC, excluding production residues.
  • (27) Re-use: Operations where reusable packaging is used multiple times for the same purpose for which it was conceived.
  • (28) Rotation: The cycle from when reusable packaging is placed on the market with the product to when it is ready to be reused again.
  • (30) Systems for Re-use: Organizational, technical, or financial arrangements that enable re-use, including deposit and return systems ensuring packaging is collected for re-use.
  • (32) Refill: An operation where a container owned by the end-user is refilled by the end-user or final distributor with products purchased by the end-user.
  • (34) HORECA Sector: Refers to the accommodation and food service activities sector.
  • (36) Design for Recycling: Design of packaging ensuring recyclability with established collection, sorting, and recycling processes proven in an operational environment.
  • (37) Recyclability: Compatibility of packaging with waste management and processing, based on established processes, to ensure effective recycling.
  • (38) Packaging Waste Recycled at Scale: Packaging waste that is collected, sorted, and recycled using established processes that meet minimum annual recycled material quantities at the Union level.
  • (39) Material Recycling: Reprocessing of waste materials into new materials or substances, excluding biological treatment, energy recovery, and backfilling operations.
  • (40) High-Quality Recycling: Recycling processes that produce materials equivalent in quality to the original, preserving technical characteristics and substituting primary raw materials.
  • (46) Post-Consumer Plastic Waste: Waste plastic generated from products supplied for distribution, consumption, or use and placed on the market within a Member State or third country.
  • (47) Compostable Packaging: Packaging that biodegrades in industrially controlled conditions. It undergoes biological decomposition, possibly including physical treatment and anaerobic digestion (we have this in Sweden), and ultimately converts into carbon dioxide (or methane in the absence of oxygen), mineral salts, biomass, and water. This packaging must not hinder or jeopardize the separate collection, composting, or anaerobic digestion processes.
  • (48) Home Compostable Packaging: Packaging that can biodegrade in non-industrial, home composting conditions, allowing private individuals to produce compost for personal use.
  • (49) Biobased Plastics: Plastics derived from biological resources such as biomass feedstock, organic waste, or by-products, regardless of whether they are biodegradable or non-biodegradable.
  • (64) Life-Cycle: All stages of a packaging’s life, from raw material acquisition to end-of-life management, including manufacturing, distribution, use, and recycling.

Article 4: Free Movement

  • Compliance: Packaging must meet the Regulation’s sustainability and labelling standards to be legally marketed.
  • Prohibition: Member States cannot impede the market entry of compliant packaging.
  • National Requirements: While Member States can introduce additional sustainability requirements, these must not conflict with the Regulation and must not hinder the market entry of compliant packaging.
  • Exhibitions: Non-compliant packaging can be displayed at trade fairs provided it is clearly marked as non-compliant and not for sale until it conforms to the Regulation.


Chapter 1 of the PPWR establishes a robust framework for sustainable packaging practices. By setting stringent standards and definitions, it aims to create a cohesive approach across the EU, fostering a circular economy and striving for climate neutrality by 2050. For us in the packaging industry, understanding these detailed requirements is crucial for ensuring compliance and leveraging the opportunities presented by this regulatory shift.

PPWR will be implemented by each EU Member State, meaning they will adapt their laws, set up compliance systems, and might add extra national requirements. Keeping up-to-date with both the EU-wide regulations and specific national implementations will help you optimize your operations and stay compliant.

💬 I’m here to help you navigate these changes and make the most of the opportunities they bring!




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