Over 200 participants, a new location with plenty of room for exchange and an inspiring programme all about the PPWR: Future Resources 2025 in Cologne was a complete success. Together with Interzero and interpack, packaging journal co-organised the event for the first time as an official event partner.
In the Alter Wartesaal right next to Cologne's main railway station, where the WDR Mitternachtsspitzen is usually recorded and the cult party Lambertz Monday Night takes place during the confectionery fair, the leading minds of the recycling and packaging industry will be exchanging ideas at the annual Future Resources conference this year.
However, the keynote speech by meteorologist Sven Plöger first focussed on the climate. His statement on climate change „We don't have a knowledge problem, we have an action problem“ was easily transferred to the current situation in the packaging industry by the following speakers. For example, when it comes to the recyclate quotas prescribed in the PPWR, which are not expected to be achieved by 2030. However, lawyer Dr Markus W. Pauly first explained the obligations that companies will face from 2026 with the PPWR - and why now is the right time to prepare.
From August 2026, a phase of far-reaching changes will begin for the entire European packaging industry. The new EU regulation on packaging and packaging waste (PPWR) is intended to strengthen the circular economy, reduce waste and increase the mandatory use of recyclates. The regulation, which came into force on 12 February 2025, will apply from 12 August 2026, but many key details are still missing.
Between EU law and national law
With legal precision and a twinkle in his eye, lawyer Pauly explained why the regulation - although it is formally an EU regulation - contains numerous elements of a directive and therefore plays a hybrid role between EU and national law, which leads to legal uncertainty. This means that although the PPWR comes into force directly in all member states, many details must first be specified in national implementing laws - which have not yet been passed. „There are still no delegated acts from Brussels, no national implementing laws. We currently have nothing, but the deadlines are running,“ says Pauly, describing the current situation. The industry therefore knows that it is facing extensive obligations, but does not yet know the specific implementing provisions.
At the same time, the PPWR significantly expands the definition of packaging. In future, tea bags and coffee capsules, for example, will also be classed as packaging for the first time. Companies that have not previously categorised these products as packaging must expect new obligations in future - from registration and licensing to conformity assessment.
Who is the manufacturer, who is the producer?
The distinction between producer and manufacturer has also been revised. Producers are therefore those who develop or manufacture packaging and are responsible for ensuring that the packaging produced fulfils the requirements of the PPWR. Manufacturers, on the other hand, are companies that place packaging on the market in a member state for the first time. This does not correspond to the familiar German model, in which the importer is automatically considered the manufacturer. For globally active companies, this results in shifts in the liability and responsibility structure.
In addition to formal aspects, Pauly dealt with the substantive obligations of the PPWR: substance bans such as PFAS, minimum recyclate content for plastic packaging, the requirements for recyclability, minimising packaging and reusable quotas. He emphasises the uncertainty of many companies that are still waiting for national implementation regulations - and are also under time pressure: This is because the first regulations will become binding from 12 August 2026. However, some of the regulations will be subject to separate entry into force requirements. For example, the recyclability requirements are expected to come into force in stages from 1 January 2030.
The presentation thus provided a clear legal compass in an increasingly complex regulatory environment - and showed why packaging manufacturers, brands and retailers should urgently address the upcoming obligations now.
Many definitions are still missing
Recycling-friendly design, declarations of compliance and tight timeframes: Gunda Rachut from the Central Agency Packaging Register described the situation as a „maze of maize“ in which everyone sees something different because many elements of the PPWR have been announced but not defined. The PPWR brings many challenges for companies - much of which should have been implemented long ago. The timetable is ambitious: National implementation laws, technical documentation and assessment procedures must be in place within a few months - a challenge for both authorities and companies.
Design for recycling is set to become mandatory from 2030, but some of the definitions, assessment standards and test methods will be introduced as early as 2026. European standardisation bodies and the EU's Joint Research Centre are working in parallel on catalogues of criteria, but so far there are neither harmonised standards nor recognised procedures.
At the same time, the PPWR requires binding technical documentation and declarations of conformity for all packaging for the first time. Companies must disclose material compositions, assess risks and prove recyclability according to standardised criteria - although these criteria have not yet been established. Manufacturers with a wide range of products are particularly affected: thousands of items of packaging have to be assessed, documented and, if necessary, converted. In addition, new declarations of conformity have to be drawn up without any standardised test methods or standards yet being in place.
The ZSVR has already revised its minimum standard for recyclability in order to anticipate the requirements of the PPWR. At Future Resources, Gunda Rachut showed how manufacturers will be able to assess their packaging in future - from the proportion of recyclable materials and incompatibilities to cross-material standards. She called for more transparency in the supply chain: In future, suppliers would have to disclose which materials, additives or barrier layers they use so that producers and distributors can act in accordance with the law. She also concludes that companies should prepare early to avoid being overrun by regulation. After all, recyclability will become a market-relevant requirement from August 2026.
The clock is ticking
Matthias Giebel, Partner at b+p Consultants, vividly explained to the participants why Europe is unlikely to achieve its recyclate quotas by 2030 - and what companies need to do now to avoid falling behind. The EU wants to turn the circular economy into a successful business model, but reality is lagging behind. The gap between political aspirations and the actual availability of recycled materials is huge. According to Giebel, even on optimistic assumptions, Europe will produce around one million tonnes too few recyclates by 2030 to meet the prescribed usage quotas.
Using current market data and interviews with industry representatives, he illustrates that the industry has long been confronted with a massive „recyclate bottleneck“: mechanically recycled plastics are currently just enough, but high-quality grades are rare and expensive. Chemical recycling has so far mainly existed at pilot level and only delivers „homeopathic quantities at homeopathic prices“. Investments in new capacities are being postponed or cancelled - even though the political framework and financing options are actually available.
Competition for recyclates
As a result, competition for available recyclates will intensify. Branded companies currently procure most PCR volumes from their packaging suppliers, but these procurement channels will no longer be sufficient from 2030. Giebel therefore recommends that companies secure strategic partnerships with recyclers, dual systems and sorters at an early stage. If you wait, you risk production bottlenecks, rising costs and regulatory risks.
At the same time, the PPWR is tightening the requirements for reusable packaging and waste avoidance. Transport and sales packaging should consist of 40 per cent reusable solutions by 2030, and even 70 per cent by 2040. Minimum proportions of reusable systems will also apply to beverage packaging in future, and these will continue to increase.
Basic direction remains clear
At the same time, the EU is introducing a binding reduction target for packaging waste per capita for the first time, measured against the reference year 2018, with the aim of reducing the amount by at least 15 per cent by 2040. These targets will have a profound impact on the product development, logistics and product range design of many companies. Although the EU is planning exceptions in some areas - as of October 2025, for example, certain transport aids such as strapping bands or pallet wrapping are not affected for the time being - the basic direction remains clear: less material, more recycling, more reuse.
The fact that all these requirements are not only ecologically motivated, but also pursue an industrial policy goal, is shown by the fact that the PPWR is embedded in the Green Deal and the subsequent EU Clean Industrial Deal. The circular economy should not only protect the environment, but also become a viable business model that keeps value creation in Europe, reduces dependencies and creates new jobs.
For companies, however, this means that regulatory requirements are not likely to be weakened, but rather tightened. According to current stakeholder surveys, the industry itself assumes that the quotas will be implemented largely unchanged. A fundamental backpedalling is considered unlikely.
packaging journal 6/2025
This article was published in packaging journal 6/2025 (December).
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