Your expert for questions
Emanuel Chibesakunda
Partner, Sustainability Services at PwC Germany
Tel: +49 175 3516769
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How you can optimise your packaging management and sustainably reduce packaging waste
The Packaging and Packaging Waste Regulation passed by the EU Council on 16 December 2024 was a pioneering step in the fight against increasing environmental pollution and the process of greater European harmonisation.
From 12 August 2026, the first provisions of the regulation will start to apply in the European Union. They will be gradually stepped up until 2030 in order to increase the circularity of packaging in the coming years. The requirements vary depending on the packaging material and application scenario.
“Be it paper, cardboard, glass or plastic – all packaging materials are affected by the amendments. For companies and customers, this means rethinking packaging, educating people about how to handle it responsibly and internalising this approach.”
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Analysing packaging, minimising risks and promoting sustainable innovation
The regulation, which came into effect in February 2025, pursues three main goals:
1. Preventing the creation of packaging waste
2. Promoting a high-value recycling loop
3. Reducing the demand for primary resources and creating a market for secondary raw materials
The regulation is based on the EU Green Deal and the Circular Economy Action Plan (CEAP), thus putting a clear focus on bolstering the circular economy. It was supplemented at the end of February by the Clean Industrial Deal.
What does that mean for practical implementation?
Some packaging in specific formats and for different application scenarios can no longer be put into circulation. In addition, the maximum amount of empty space permitted for outer packaging, transport packaging or packaging for e-commerce is limited. Reusable and refillable packaging solutions are also being promoted (multi-use and deposit schemes).
Extended producer responsibility (EPR) also plays a significant role and is gaining relevance. The reason for this is the increasingly heated debate about amending ERP fees in the context of ecomodulation. While ERP fees have so far covered mostly costs for waste management (including collection, transportation, sorting and recycling), ecomodulation is intended to create an incentive for recyclable packaging. Due to its circularity, this packaging should be less expensive in future than conventional packaging. The aim is to create incentives for manufacturers to design their products so that they are easier to reuse, repair or recycle.
Businesses must adhere to rigid labelling rules in order to improve the sorting process. Moreover, specific design requirements for increasing recyclability have been introduced – based on mandatory targets. On top of this is the manufacturers’ duty to ensure that the relevant plastic packaging is compostable.
Recycling targets according to Article 46 of the regulation
| Current targets (%) | By 2025 (%) | By 2030 (%) | |
| All packaging | 55 | 65 | 70 |
| Plastic | 25 | 50 | 55 |
| Wood | 15 | 25 | 30 |
| Ferrous metals | 50 (incl. aluminium) | 70 | 80 |
| Aluminium | - | 50 | 60 |
| Glass | 60 | 70 | 75 |
| Paper and cardboard | 60 | 75 | 85 |
Source: own representation
“Companies must start actively grappling with the new requirements now in order to meet the targets set out in the regulation. For consumers, it’s not only sustainable products that are increasingly becoming a key purchasing criterion, but also sustainable packaging. Innovative and compliant packaging will make all the difference in the future.”
We offer a modular range of services tailored to you
- Baselining and market analysis
- Strategy development
- Transformation
- Implementation and monitoring
- Reporting
Baselining and market analysis
As part of internal baselining (inside-out), we will identify the potential, opportunities and risks that arise within the context of the EU packaging regulation using a gap analysis. We will also conduct impact and material flow analyses, consult relevant stakeholders and assess your current initiatives. Based on this, we will then derive the measures going forward. The external market analysis (outside-in) allows you to better understand your competitors and to derive suitable measures for strategic positioning.
Strategy development
Building on the results of the internal and external analyses, we will define appropriate strategic steps that are tailored to your company and to your packaging – including corresponding materials. We will empower you to translate the potential of product compliance into sustainable innovations and to establish relevant performance indicators. A solid business case underpins your circular economy strategy and the status of your initiatives.
Transformation
Our experience with countless transformation processes has shown that change is not a given. Aside from helping you to ensure that individual packaging products meet the requirements, we will also help you to develop holistic governance concepts, adapt your internal processes and get to grips with EPR. We will provide you with customised support along the entire value chain as needed and ensure appropriate communication.
Implementation and monitoring
We will also support you with the implementation of your circular economy strategy. Together, we will define relevant training needs and develop appropriate training programmes. The aim is to allow all relevant stakeholders to actively build their knowledge. We will also advise you on capacity requirements and adjustments based on the business case so that you can implement processes efficiently. At the same time, we will conduct risk analyses, monitor the market and help you to continuously align your performance indicators with your goals.
Reporting
We also draw on our expertise as an auditor in the context of non-financial reporting in order to pool all required data points relating to your packaging products and prepare them for external reports. This also includes specific indicators for your circular economy strategy. In addition to external communication, we will also support you with internal communication activities of all kinds.
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