EU PPWR: Packaging industry shifts to evidence-based compliance ahead of deadline

As the enforcement of the EU’s Packaging and Packaging Waste Regulation (PPWR) approaches, the packaging industry faces challenges around regulatory compliance and execution. 

The regulation will come into effect on August 12, 2026. To understand how the sector is preparing, Packaging Insights speaks to Packaging Strategy Lab (PSL), RecyClass, and The Circular Economy for Flexible Packaging (CEFLEX) about the ongoing shift to an “evidence-based” compliance approach.

Felix Gass, founder and director of PSL, tells us that one of the biggest misconceptions around PPWR is the belief that August 12 marks the beginning of the journey. “It is not when we start. It is when PPWR applies — so your packaging must be compliant and defensible on day one.” 

Need for data governance

As the PPWR redefines packaging data and reporting requirements, Gass emphasizes that the focus is shifting from supplier-managed topics to what he calls “the brand’s operating system.” The EU has aimed to set the standards for registration and reporting formats early this year.

“The industry is moving from ‘design plus sustainability’ narrative to ‘prove it’ compliance: material-level data, supplier-backed declarations, and audit-ready documentation that can be reported in structured formats,” Gass explains.

PPWR turns packaging into a data-and-evidence, according to Gass.

To meet this shift, he advises companies to treat packaging data governance as a core business system. This requires creating a consistent taxonomy, controlled evidence capture, and technical documentation discipline.

Addressing data gaps 

For flexible packaging, Alec Walker-Love from CEFLEX points out a key data gap in areas like sortability, recyclability, and the impact of design decisions in the open-access shared data space. To tackle this, CEFLEX conducted phase 2 of its Designing for a Circular Economy program (D4ACE). 

“Over two years, more than 600 representative flexible packaging samples were tested across five independent laboratories in Europe, generating around 1,760 data points on sortability and mechanical recyclability,” he says

“The data brings detail to how strongly small design choices, such as inks, barrier layers, adhesives, and their relative proportions, move through the system and influence sorting and recycling. Phase 2 results and guidance have helped replace assumptions with shared, transparent evidence on what we can control.”

Walker-Love shares that CEFLEX plans further testing to address remaining data gaps, expanding coverage to additional materials and components, and updating guidance as regulatory and technical requirements evolve.

“CEFLEX is also actively involved in European standardization, including leading work in the European Committee for Standardization on film design for recycling, where phase 2 data has already informed design-for-recycling criteria.”

“Importantly, these design insights do not sit in isolation. They underpin a range of CEFLEX work, from building credible recycled content end markets to shaping strategies for collection, sorting, and recycling systems for circular flexible packaging in Europe. Design is where system performance starts, and without robust design signals, progress downstream becomes harder and more costly.”

“We are operating in increasing uncertainty. D4ACE does not claim to remove that. It gives the industry a shared, data-led way to identify what can be done now to move closer to PPWR requirements and to support a circular economy for flexible packaging.”

Evaluating packing through new tech

At RecyClass, the approaching implementation of PPWR is seen as a change in momentum. 

”Companies will need to adhere to regulatory requirements rather than on voluntary initiatives alone. The readiness to take on this challenge is what will set companies apart in the years to come,” a spokesperson from the cross-industry initiative tells us.

“While the details of PPWR implementation are dependent on upcoming secondary legislation, RecyClass and its approach serve the industry players in getting ahead of the targets.” 

“The TechAp Tool is the latest development of its kind. This platform aims to facilitate the process of obtaining a RecyClass Technology Approval. By making the process fully integrated and more transparent, the Tool increases RecyClass’ capacity to evaluate plastic packaging technologies, innovative and existing ones.”

The online platform can streamline recyclability assessments for plastic product innovations.

“The TechAp Tool accelerates the cycle from concept to verification by providing a fast and trusted pathway to assess new materials, structures, or technologies against existing recycling streams in Europe. By integrating a science-based approach with an increasingly efficient evaluation process, RecyClass supports the plastic packaging value chain players in anticipating the upcoming legislative requirements,” the spokesperson adds.Prioritizing the compliance backbone, specifically packaging master data, is essential for businesses.

Operationalizing evidence, reducing complexity

Looking ahead, Gass stresses that PPWR will require brands to make tough decisions about end-of-life packaging solutions.

“Brands will have to decide which formats are recyclable at scale, where reuse systems are operationally credible, and where compostables are genuinely justified — not used as a workaround. As standards and grading harden, these choices become measurable and enforceable, not preference-driven.”

“Business could choose to reuse only where you can run a real system, design the rest to pass recyclability grading, and treat compostables as tightly governed exceptions linked to credible collection and treatment pathways. The winners will be the companies that operationalize evidence and reduce complexity,” he says.

For RecyClass, the future of the industry involves more than just compliance. It is about fostering a fully circular packaging ecosystem.

“We will continue to evolve the design for recycling guidelines in parallel with regulatory timelines like the PPWR, expand support for different materials and packaging formats, and integrate further with RecyClass’s broader portfolio of protocols and certifications,” says the spokesperson. 

“We also aim to foster collaboration across the value chain — from material suppliers to brand owners, recyclers, and policymakers — to ensure that innovations are technically robust, environmentally meaningful, and economically viable.”