1 EU product baseline · 5 national implementation perspectives · 4 business ledgers

01 · COMMON GROUND

The EU sets the baseline, but Member States still operate their own packaging systems

PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026. These two dates must not be conflated. General application does not mean that labelling, recyclability grades, recycled-plastic content, packaging minimisation, reuse targets and restrictions on single-use packaging all become due on the same day.

From that date, PFAS limits apply to food-contact packaging. The first limit is25 ppb.The limit for the sum of targeted PFAS is250 ppb.The limit for total PFAS is50 ppm.This three-threshold framework applies to food-contact packaging.

Also from 12 August, Article 6(1)—“all packaging placed on the market shall be recyclable”—begins to apply. However, harmonised design-for-recycling criteria and assessment methods still depend on subsequent delegated acts and will apply from 1 January 2030 or 24 months after those acts enter into force, whichever is later.Recyclability is now a legal principle, while the harmonised scoring framework is still being developed.

Europe is not starting from a perfect position. PPWR harmonises the product baseline for packaging while leaving national authorities, producer registration, EPR, collection systems, deposit return, reuse promotion and enforcement to Member States. The practical reality is therefore neither “27 product standards” nor “one EU certificate that clears all 27 countries”, but:one EU product platform combined with multiple national operating accounts.

Legislation and sources:Regulation (EU) 2025/40; European Commission PPWR implementation guidelines C/2026/3084; Eurostat 2023 packaging-waste data

02

DE / GERMANY · RESPONSIBILITY

Germany: put responsible parties on a public register first

Its first question: who is responsible?

Germany’s core action is not to dismantle the existing system, but to clarify roles on the established foundations of LUCID packaging registration, system participation and volume reporting. ZSVR states that PPWR and Germany’s new Packaging Law Implementation Act operate together from 12 August 2026 and replace the former Packaging Act. Existing basic registration and EPR obligations remain, while the responsible party changes in some own-brand, import and service-packaging scenarios.

Two roles are most easily confused:the manufacturer bears product-compliance responsibility for the complete packaging, while the producer bears the national EPR responsibility once that packaging becomes waste.The same company may hold both roles, or the roles may need to be assessed separately depending on the brand, commissioned design and route by which the packaging is first placed on the market.

For service packaging such as paper cups and food containers, “we are only the contract manufacturer” is no longer a sufficient answer. The relevant questions are who determines the structure, who influences materials and design, and who places the packaging on the market under its own name. From 12 August, a non-EU business with no German establishment that sells directly to end users in Germany must also appoint an authorised EPR representative; however, the producer must still complete its own LUCID registration.

03

FR / FRANCE · REUSE

France: bring reuse into restaurants—and put the shortfall on the table

Its first question: how can single use be reduced?

Since 1 January 2023, dine-in food-service establishments able to serve at least 20 customers at the same time have been required to use reusable cups, lids, plates, containers and cutlery. France has also set national packaging-reuse targets of 5% for 2023 and 10% for 2027.

Moving from 1.82% to 10% is not achieved simply by replacing a single-use cup with a heavier cup. It requires simultaneous improvements in container standardisation, in-store take-back, washing capacity, transport radius, loss control and the actual number of reuse cycles.

The latest adjustment to France’s EPR scheme for professional packaging illustrates the same logic. The new scheme, originally scheduled to operate from 1 July 2026, was officially deferred to 1 January 2027 because the identification of responsible parties and the fee structure were not ready. This is neither a delay to PPWR nor a suspension of all French EPR. It is a specific national scheme completing its interfaces before formal charging begins.

04

ES / SPAIN · DATA

Spain: write the regulation’s dates into annual reporting

Its first question: who reports how much, and for which dates?

Producers in Spain must enter the national Product Producers Register (RPP) and report the volume of packaging first placed on the Spanish market in each calendar year. Because PPWR changes the status of some “producers” from 12 August, the authorities do not simply require every company to report the full year. Instead, they divide 2026 into three cases according to changes in the responsible party.

The reporting window runs from 2 January to 31 March 2027. Companies therefore cannot ask only, “How much packaging did we sell in 2026?” They must also ask:For each batch of packaging, who was the producer under the rules in force when it was first placed on the market?

Spain also brings e-commerce platforms into advance verification. Before allowing a producer to use a marketplace, the platform must verify RPP registration information and the declaration of EPR compliance, and it may consult the government’s public list of producers. The list dated 31 July 2026 is already online; an automated query interface is still under development.

05

AT / AUSTRIA · RETURN

Austria: €0.25 to bring bottles and cans back

Its first question: how can packaging actually be returned?

Since 1 January 2025, plastic beverage bottles and metal beverage cans from 0.1 to 3 litres within the scope of the scheme have been subject to a one-way packaging deposit of €0.25 per item. Consumers recover the deposit only when they return an empty container bearing the Austrian deposit mark to a reverse-vending machine or return point.

A €0.25 deposit may be small, but it simultaneously gives consumers a reason to retain the container, enables identification, encourages return, improves material purity and creates a stable feedstock stream.

Austria also assesses “whether it came back” separately from “whether it is easy to recycle”. In March 2026, the system operator reported an average recyclability rate of 99.5%, calculated by weight of recyclable components for packaging covered by the scheme, and an average recycled-plastic content of more than 60% in one-way plastic bottles placed on the market. Both figures are operator disclosures based on registration and assessment data and should not be extrapolated to all packaging in Austria.

06

DK / DENMARK · COST

Denmark: translate packaging design into a cost per kilogram

Its first question: what will this packaging ultimately cost?

From 1 January 2025, all packaging-material categories were brought within the producer-responsibility registration scope after categories such as ceramics, cork, porcelain and textiles were added. The practical start date for extended packaging EPR was 1 October 2025. New entrants must in principle register nationally no later than 14 days before placing packaging on the market and subsequently report volumes annually.

In the past, removing 1 g of material meant calculating mainly the savings in purchasing and transport. Companies must now continue asking: what material category does that 1 g belong to? How many kilograms are placed on the market annually? Which grade applies under the eco-modulation criteria? What registration, collection and treatment costs will result?

Packaging is therefore no longer merely a purchasing cost. It is an operating responsibility that design, supply-chain, finance and environmental teams must calculate together. The measure of success is not only whether the “material is greener”, but whether material classification, weight data, fee grades, collective-scheme invoices and actual waste costs form a closed loop.

07 · FIVE OPERATING MACHINES

Five countries, not five separate stories, but one operating chain

The five systems are not legal categories under EU law, but the comparative framework used in this article. Together they perform five basic functions: identify the responsible party, calculate packaging volumes, attach costs to responsibility, build collection or reuse infrastructure, and use data to demonstrate outcomes.

PPWR harmonises the baseline for packaging entering the market. Member States operate the national systems through which packaging is registered, measured, charged and taken back.

08 · BUSINESS RESPONSE

For Chinese companies: move from one test report to four auditable ledgers

Material composition, food-contact testing, heavy-metal reports, physical performance and evidence of recycling or compostability within a defined scope remain important, but they do not cover all product rules and national operating obligations. A more robust approach is to maintain one EU master technical file and four auditable ledgers for each destination country.

09 · PAPER PACKAGING

The opportunity for paper packaging is not that “paper automatically replaces plastic”

Paper-based, water-based, bio-based, biodegradable, compostable, repulpable, recyclable, food-contact safe and PPWR-compliant are distinct evidence pathways. None can be inferred automatically from a material name.

The real opportunity is to reduce unnecessary material and hard-to-separate structures while meeting barrier, sealing, mechanical-strength, food-contact and shelf-life requirements—and to ensure that the final packaging is recognised by the collection, sorting and recycling systems of the target market. Water-based barriers or bio-based functional systems containing PHA may enable downgauging, functional integration or material substitution in specific structures, but their value must be demonstrated step by step fromspecific formulation—coating—coated paper—final packagingmust be demonstrated at each stage.

The opportunity belongs to companies that can do three things at once: deliver the required function, provide the data, and return the packaging to the system.

CONCLUSION

PPWR is not a certificate; it is a European operating system

What is already in place is the common EU product baseline. What is now taking effect is the national implementation capacity represented by Germany’s public responsibility register, France’s reuse infrastructure, Spain’s date-based reporting, Austria’s deposit return and Denmark’s fee modulation. Still to be delivered are phased outcomes such as harmonised labelling, full recyclability assessment, reuse at scale, collection rates, data quality and subsequent enforcement.

The most positive and profound aspect of this change is that packaging competition is moving from “what is the material called?” to “can the system handle it?”. Packaging that can enter the European market reliably in future must be:identifiable, measurable, accountable, recyclable and verifiable.

Companies do not need an unrelated product design for each of the 27 Member States, but they do need one EU master technical file connected to each destination country’s responsibility, registration, fee and recycling interfaces. Those that first turn these interfaces into repeatable organisational capabilities are more likely to convert compliance cost into customer trust and long-term order capability.

BIOTEN Packaging will continue to examine the real interfaces between paper, functional materials, packaging design and Europe’s collection, reuse and recycling systems. Our criteria remain unchanged: has progress actually occurred, how is industrial value created, and which data and operating indicators demonstrate it?