Packaging sustainability in Europe is moving rapidly from corporate ambition to commercial reality. The Packaging and Packaging Waste Regulation, or PPWR, together with Extended Producer Responsibility schemes, is changing how packaging is designed, evaluated and costed.
For brand owners and packaging manufacturers, this means that packaging weight, material composition, recyclability and recycled content will increasingly affect not only compliance, but also costs, customer requirements and market positioning.
The question is no longer whether packaging will need to change. The question is how companies can adapt while maintaining performance, processability and commercial viability.
Extended Producer Responsibility, or EPR, is based on the principle that companies placing packaged products on the market take financial and organisational responsibility for the packaging once it becomes waste. EPR fees contribute to the costs of collecting, sorting and recycling packaging waste.
PPWR creates a more harmonised regulatory framework for packaging across the European Union. Regulation (EU) 2025/40 entered into force on 11 February 2025 and has applied since 12 August 2026. It covers all packaging and introduces requirements related to recyclability, recycled content, packaging minimisation, reuse, labelling and waste prevention.
In simple terms, PPWR sets the direction for future packaging, while EPR provides an economic mechanism that can make some packaging choices more costly than others. Under the new framework, EPR fees are intended to encourage eco-design and recyclability through fee modulation.
This makes EPR more than a reporting or waste-management issue. It is increasingly becoming a packaging design issue.
For brand owners, packaging decisions can influence regulatory compliance, EPR-related costs, sustainability targets, customer tenders and brand positioning.
For packaging manufacturers and converters, the challenge is to translate changing regulatory and customer expectations into solutions that work under real production conditions. Requests for recyclable structures, mono-material alternatives, lightweighting and post-consumer recycled content are likely to become more common.
However, these requirements cannot be considered in isolation.
Changing a sealant layer, barrier material, adhesive, coating or additive may influence the performance of the entire packaging structure. Depending on the application, packaging must continue to provide effective sealing, mechanical strength, puncture resistance, barrier performance, machinability and product protection.
A packaging redesign that results in more production waste, reduced shelf life or increased product losses cannot be considered a successful solution. The goal should be to improve the complete packaging system rather than optimise one sustainability indicator at the expense of others.
Traditionally, packaging costs have often been evaluated primarily through raw material prices and conversion costs. This calculation is becoming more complex.
PPWR requires packaging to minimise weight and volume while maintaining its functionality. It also introduces recyclability requirements and minimum recycled-content targets for plastic packaging, with specific timelines and exemptions. Recyclability performance grades are expected to become applicable from 2030, while packaging must also be capable of being recycled at scale from 2035.
At the same time, the cost exposure of a packaging format may increasingly depend on factors such as:
The exact financial impact may differ between European markets. EPR structures, fee levels and recycling infrastructure can vary by country. In addition, a number of detailed PPWR implementation measures are still being developed, including recyclability criteria, recycled-content methodology, labelling and harmonised EPR reporting formats.
Nevertheless, the overall direction is clear: packaging choices made today can influence both regulatory exposure and future costs.
It may be tempting to wait until all technical criteria and national fee structures are finalised. However, packaging redesign is rarely a quick process.
A new solution may require material screening, laboratory evaluation, industrial trials, equipment adjustments, shelf-life testing, customer approval and regulatory validation. Starting too late can reduce the number of available options and create pressure to implement changes without sufficient testing.
Another common risk is treating recyclability as a simple material substitution. Replacing one polymer with another does not automatically make the complete package recyclable.
The full packaging system must be considered, including barrier and tie layers, adhesives, coatings, inks, labels, closures and other components. Even a structure described as mono-material may include elements that affect sorting or recycling compatibility.
Early preparation does not necessarily mean replacing existing packaging immediately. It means understanding the current portfolio, identifying the most exposed applications and beginning to evaluate realistic alternatives.
EPR and PPWR create new obligations, but they also provide an opportunity to review packaging portfolios more systematically.
This process can reveal possibilities to:
For example, a higher-performance polymer may allow downgauging while maintaining the required mechanical properties. In another application, carefully redesigning individual layers may improve recyclability without sacrificing sealing performance or product protection.
The lowest-priced material does not always provide the lowest total packaging cost. A material with a higher price per kilogram may create value by enabling lower thickness, reducing scrap, improving line efficiency or preventing packaging failure.
The objective should not be to make packaging more sustainable at any cost. It should be to find solutions that improve circularity while remaining technically and commercially realistic.
A practical starting point is to conduct a structured review of the existing packaging portfolio.
Companies can begin by mapping their packaging formats, materials, structures and weights. High-volume, heavy or complex structures can then be prioritised for further evaluation.
The next step is to assess the complete packaging system rather than only the main material. This includes identifying components that may limit recyclability and evaluating whether the structure can be simplified or downgauged.
Companies can also identify applications where PCR may be technically and legally suitable. This evaluation should consider not only recycled-content targets, but also material consistency, processing behaviour, colour, odour, mechanical performance and product requirements.
Most importantly, alternative solutions should be tested early. Laboratory data is useful for selecting potential materials, but it cannot always predict performance on existing extrusion, printing, laminating, filling and packaging equipment.
Collaboration across the value chain is therefore essential. Brand owners, packaging manufacturers, raw material suppliers, equipment providers and recycling experts need to work together to identify solutions that can be implemented at scale.
Navigating EPR and PPWR requires companies to connect regulatory objectives with material selection, processing conditions and real packaging performance.
Telko’s role goes beyond raw material supply. By combining material expertise, regulatory understanding and access to innovative polymer and additive technologies, Telko can help customers evaluate alternatives and identify practical pathways towards more circular packaging.
This may include supporting lightweighting and downgauging projects, developing more recyclable structures, evaluating PCR options and balancing mechanical, optical, sealing and barrier properties.
In demanding packaging applications, the solution is rarely a direct one-to-one material replacement. Progress often comes from the right combination of materials, structural changes, additives and processing optimisation.
There is no single perfect packaging solution. Success comes from balancing performance, cost, recyclability, recycled content and regulatory requirements.
Companies that start reviewing their packaging portfolios today will have more options, more time for testing and a better opportunity to manage the transition in a controlled and commercially realistic way.
Ivan Bobich is Market Development Director, Base Polymers at Telko. He works with packaging manufacturers and brand owners across Europe to connect regulatory requirements with material selection, processing conditions and real packaging performance. Telko helps customers evaluate alternatives and find practical pathways to more circular packaging.