Understanding the PPWR and the Regulatory Landscape with a Sustainability Regulatory Expert

In this interview, Markus Müller, Sustainability Regulatory Expert at MM, answers some of the most common questions about PPWR, sharing practical insights to help organisations prepare their packaging portfolios and assess the role of recycled content within their packaging strategies.

Interview with Markus Müller, Sustainability Regulatory Expert

EU Harmonisation

Do we expect a lot of national variation between different EU countries when it comes to implementation? For example, are there countries that would seek to ban single-use plastic packaging for fruits below 1.5 kg?

Since the PPWR is a regulation, it will be applicable in a harmonised fashion across the European Union. This means that we can expect a consistent legislative landscape, including for applications such as single-use plastic packaging defined in Annex V.

However, some nuance is important. The Commission will issue guidelines to clarify Annex V in more detail, including examples of packaging formats in scope and exemptions, for example, for certain fresh fruit and vegetables. In addition, where packaging is not covered by Annex V but still falls under the Single-Use Plastics Directive, national measures may continue to play a role.

Key Challenges for MM

What will be the biggest challenge for MM in terms of compliance with the bans in Annex V?

For MM Packaging, it will be essential to fully understand the impact across all affected product types. At the same time, we need to ensure compliance with recycled content targets, sustainability goals, and design-for-recycling criteria. This also means reviewing our raw material sourcing and evaluating potential substitutions where needed.

For MM Packaging, the key challenge will be to translate the Annex V requirements into practical product and customer guidance.

For paper-based composite packaging, the plastic share will become an important design parameter. The Commission guidance provides further clarity on the 5% threshold, which helps the industry assess which applications may be affected by Annex V and where fibre-based solutions can be designed in a compliant and functional way.

Timeline for Bans

Single-use PET multipacks will be banned by when?

The provisions outlined in Annex V for single-use plastic applications will take effect starting from 2030.

Global Impact

Will European requirements also impact your global offer? Will your global product portfolio reflect European requirements?

PPWR is primarily focused on the EU internal market, so its immediate impact will be strongest in Europe. However, aspects such as recyclability scoring, reuse, and waste prevention are likely to gain importance globally. At MM, we are prepared to align our offerings to meet requirements across all relevant markets.

EPR Fees

When will the amount of the Extended Producer Responsibility fee be defined, and how significant could the impact be?

EPR fees will continue to be set within national EPR systems, so the exact amounts will not be fixed centrally at EU level.

What PPWR does is harmonise certain administrative EPR obligations, such as registration, reporting deadlines and data granularity. It also harmonises the framework for eco-modulation based on recyclability performance grades. The first reporting under the new harmonised register rules is expected to be established by 2028.

The financial impact may be significant, depending on the packaging material, weight, recyclability grade and any additional national criteria such as recycled content or reusability. For MM, the key is to design packaging that performs well under future recyclability and EPR eco-modulation criteria.

Harmonisation of EPR Fees

Will these EPR fees be harmonised across Europe?

Not fully. PPWR harmonises important elements, especially producer registration, reporting obligations, the definition of who the “producer” is, and the criteria for EPR eco-modulation.

However, Member States will still have flexibility to organise their national EPR systems and waste management structures. Therefore, the calculation logic will become more harmonised, but actual fee levels are still expected to differ between Member States.

Recyclability Score

Regarding the recyclability score as part of Design for Recycling—who determines the final score? Will there be differences between EU countries?

The Design for Recycling criteria will be defined by the European Commission, with adoption expected by 2028, followed by a transition period for compliance. The process involves expert committees from Member States and consultation with industry stakeholders. Both the Commission and the European Parliament must approve the delegated act, ensuring alignment across the EU.

The objective is to create a harmonised EU framework. The final recyclability performance grade will therefore be based on EU-level criteria, not on separate national scoring systems.

The transition towards the PPWR framework is expected to reshape how organisations approach packaging design, compliance and long-term planning. While several implementing measures are still to come, understanding the regulatory direction today can help businesses assess potential impacts and prepare their packaging portfolios for future requirements. As Markus Müller highlights, early preparation, collaboration and a clear understanding of evolving sustainability regulations can help organisations navigate change with greater confidence.