Sustainability consultancy is facing enormous pressure in the context of the European Regulation on Packaging and Packaging Waste (PPWR / EU Regulation 2025/40). As the regulation has recently come into force and the first major obligations apply directly from 12 August 2026, the consultancy market has instantly shifted from theoretical guidance to crisis management and strict legal compliance. And that is not all. The role of sustainability consultancy is not to put out the fires caused by the new regulations, but to ignite the spark of a profound and competitive transformation of the entire business model. For companies that use packaging, it is important to view this period not as a crisis, but as an opportunity – namely, for the current period to be a key time for redesign.
We therefore offer you a fresh perspective on the PPWR approach, enabling you to identify the change that delivers a genuine competitive advantage and will position you amongst the market leaders.
European packaging is entering a new phase. Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR – Packaging and Packaging Waste Regulation, applies across the European Union and fundamentally changes the way in which packaging must be designed, developed and placed on the market.
This change is important not only for packaging manufacturers, but for the entire value chain. Brands, retailers, manufacturers, designers and material suppliers are all faced with the same question: how should packaging be rethought to meet the demands of an economy that aims to consume fewer resources and keep materials in circulation for as long as possible?
PPWR is not, in essence, just about recycling. It is about how packaging is designed right from the outset. Size, material quantity, material combinations, recyclability, recycled content, reuse, and even the information provided to the consumer all become part of the same design process.
This marks a significant shift in perspective. Until now, packaging redesign was driven mainly by visual identity, brand positioning, costs, or production efficiency; today, these criteria must be considered alongside another factor, the so-called packaging’s circularity.
The Path from sustainable packaging to design for circularity
In recent years, the term ‘sustainable’ has become ubiquitous in the packaging industry. Lighter packaging, paper packaging, or packaging made from recycled material is often presented as a sustainable solution. However, genuine sustainability is not merely a technical tick-box exercise or an isolated material characteristic. It represents a systemic approach: packaging is only truly sustainable when its environmental impact is minimized throughout its entire life cycle — from the way resources are extracted, through distribution logistics, to the assurance that the packaging will be collected, sorted and effectively recycled, re-entering the economy without leaving any waste behind.
However, the PPWR requires the industry to go beyond this simplified approach.
A material does not automatically become a good solution simply because it is recyclable under certain conditions. What matters is what is actually happening to the packaging. Here, it is important to determine whether it can be collected, sorted, recycled, and whether the resulting material can serve a practical purpose. The Regulation introduces this perspective on recyclability precisely, linking the design of the packaging to its ability to actually enter a recycling system.
Therefore, the redesign must begin with a question that goes deeper than a simple question such as…what material should we use for the new packaging?. The right question would be… How can we design this packaging so that it fulfills its function whilst using resources as efficiently as possible and can be reused or recycled? This is the difference between a simple redesign project and the design project for circularity.
Now let’s look at the thinking behind the packaging strategy, which a company should adopt.
The first step: to use less packaging
It may seem paradoxical, but when looking at the product, one of the most important aspects of the PPWR is to return to a very simple question….. is everything contained in the current packaging really necessary?
Before switching from plastic to paper, introducing a recycled material, or looking for an alternative coating, it is worth considering whether certain components can be removed, whether the size can be reduced, or whether the packaging structure can be simplified.
Packaging that uses 20% less material should not automatically be viewed as less performant… on the contrary, if it maintains its protective function and consumer experience, material reduction can be one of the most effective forms of optimization.
This reasoning becomes even more relevant in the context of e-commerce, where empty space and oversized packaging can lead to both additional material consumption and logistical inefficiencies.
From a PPWR perspective, redesign therefore begins not with choosing a new material, but with a critical analysis of the existing packaging.
“There is no such thing as ‘away’. When we throw anything away, it must go somewhere.”
— Annie Leonard, environmental advocate and creator of The Story of Stuff
Recyclability must be taken into account right from the design stage
One of the major changes introduced by the PPWR is that recyclability can no longer be treated as a feature added at the end of the process. The regulation stipulates that packaging placed on the market must be recyclable, and from 2030 the design requirements for recycling will become an essential criterion. From 2035, an assessment of recycling capacity at scale will also come into play, and from 2038 the criteria will become even stricter.
For the designer, this change is essential.
A piece of packaging may look impeccable, have an efficient design and be made from a material that, in theory, is recyclable. But if its components are difficult to separate, if certain combinations of materials interfere with the sorting process, or if the resulting material cannot be properly recycled, the problem is no longer one of communication, but one of design.
This means that the choice of adhesive, label, ink, varnish or any additional component can no longer be made entirely independently of the path the packaging will take after consumption.
In this new context, designers must consider packaging not only from the shop shelf to the consumer, but also from the consumer to the collection and recycling system.
Single-material design is not an end in itself
In this context, there is increasing talk of single-material packaging. This is an important development, but it must be properly understood. A package made from a single material does not automatically mean it is the best solution. Packaging function must remain the priority. The product must be protected, the use-by date must be maintained, and the packaging must withstand the processes of production, transport, and use.
That is why the real challenge lies in striking a balance between performance and circularity.
In some cases, simplifying the structure may be the ideal solution. In others, the product’s requirements may justify a complex structure. What is important is that this complexity is assessed and justified, rather than simply perpetuated because ….that is how it has always been done.
PPWR is changing precisely this mindset.
Recycled material becomes part of the design strategy
For plastic packaging, another major change is the introduction of minimum requirements for post-consumer recycled content. From 2030, the PPWR sets minimum levels of recycled content by packaging category. For certain categories, the requirements start at 10 percent, 30 percent or 35 percent, and higher levels are envisaged for 2040, which may reach up to 65 percent for certain types of packaging. This change will directly affect the redesign process.
Recycled material does not always behave exactly like virgin material. Differences may include color, transparency, mechanical properties, processability, or appearance. For food-contact packaging, the issues become even more sensitive.
That is why the redesign must be carried out in collaboration with materials manufacturers and packaging suppliers. It is not enough simply to draw up a new design and assume that the desired material will perform in exactly the same way in production.
In practice, this means that the designer must gain an ever-deeper understanding of the material, and the packaging engineer must be involved right from the conceptual stage.
Reuse changes the relationship with the life cycle
Another important aspect of PPWR is reuse. Until now, many packaging projects have assumed packaging is used only once and then becomes waste. In a reuse system, this logic changes completely. The packaging must be robust enough to withstand repeated use, whilst remaining practical, attractive and logistically efficient. It must be possible to empty, transport, refill or reload it and, depending on the system, track it throughout several cycles of use.
The PPWR links reuse to the existence of actual reuse systems and introduces specific requirements for reusable packaging. Furthermore, the regulation stipulates that reusable packaging must also meet applicable recyclability requirements when it reaches the end of its life cycle. Reuse is therefore not the opposite of recycling. Packaging that is well designed for reuse must ultimately be able to enter a recycling stream.
This approach introduces a new dimension to design: packaging is no longer designed for a single moment of use, but for its entire life cycle.
The chemistry of packaging is becoming just as important as its form
Another aspect relevant to the redesign concerns the substances used in packaging materials and components. The PPWR introduces, amongst other things, strict restrictions on the use of PFAS — a family of synthetic chemicals known as ‘forever chemicals’ due to their resistance to degradation — prohibiting their use as water- and grease-repellent coatings in packaging intended to come into contact with food.
This clearly shows that redesign can no longer be merely a visual or structural issue. Packaging may look perfect, but it may require changes to the coating, adhesive or other surface treatment. For this reason, developing new packaging must increasingly involve the packaging, quality, procurement, and regulatory departments.
In other words, packaging design is becoming an interdisciplinary field.
What changes does this bring to the label?
The PPWR will also change how packaging is labeled and the information provided to consumers. The Regulation provides for a harmonized label detailing the composition of the material, to apply from 12 August 2028 or later, depending on when the relevant acts are adopted and implemented. The requirements also set out information for reusable packaging, including the option to use a QR code or another standardized digital medium. This development is also significant from a graphic design perspective.
The space available on the packaging must accommodate not only the brand identity and mandatory product information, but also information about the packaging itself. The graphic design must therefore be flexible enough to incorporate these elements without compromising legibility and visual identity. This is another reason the redesign should not be carried out piecemeal.
What does a PPWR-ready redesign actually mean?
A successful redesign project avoids the premature question, “What will the new packaging look like?” and instead anchors itself in a thorough analysis of the existing format. At the risk of sounding repetitive, it is worth emphasizing why this groundwork matters.
It is important to understand why it has its current form, what function each component serves, and where there are genuine opportunities for simplification. Sometimes the result will be smaller packaging. At other times, it will involve a change of material. In some situations, the solution may be a single-material design, whilst in others it may be a switch to a reusable model.
The solution must be based on function and the packaging’s entire life cycle, not a passing trend. A meaningful redesign for PPWR must address several key questions simultaneously: how much material is actually needed?; whether the structure can be simplified?; what happens to the packaging after use?; whether the materials can be recovered?; and whether the new solution can be produced and scaled up without problems?.
This is where one of the greatest opportunities for companies arises: PPWR can transform redesign from a one-off project into an ongoing process of optimizing the packaging portfolio.
Why is it important to start now?
The fact that the PPWR is already in force does not mean that all its requirements become mandatory on the same day. The Regulation has a phased timetable, and many requirements will come into force in 2030, 2035 or 2040. At the same time, in June 2026, the European Commission published a guidance document designed to clarify the interpretation of certain provisions and to support companies and authorities in implementing the regulation. This phased approach makes the current period an important one for redesign.
Changing packaging doesn’t happen overnight. It requires testing, prototyping, validation, approvals, mould modifications, adjustments to production lines, and sometimes finding completely new suppliers.
If the redesign starts only when a requirement becomes urgent, the company risks embarking on a process under time and cost pressure. If, however, it is started in good time, PPWR can become a tool for planning and innovation.
PPWR is not just an obligation. It is a paradigm shift.
The PPWR should not be viewed solely as a new set of rules that the industry must comply with. It changes the way we define good packaging and paves the way for innovation and real economic opportunities. High-performance packaging is no longer simply packaging that protects the product, looks good, and can be produced at a competitive cost. By shifting the focus toward resource efficiency, recyclability, and a clear post-consumer lifecycle, the role of a redesign evolves from a simple cosmetic makeover into a fundamental evaluation of whether the current packaging is still justified, how its materials perform, what components can be eliminated, and how it can successfully function within a circular system.
In this regard, the PPWR can be seen not merely as a legislative constraint, but as a catalyst for innovation. Companies that view this change solely as a compliance issue will attempt to modify their existing packaging just enough to meet the new requirements. Companies that view PPWR as an opportunity for redesign will have the chance to do something even more valuable: to rethink packaging from the ground up.
And the question that should underpin this process is not…..How do we make packaging compliant with the PPWR, but one that is far more relevant for the future…… How do we design packaging that performs well today and is relevant to tomorrow’s circular economy?
PLEASE CONTACT US if you decide to undertake an innovative packaging redesign. We can help you.
