Lorax EPI

The impact of PPWR on packaging portfolios
by Annis Mapleston at 11:05 in Emerging, Environmental, Packaging

​I joined Lorax EPI as a consultant in early 2020, from a role as a Policy and Strategy Manager in the university sector. Over the past six years, I've had the opportunity to work with a great range of clients - from small cosmetics brands to massive multinational FCMG companies. My greatest (professional) satisfaction comes from helping people really understand what impact policy and legislation will have on them, and develop concrete plans for how to respond to it. Moving conversations from 'I know I need to do something, but I don't know what it is' to the light-bulb moment of 'Oh, I get it now! This is what I have to focus on' is incredibly rewarding.

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2025 has given me many opportunities to support this type of thinking. In January, the much anticipated Packaging and Packaging Waste Regulation (PPWR) was published, which will introduce significant changes and new responsibilities for anyone selling into the EU. However, whilst the broad principles and timelines are now established, a lot of questions remain to be clarified through implementing regulations - with many not expected to be released more than 18-24 months before the related requirements come into force.


Unsurprisingly, this has led to a lot of questions throughout the year about what producers need to plan for, and how they can do so without all the details they need. Our suggested approach varies depending on a number of factors, including understanding of the legislation and available data. For me though, the most interesting approach was one we took with a multinational corporation selling multiple brands and product categories across a range of EU member states.


The project began with a presentation to a range of stakeholders (including senior management, packaging design engineers, finance, marketing and regulatory team members), some of whom were well aware of the EU legislative landscape and others who were not. We covered all of the key topics from the PPWR, as well as touching on other EU regulations such as the EUDR, the proposed Green Claims Directive and the Ecodesign for Sustainable Products Regulation. This presentation aimed to raise awareness of the high level requirements and potential issues that they might raise for the company.


The next phase of the project was a deep-dive into the company's packaging portfolio. We identified 50 packaging formats that were representative of their broader product base, and 8 evaluation criteria (such as empty space and PCR content). Based on a sample SKU for each packaging format, we used the relevant Bill of Materials and artwork to identify areas that had the potential to result in market restrictions if not addressed. This allowed us to then classify the company's products into three groups: those which were not likely to face any restrictions based on current design, those which needed only minor changes (e.g. labelling tweaks or greater PCR quantity), and those which were at risk of being banned from the market without substantial redesign. As a result of this project, the company is now aware of which products/brands need significant investment and is able to plan accordingly - even where this means having to wait for additional guidance from implementing regulations.


If you need support in understanding the PPWR and its potential impact on your business, it's not too late. Please contact us to see how we can help.

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