For packaging professionals, one of the most important points is that 12th August should not be viewed as the moment when every PPWR requirement arrived at once. As Rory explained, the regulation will continue to develop over a long time-frame, with requirements rolling out through to 2040.
That makes PPWR less of a single compliance deadline and more of an ongoing process. Implementing and delegated acts, European Commission guidance and FAQs are continuing to add detail to what businesses need to do and how individual requirements should be interpreted.
What changed on 12th August?
The 12th August milestone established important foundations for what follows. For manufacturers in particular, this includes the systems and documentation needed to demonstrate packaging compliance and traceability.
Rory highlighted Article 5 on substances of concern, including relevant heavy metal limits and PFAS limits for food-contact packaging. Emili and Ellie also pointed to other areas businesses need to consider, including manufacturer information, reusable packaging requirements under Article 11 and environmental claims under Article 14 where these provisions apply.
Manufacturer details are another practical consideration. The discussion highlighted requirements around the full manufacturer address, an electronic means of contact and a unique identifier on packaging units.
The immediate lesson for packaging teams is therefore to understand not only which PPWR provisions apply to their organisation, but also who internally owns the information, documentation and implementation needed to address them.
That responsibility may cut across several functions. Emili gave the example of the conformity assessment procedure potentially being managed by office-based colleagues responsible for gathering the necessary information and preparing declarations, while labelling requirements may involve teams working more directly with packaging and warehouse operations.
Compliance is becoming a cross-functional packaging issue
Businesses are not all starting from the same point. Emili explained that some companies have made considerable progress with conformity assessment procedures and the requirements associated with 12 August, while others are finding it difficult to keep pace with regulatory updates and determine how to approach compliance assessments.
A further challenge is that clarity is still developing in some areas. Rory pointed to substances of concern as an example where companies may not have harmonised standards setting out precisely what is required for compliance.
In those circumstances, compliance can become a question of risk management. Businesses need to determine what evidence is sufficient, understand areas of uncertainty and establish an internal approach to managing that risk.
Ellie highlighted the importance of those internal conversations. PPWR can involve different departments and entities within the same organisation, making it important to establish what is required, where responsibilities sit and how the business intends to approach compliance.
The regulation also broadens the conversation beyond a traditionally producer-focused approach. As Rory explained, different roles across the supply chain now have responsibilities relating to areas including packaging sustainability and traceability.
For packaging professionals, this means PPWR cannot simply sit with one compliance specialist. Decisions around pack design, specifications, labelling, documentation, substances, reuse and future recyclability requirements can have implications for multiple teams.
Preparing packaging innovation for what comes next
For innovation teams, the challenge is not simply responding to requirements already in force. Packaging development also needs to take account of what is coming next.
By the October course, Rory said there will be more to discuss than was available when ThePackHub ran its previous PPWR course in April. This includes greater clarity around specific compliance requirements, PFAS testing guidance, new labelling requirements and finer details of obligations that have been addressed through European Commission guidance and FAQs.
The course will also look ahead at further implementing and delegated acts. The discussion highlighted forthcoming information on PFAS testing expected from the European Commission on 31st December, while Rory said the October timing will allow the course to address additional clarity around recyclability gradings.
This is where ThePackHub’s innovation perspective becomes particularly relevant. Katie Roselaar, our Innovation Director, will explore how regulatory change intersects with packaging innovation, supported by examples of packaging developments in the course and accompanying workbook.
For innovation teams, the question is how to develop packaging while anticipating a regulatory framework that is still being built out. A technically promising pack may need to be considered not only in terms of performance and consumer experience, but also against evolving requirements around labelling, substances, documentation, traceability, reuse and recyclability.
Turning PPWR requirements into practical action
ThePackHub’s updated PPWR training course is designed for businesses at different stages of preparation, from teams still developing their understanding of the regulation to those already working through detailed compliance questions.
The online session takes place on Thursday 8th October from 2:00 – 5:00 p.m. UK time, with Valpak’s PPWR experts Rory Baird, Emili Ladwa, Ellie Stone and ThePackHub Innovation Director Katie Roselaar.
Rather than focusing solely on explaining the legislation, the course will examine how requirements translate into practical responsibilities within businesses. Topics discussed ahead of the course include conformity assessment, traceability, labelling, substances of concern and PFAS, reusable packaging, environmental claims, risk management and forthcoming PPWR developments.
It will also bring packaging innovation into the discussion, examining how changing regulatory requirements could influence packaging development and using examples to help teams connect the legislation with real packaging decisions.
As Rory put it, the scale of PPWR can initially feel overwhelming, but breaking the regulation down into individual requirements makes the task more manageable. With the regulatory picture continuing to develop, the October course is intended to help packaging businesses understand what applies now, identify what they need to prepare for next and turn PPWR requirements into actions relevant to their own roles.
