It entered into force in January 2025 Packaging and Packaging Waste Regulation (PPWR), which forms the legislative „backbone“ of the transition to a circular economy in the EU. However, for successful implementation it is critical to distinguish between the legislative „"WHAT"“ (political objectives and minimum requirements) and technical „"HOW"“ (European harmonised standards). While the regulation sets the direction, standards create an „invisible infrastructure“ that allows systems to operate across borders without market fragmentation.

From political goals to technical reality

„The PPWR provides the legal backbone, but the standards are the practical toolkit and invisible infrastructure that will make reuse systems actually work in practice.“ — Iara Beekma, Head of Business Development, New European Reuse Alliance (NewEra)

The transition to a new reality is not just a matter of goodwill, but a precisely planned process of transforming technical rules, for which companies have an unprecedentedly short time.

Chronological transformation plan (2025 – 2030)

The path to 2030 is defined by strict deadlines. It is essential to draw attention to critical time pressure: only 2027-2030 remain for the revision of the standards three-year window, which is shorter than the standard four-year process. Any inaction during this period poses a high risk of strategic delay.

• January 2025: Entry into force of the PPWR. Launch of the harmonisation of rules for the packaging sector.
• February 2027: Key legislative and technical node.
  • The European Commission will adopt SReq (Standardisation Request) – an official assignment to standardisation bodies (CEN) to revise standards for packaging minimisation.
  • Adoption of a delegated act on the minimum number of rotations (cycles) for reusable packaging.
  • Obligation for the HORECA sector: Businesses must start offering the option of refilling (refill) for drinks and takeaway food.
• February 2028: The HORECA sector is also required to offer reuse options (reuse) for self-relationship.
• January 2030: A sharp start to the obligations. All packaging on the EU market must have a minimized weight and volume. A ban on excess packaging and targets for reuse come into force.

These milestones are contingent on the successful revision of outdated standards that are currently hindering innovation.

Three Pillars of Standardization: Revising Outdated Rules

The current technical standards (EN 13428 and EN 13429) date back to 2004. They are outdated, do not take into account modern materials or digital tracking systems. Their complete revision is essential for business stability and the prevention of greenwashing.

HORECA sector and replenishment systems: End of fragmentation

For the hotel, restaurant and café sector, the PPWR brings uniform definitions that are key to fair competition. It will no longer be possible to confuse „refill“ with „reuse“, which has previously caused confusion for consumers and regulators.

• Refill: The customer uses their own container. Examples of successful implementations are systems such as CopoMais in Lisbon.
• Reuse: A professionally managed system where the packaging (e.g. stainless steel box) circulates in a closed cycle.

Milestone: February 2027 From this date, HORECA establishments are required to allow customers to purchase food and beverages in their own containers (refill).

These systems are inspired by international standards PR3 (Global Alliance to Advance Reuse), which provide proven frameworks for system interoperability, preventing the emergence of isolated "island" solutions that are not economically sustainable.

Chemical Safety: An Essential Design Factor

Increasing the number of packaging rotations brings new risks. The more often the packaging is washed and the longer it is in contact with food, the higher the risk of migration of hazardous substances. According to scientific findings, we know about 2,160 chemicals, which have been shown to migrate from packaging, and about another almost 100,000 unintentionally added substances (NIAS).

„Chemical safety must be part of reuse and refilling standards from the start.“ — Justin Boucher, Operations Director, Food Packaging Forum

Factors increasing the risk of migration:

• High temperature (hot drinks and food).
• Fatty foods (fats bind chemicals).
• Small portions (larger surface area of contact of the packaging with a small volume of food).
• Long contact time.

TOP 5 principles for safer design:

1. Priority of inert materials: Prefer stainless steel, glass or glazed ceramics to complex plastics.
2. Simplifying the composition: Fewer ingredients mean a lower risk of developing NIAS.
3. Elimination of known pollutants: Removal of toxic substances already at the design-out stage.
4. Testing the final product: Test the toxicity of the entire packaging, not just the raw materials.
5. Adaptability: Standards must reflect the latest health knowledge (e.g. endocrine disruption).

Summary for practice: How to prepare for 2030

A successful transformation requires immediate action. Europe currently lacks sufficient, comprehensive data on real-world packaging rotation, so engaging companies in testing is critical.

• [ ] Follow the revision of EN standards: Actively monitor changes to outdated 2004 standards through national standards bodies (NSBs).
• [ ] Accelerate data collection from pilot projects: Implement smaller systems (following the CopoMais model) and collect accurate data on the real number of cycles and wear.
• [ ] Portfolio audit to minimize: Analyze current packaging in terms of wall thickness and void space in accordance with the future SReq.
• [ ] Integrate chemical safety: Reassess the selection of materials in gastro operations with an emphasis on risk factors (heat, fats).

Clear and harmonised rules will bring stability to the business environment and real protection of health and nature. The involvement of civil society and industry in standard-setting over the next three years will determine whether 2030 is a success or a missed opportunity. JRi&CO2AI 

Source: Decoding EU Packaging Regulations – Best Practices for Packaging Standards