IN Brief:
- Only 7% of companies in the survey said they felt confident about the specific requirements of PPWR.
- Around two-thirds are already planning or implementing measures, with declarations of conformity creating a substantial documentation burden.
- Packaging reduction, recyclable formats, plastic substitution, and fibre-based materials are among the responses already under consideration.
Only seven per cent of companies questioned in a survey involving BAUM e.V. say they feel confident about the detailed requirements of the EU Packaging and Packaging Waste Regulation, even though implementation work is already under way across much of the respondent group.
Around two-thirds of participants are planning specific measures or have begun putting them into practice. The findings point to a widening gap between understanding the broad direction of PPWR and having the technical information, internal responsibilities, and documentation needed to demonstrate compliance for individual packs.
The survey was conducted on behalf of Forum Ökologisch Verpacken and is explicitly non-representative, so its 7% figure cannot be treated as a statistical measure of European industry as a whole. It nevertheless captures a practical problem appearing inside companies that are already sufficiently engaged with the legislation to be redesigning packs and gathering conformity information.
PPWR began applying across the European Union on 12 August, moving the regulation from a future planning issue into an operating requirement. Its framework covers packaging reduction, recyclability, reuse, material composition, producer responsibilities, labelling, and supporting technical evidence, with different requirements coming into force over a phased timetable.
Declarations of conformity are emerging as one of the harder parts of implementation. Packaging manufacturers and other affected operators have to assemble evidence covering relevant properties of a pack, potentially including recyclability, compostability, labelling, material composition, and other technical requirements.
In food production, that evidence can span a surprisingly long specification chain. A primary pack may contain a base film or board, coatings, inks, adhesives, labels, closures, seals, and barrier structures produced by several suppliers before the food company fills or otherwise modifies the finished packaging.
Responsibility consequently crosses procurement, technical, quality, packaging development, sustainability, legal, and production functions. A conformity document filed by purchasing is of limited use if it cannot be tied to the material code running on the line, while a technically recyclable structure still creates compliance risk if its supplier evidence or change-control records are incomplete.
The survey reflects that administrative load. Respondents cited bureaucracy, legal uncertainty, the need for external consultancy, and difficulty assembling data for declarations among the main problems surrounding implementation. Broad support for the circular-economy objectives has not removed uncertainty about how the paperwork should be completed in practice.
IFS has already framed PPWR preparation as an auditable process, connecting supplier information with internal responsibilities and the packaging actually released into production. The survey suggests that this connection remains one of the less mature areas of compliance despite years of discussion around packaging sustainability.
Companies are not starting from nothing. Material reduction, switching towards recyclable structures, and replacing plastics were among the measures already being implemented, while fibre-based packaging such as paper, board, and corrugated formats featured prominently in future plans.
Substitution creates its own engineering workload. Replacing a plastic structure with paper or board can alter moisture resistance, grease resistance, sealability, stiffness, barrier performance, dimensions, and line behaviour, meaning a decision taken to simplify the regulatory position can trigger trials and machinery adjustments elsewhere in the plant.
Lightweighting creates a similar trade-off. Reducing gauge lowers material consumption, but a thinner structure still has to form correctly, resist puncture, carry top loads where required, protect the food, and retain enough stiffness to run through the packaging line without increasing rejects.
The regulatory redesign is therefore becoming a controlled manufacturing change rather than a packaging purchasing exercise. Material specifications, supplier approval, line settings, artwork, food-contact information, quality checks, pallet configurations, and customer documentation can all be affected by a single structural change to the pack.
Commission guidance issued shortly before PPWR began applying also underlined the phased nature of the timetable. Later deadlines do not remove requirements already in force, leaving companies to manage current obligations while building data systems capable of supporting additional rules due over the next several years.
That is where documentation becomes more than an administrative inconvenience. Packaging portfolios change routinely as suppliers, print designs, gauges, resins, coatings, and formats are adjusted, so compliance data has to remain linked to the actual pack in production rather than becoming a one-off exercise completed at the start of the regulation.
The survey also highlights interaction with wider European rules governing environmental claims. Technical information created to demonstrate packaging compliance can therefore influence marketing language, supplier contracts, artwork approval, purchasing decisions, and customer communications as well as regulatory files.
None of this means the regulation’s objectives are being rejected. Respondents generally supported better recycling and the removal of unnecessary packaging, but support for the policy is proving considerably easier than implementing the evidence system around thousands of individual packaging specifications.
The 7% confidence figure is best read in that context. Companies are changing materials and redesigning packs, but the legal and technical records needed to support those decisions are still catching up.
PPWR has spent years as a date on a compliance calendar. It is now part of daily packaging control, where a recyclable pack without the right evidence can be just as awkward operationally as a compliant file attached to a material that will not run through the line.
