PPWR regulation: what Rabobank’s analysis reveals about the packaging transition

Since 12 August 2026, every EU member state has had to apply the PPWR regulation – Regulation (EU) 2025/40 on packaging and packaging waste. In its August report, RaboResearch Food & Agribusiness, the research arm of Dutch bank Rabobank, examined where the rules stand today, what the market faces before 2030, and which parts of the industry are better prepared for the shift.

The report’s core message is simple: the PPWR regulation has moved from ambition to execution. The question is no longer what Brussels wants, but whether there will be enough recycling capacity, high-quality recyclate and paying customers for greener packaging.

In short: The PPWR regulation has applied since 12 August 2026, but its toughest requirements – mandatory recycled content, packaging minimisation and reuse targets – only take effect in 2030. According to Rabobank, the tightest bottleneck is flexible plastic packaging: by 2030, Europe must raise its use of recycled material from this stream from about 1.5 million to at least 2.5 million tonnes a year.

Where does the PPWR regulation stand today?

The regulation was adopted at the end of 2024, entered into force in February 2025, and began to apply generally on 12 August this year. Because it is a regulation rather than a directive, it does not need to be transposed into national law: it applies directly and uniformly in every member state.

Since the August date, three baseline requirements have been in force. All packaging must undergo a conformity assessment and be covered by an EU Declaration of Conformity – put simply, whoever places it on the market must be able to prove on paper that it meets EU rules. Food-contact packaging must respect limits on PFAS (the so-called “forever chemicals”), and heavy-metal limits apply to all packaging. How this regulatory pressure is already reshaping product development is illustrated by our piece on PE-free cup technology scaling up to billions of units.

Rabobank also highlights a mid-course correction. In February 2026, the European Commission exempted pallet wrapping and straps from the PPWR’s 100% reuse requirement. From 2030, these formats will instead face a 40% reuse target, while recycled-content rules still apply to them. The Commission cited a feasibility study showing that the original requirement would have imposed disproportionate costs: roughly EUR 610 million in adaptation costs across some 600,000 EU logistics providers.

What still lies ahead before 2030

The real test is the “second wave”, with a target date of 2030. That is when mandatory minimum recycled content in plastic packaging, packaging minimisation, bans on certain formats, reuse and refill targets, and recycling targets take effect. Member states must cut packaging waste to 5% below 2018 levels by 2030, and several thresholds tighten further after that. The PPWR also requires deposit return systems for single-use plastic drinks bottles and metal cans from 2029 wherever 90% separate collection is not achieved by other means – for how such a system beds in, see our report on Poland’s new deposit-refund system. Hungary has operated one since 2024.

Much of the detail is still missing. Rabobank counts at least 30 separate implementing and delegated acts that must be adopted under the PPWR by 2029. The timeline looks roughly like this:

• Late 2026: harmonised waste-sorting labels, a methodology for calculating recycled content, and rules for packaging minimisation and empty-space ratios.
• 2027: harmonised registration formats to bring national extended producer responsibility (EPR) schemes into a common European framework by 2029.
• 2028: design-for-recycling criteria and a methodology for “recycling at scale”.

Design-for-recycling rules will build on work already being done by industry bodies – see RecyClass’s updated packaging recommendations.

From 1.5 to 2.5 million tonnes: the flexible-packaging challenge

The report’s most important figures concern flexible plastic packaging: films, bags, pouches and most food wraps, typically made from polyethylene (PE) and polypropylene (PP).

Europe currently uses about 1.5 million tonnes a year of post-consumer recycled material (PCR) derived from flexible packaging. CEFLEX (Circular Economy for Flexible Packaging) estimates that at least 2.5 million tonnes will be needed by 2030 for producers to meet the PPWR’s recycled-content requirements. By 2035, flexible-packaging recycling capacity would need to reach roughly 5.9 million tonnes a year for this packaging type to count as genuinely “recyclable at scale”.

Compared with rigid packaging such as PET bottles, flexible plastics recycling is less mature, and using recycled content is far from standard practice. European recyclers, meanwhile, face high energy and labour costs, weak demand and competition from cheaper virgin resin. The UK offers a clear warning of what happens when policy ambition outpaces infrastructure – see our article on UK recycling infrastructure under pressure – while collection itself remains a challenge, as the Defra and ReLondon flexible-packaging pilot shows.

According to Rabobank, three things must happen in parallel:

• Invest on time. Permitting, building and ramping up a new plant takes years, so delays risk a structural supply shortfall by 2030.
• Find end markets beyond packaging. Packaging alone is unlikely to absorb the volumes needed by 2035, so durable non-packaging applications – such as outdoor furniture or construction products – are needed too.
• Protect quality, not just volume. Recyclate quality determines whether material can return to demanding applications. Mechanical recycling will handle most of the volume, while chemical recycling can complement it for contact-sensitive uses. Process quality matters at every step, including often-overlooked issues such as wash water in plastic recycling.

The report stresses that every polymer has different material flows, technologies and end markets, so targeted, material-specific approaches work better than a single one-size-fits-all model.

A divided industry: who wants more time, and who wants to keep the timetable?

Rabobank finds readiness uneven. Earlier this year, two industry coalitions sent opposing positions to the European Commission. A food, beverage and supplements coalition asked for delays and a review of selected provisions, while plastics, recycling and waste-management groups backed the current timetable.

The split is logical: readiness follows business exposure. Companies facing portfolio redesigns, supply-chain changes and new compliance systems expect the greatest disruption, while circular-economy businesses are generally better aligned. Rabobank does not expect major changes to the PPWR; the practical question is how quickly each sector can adapt as the secondary legislation emerges.

Importantly, the regulation applies to all packaged goods sold in the EU, regardless of origin. Non-EU exporters risk market restrictions, delays, product withdrawals or fines if their packaging does not comply. The report suggests six steps: assess existing packaging portfolios against upcoming requirements; evaluate the impact on products and supply chains, from design and material selection to recyclability; engage suppliers and partners to gather data and align compliance strategies; strengthen documentation and reporting processes; monitor the secondary legislation still in development; and track national implementation, because interpretation and enforcement may differ between member states.

Pricier feedstock, a more uncertain market

The transition is unfolding in a difficult market. According to Rabobank, the conflict involving Iran and disruption around the Strait of Hormuz rippled through the plastics industry over six months: oil and petrochemical feedstock supply tightened, energy and production costs rose, and price volatility increased.

The gains were unevenly shared. Some resin producers – such as North America’s LyondellBasell, whose net profit rose nearly fivefold in the second quarter – benefited from scarcity. Packaging makers fared worse: Amcor, one of the world’s largest packaging companies, faced a USD 500 million rise in input costs, more than it had forecast. Surveys of the German plastics industry found that four in ten companies did better in the first half of 2026, but only about one in five expected further gains, and every plastics-machinery respondent reported fewer orders.

This matters for the PPWR because the packaging industry is being asked to invest heavily at exactly the moment when costs are rising and demand is hard to predict.

Lessons from across the Atlantic: fees, labels and lawsuits

The report also covers the United States, which offers useful lessons for Europe. In California, the SB 54 law shifts recycling costs from taxpayers to around 5,700 producers through a producer responsibility organisation. The first invoice, due in 2027, is expected to total USD 1.26–1.87 billion, recurring annually thereafter. Fees are eco-modulated: packaging that recycles better pays less.

California also strictly defines what can be called “recyclable”: only materials accepted by collection programmes serving more than 60% of residents may carry the familiar chasing-arrows symbol. A federal court temporarily paused this labelling rule in July 2026, and a trial over Oregon’s EPR scheme has also taken place. The dispute is not about recycling itself, but about how transparently and fairly producer responsibility organisations set their fees.

For Europe, the message is clear: producer fees will increasingly reflect how recyclable packaging is, making good packaging design a financial as well as an environmental issue.

What this means for Hungarian businesses and consumers

Hungary’s extended producer responsibility system has been running since 1 July 2023, and because the PPWR applies directly, Hungarian manufacturers, distributors, importers and webshops already have to demonstrate that their packaging complies. Rabobank’s advice holds here too: companies that audit their packaging, request data from suppliers and begin redesigning now will not be making decisions under pressure in 2030.

Consumers will notice the change gradually: harmonised sorting labels, less unnecessary filler and empty space in boxes, and more packaging containing recycled material. But the system’s success depends on supply and demand growing together – on there being enough high-quality recycled plastic, and enough buyers for it. Accurate everyday sorting at home plays its part in that too.

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Frequently asked questions about the PPWR regulation

When did the PPWR regulation start to apply?

The PPWR regulation has applied generally in all EU member states since 12 August 2026. From that date, packaging requires a conformity assessment and an EU Declaration of Conformity, food-contact packaging must meet PFAS limits, and all packaging must comply with heavy-metal limits. As a regulation, it applies directly without national transposition.

Which new requirements take effect in 2030?

The second wave of the PPWR regulation takes effect in 2030. It includes mandatory minimum recycled content in plastic packaging, packaging minimisation, bans on certain formats, reuse and refill targets, and recycling targets. Packaging waste must fall 5% below 2018 levels by 2030, and several thresholds will tighten further after that date.

Why is flexible plastic packaging the biggest challenge?

Because the gap between supply and demand is widest there. Europe currently uses about 1.5 million tonnes a year of recycled material from flexible packaging, while CEFLEX estimates at least 2.5 million tonnes will be needed by 2030. Recyclers also face high energy and labour costs, weak demand and competition from cheaper virgin resin.

What changed for pallet wrapping and straps?

In February 2026, the European Commission exempted pallet wrapping and straps from the 100% reuse requirement. From 2030, they will instead face a 40% reuse target, while recycled-content rules still apply. The Commission based the change on a feasibility study estimating around EUR 610 million in adaptation costs for roughly 600,000 EU logistics providers.

Does the PPWR regulation apply to products from outside the EU?

Yes, the PPWR regulation applies to all packaged goods sold in the EU, regardless of where they come from. According to Rabobank, non-EU exporters risk market restrictions, delays, product withdrawals or fines if their packaging does not comply, so they should already be auditing their packaging and strengthening their documentation processes.

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Sources:

• RaboResearch Food & Agribusiness (Jim Owen, Regina Mestre): Unwrapped: Plastic packaging matters, August 2026
• European Commission, 2026
• CEFLEX – Circular Economy for Flexible Packaging (figures cited in the Rabobank report)