The objectives of the PPWR and the challenges for authorised representatives in Europe

 

The Packaging and Packaging Waste Regulation (PPWR) is part of the European Green Deal and therefore a central element of the EU strategy to promote a circular economy. With ambitious goals, such as reducing packaging waste, increasing recycling rates and promoting reusable packaging, it affects all players along the packaging value chain. Authorised representatives (ARs) play a key role in this, especially for companies outside the EU, and face unique challenges in implementing the regulations across borders.

What is the PPWR?

The PPWR is an EU regulation that aims to establish uniform rules for packaging and packaging waste in all member states. Its goal is to promote the European single market and to advance the transition to a modern circular economy through harmonised requirements.
The main topics of the regulation are recyclability, mandatory recycled content in plastic packaging, packaging minimisation, labelling, packaging bans and reusability.

These goals bring clear environmental benefits for our society and counteract the scarcity of resources, but at the same time they also present many companies, especially those without their own headquarters in the country concerned, with considerable challenges. As a foreign company, you generally know too little about national legislation in other supply areas, may not even speak the local language and therefore often need additional resources to fully meet EPR obligations and comply with compliance regulations.

Complex requirements for authorised representatives: between national requirements and EU-wide targets

Different national implementations

Despite the harmonising approach of the PPWR, differences still exist at the national level:

  • Recycling systems: Take-back systems (e.g. deposit systems) vary considerably from country to country. Depending on the type of packaging or the location where the packaging is generated, different providers are sometimes responsible for reporting and registering packaging or products in other EPR categories (e.g. WEEE). A country with well-developed reuse systems (e.g. Germany with its deposit system) can more easily implement strict reuse quotas than countries with less developed infrastructures.
  • Reuse targets: The definition and implementation of reuse quotas can be interpreted differently from country to country. While the PPWR sets minimum targets, member states can decide how to achieve them.
  • Interpretation of ‘reuse’: The exact definition of what constitutes ‘reusable packaging’ may vary from country to country. While some countries define reuse strictly as multi-trip packaging, others may also consider innovative systems or hybrid solutions (e.g. recyclable reusable containers) to be reused.

For authorised representatives, this means that they must understand and implement the intricacies of local regulations, which requires resources and expertise.

Increased reporting requirements

The PPWR introduces new and extensive reporting requirements, including:

  • Information on the material composition of packaging: Companies and BVs must provide detailed information on the composition of their packaging, including the exact type and proportion of materials, and also report on the use of recycled materials.
  • Evidence of compliance with recycling and reuse targets: Companies and BVs must report data on the quantity and type of packaging used and report on what proportion has been recycled or reused.
  • Reports on the implementation of eco-design criteria: Companies and BRs must prove that their packaging meets the ‘Design for Recycling 4’ criteria. This includes designing for optimising recyclability, minimising the use of materials (so the fewer different materials, the better) and avoiding unnecessary packaging elements (so-called ‘deceptive packaging’ is prohibited, for example).

Authorised representatives, in particular for companies not based in the EU, must set up systems to efficiently collect and validate all this data. There is a risk of sanctions for incorrect reports or reports not submitted by the deadline, which further increases the pressure on companies and authorised representatives.

Industry-specific requirements

The PPWR sets reuse targets for individual industries, such as for the catering and HORECA (hotel, restaurant, catering) sector:

  • Reusable packaging for takeaway food: The aim is to drastically reduce single-use plastic and other disposable packaging. This can be particularly challenging for the catering industry, as they face the problem of how to hygienically clean reusable packaging and return it to circulation. This requires appropriate take-back systems and national cooperation.
  • Reuse for large beverage containers (e.g. barrels or bottles) , i.e. participation in deposit systems or the use of reusable containers. This also means that the packaging must be designed in such a way that it can be reused multiple times without any problems and without any loss of quality.

There are also a few challenges for retailers and e-commerce providers, for example:
Reusable shipping packaging: By 2030, the e-commerce sector will be required to make a certain proportion of packaging reusable. This applies in particular to cardboard boxes, cushioning materials and plastic films. Logistics companies will therefore have to develop systems to recycle shipping materials while minimising the environmental impact of return shipments.
Authorised representatives must support their customers in adapting packaging designs and systems to meet these requirements. For example, they can support the development and introduction of reusable systems or optimise packaging designs to improve recyclability and meet legal requirements.

Rising costs and administrative hurdles

International companies must be able to rely on their authorised representatives to fulfil their obligations in the EU. The implementation of the PPWR results in higher licensing fees, administrative requirements and possible penalties for non-compliance.

The PPWR creates a complex web of EU-wide and national regulations. But how exactly does an authorised representative support foreign companies in meeting the new challenges posed by the PPWR? An authorised representative:

  • reduces the administrative burden on companies,
  • minimises the risk of errors and penalties,
  • and enables companies to focus on their core competencies while ensuring compliance with regulatory requirements.

Especially for companies without a legal presence in the EU, an AR is essential to maintain access to the European market and to efficiently fulfil the PPWR requirements.

Authorised representatives and the PPWR: a key role for compliance and sustainability 

If you want to know whether you need to appoint an authorised representative for your company or which EPR obligations apply to your company according to the country of interest, start our free ‘Quick Check’ right here.

The PPWR sets new standards for sustainable packaging in Europe, but also presents major challenges for authorised representatives. Through the targeted use of technology, proactive collaboration and the integration of expertise, BV can effectively support their customers while contributing to the realisation of the Circular Economy.