The PPWR is coming and that does not mean that tomorrow all packaging will suddenly have to be changed. But it does mean that this is the time to focus on which packaging needs attention first. Because that is where the real challenge lies for many organizations: not in "everything at once", but in smartly prioritizing the packaging where risk, complexity and ambiguity come together.
That's exactly what the PPWR calls for. It has been in effect since Feb. 11, 2025, and applies broadly from Aug. 12, 2026. In the years that follow, requirements around recyclability, recycled materials, labeling and minimization, among others, will become more concrete. Thus, organizations that gain visibility into their most critical packaging now are not only building compliance toward 2026, they are also creating peace of mind and direction for the years beyond.
Under the PPWR, packaging with complex material combinations, lots of empty space, sensitive substances such as PFAS, little visibility into recyclate or limited packaging data in particular require extra attention. It is precisely these packages that you want to be the first to see, because that is where risk, uncertainty and opportunities for improvement often converge.
That's what makes this question so relevant: which packaging is most at risk under the PPWR? Not because you immediately need a definitive opinion for each type of packaging, but because you want to apply focus. Because if you know where the biggest concerns are, preparation immediately becomes a lot more concrete.
Packaging with complex material combinations
One of the first categories that stands out under the PPWR is packaging made up of multiple materials that are difficult to separate. Consider combinations of different plastics, packaging with coatings or laminates, or packaging in which materials are so intertwined that recycling becomes complicated.
Why this is so important? Because the PPWR steers toward packaging that is recyclable in economically feasible ways. And the more complex the packaging, the more likely that recyclability is under pressure. Especially as further elaboration around design for recycling becomes more concrete, these are the packaging you don't want to look at until 2026.
That doesn't mean that every composite packaging is immediately discarded. But it does mean that this is typically the kind of packaging you want to ask questions about early on:
- could this be simpler?
- are all the components really necessary?
- How strong is the justification for recyclability?
This is precisely where the first opportunity for improvement often lies.
Packaging with a lot of empty space
Packaging with a lot of empty space also quickly stands out. This is particularly relevant for shipping and e-commerce packaging. Because the PPWR looks not only at material types, but also at minimization: packaging should not be unnecessarily large, heavy or complex.
And that makes sense. Packaging that primarily carries air uses more material than necessary, requires more transport volume and often produces more waste. This makes this type of packaging not only a future concern from a regulatory perspective, but also a very practical starting point for optimization.
The great thing is: there are often relatively quick profits here. A better box size, less cushioning material or smarter standardization can have an immediate effect on material use, logistics and future compliance.
Food contact packaging with PFAS or other sensitive substances
If there is one issue that is concretely on the table towards Aug. 12, 2026, it is PFAS in food contact packaging. The PPWR contains restrictions for this, and that makes packaging with coatings or applications that may fall under this a clear risk category.
Consider, for example, food packaging with grease-resistant coatings or other functional coatings. Not because automatically everything is problematic, but because here you want to know very precisely:
- what materials are used
- what substances they contain
- which supplier declarations are available
- and where substantiation is still lacking
For many organizations, the risk here is not only in the materials themselves, but also in the lack of overview. And this is precisely why this is one of those categories you want to have an early view of.
Plastic packaging with no visibility into recyclate
Plastic packaging also deserves extra attention, especially if it is unclear how much recycled material it contains. The PPWR is steering toward more use of recyclate in plastic packaging, with targets becoming increasingly relevant toward 2030.
That means organizations need to look not only at the type of plastic, but also at:
What proportion of recyclate is in this, and can we demonstrate this later?
This is typically one of those points where a packaging seems fine at first glance, but where the real challenge is in the substantiation. Because if supplier information is missing or unclear, a risk still arises. Not because the material is necessarily wrong, but because you will later have to be able to show how the packaging is constructed. This is precisely why you want to mark packaging without a clear view of recyclate as a point of interest now.
Packaging with many loose components
Sometimes the risk is not in the main material, but in the sum of small components. Consider:
- labels
- caps
- sleeves
- tape
- foils
- closures
- inserts
On paper, packaging like this may seem straightforward, but in practice it is these components that make all the difference. They affect recyclability, make documentation more complex and increase the likelihood that information will be missing or fragmented.
That's why packaging with many individual components is smart to screen early. Not because every extra part is immediately a problem, but because this is often precisely where the ambiguities arise that cause delays later.
Packaging from which hardly any data is available
Perhaps the most underestimated risk category: packaging about which simply too little is known. No current specifications, no clear overview of materials, no reliable supplier information, no good insight into weights or components.
Such packaging may not be the most technically challenging. But in preparation for the PPWR, this may actually be one of the biggest risks. Because without data, it becomes difficult to:
- properly assess packaging
- to build up technical documentation
- and later substantiate conformity
And this is exactly why the PPWR ends up being primarily a data issue for many organizations. Not only: what are we using?
But also: do we know enough about it?
Where do you start first?
Not with everything at once. The smartest approach is usually to start with the packages where volume, risk and data gaps converge.
That is:
- packaging that is used a lot
- and require technical or administrative attention
- And have a relatively high impact if you improve them.
These are almost always the packages where the most profit can be made. Not only towards compliance, but also towards costs, efficiency and future-proofing.
The core: risk is not only in technology, but also in uncertainty
That is perhaps the most important lesson from this whole issue. Packaging is not only risky if the material is technically difficult. Packaging can also be risky because too little data is available about it, because its structure is unclear or because it lacks substantiation.
This is precisely why it pays not to view risk analysis and packaging data separately. Getting that combination right now will make it much easier to work towards 2026 and make the next steps towards 2030 much more manageable.
The PPWR requires more than just knowledge of rules. You want to know what role you have, what packaging needs attention and what data you need to put in order now. In the PPWR starter kit you will find a practical step-by-step plan, a separate checklist and additional explanations to help you work towards August 12, 2026.
Download the starterkit
Useful starter kit with a checklist, step-by-step plan and examples to comply with the PPWR
Staying up-to-date
Stay up to date on all new developments? Follow us on LinkedIn and Instagram or subscribe to the newsletter. Are you curious about what Milgro can do for your operations and waste process? Then get in touch .
