PPWR: What the New EU Packaging Regulation Means for Flexible Film Users
The EU Packaging and Packaging Waste Regulation (2025/40) entered into force on 11 February 2025. After an 18-month transition period, most provisions will apply from 12 August 2026. This isn't a directive requiring national transposition—it's a regulation, directly applicable across all EU Member States. Same rules for everyone.
Why this matters
The PPWR replaces the previous Packaging and Packaging Waste Directive (94/62/EC), which had been in place since the 1990s. The European Commission found that the old directive was not efficiently preventing the growth of packaging waste. The new regulation aims to reduce packaging waste in the EU by at least 15% by 2040 compared to 2018 levels.
Key deadlines for flexible packaging
August 2026: General application begins. Packaging must comply with strict rules on material and space efficiency—empty space in parcels must not exceed 40%.
2027: Digital labelling requirements. Packaging must carry digital identifiers (e.g., QR codes) linking to structured environmental information, including material composition and recyclability.
2028: The Commission will adopt delegated acts setting design-for-recycling (DfR) criteria and recyclability performance grades (A, B, C, D).
2030: All packaging must be designed for recycling. Only grades A-C (minimum 70% recyclable) will be allowed on the market. Minimum 30% recycled content in single-use plastic bottles.
2035: Packaging must be "recyclable at scale"—meaning actual recycling infrastructure exists, not just theoretical recyclability.
2040: Recycled content targets increase to 65% for single-use plastic bottles.
What this means in practice
- Films that can't demonstrate recyclability will face market restrictions
- Extended Producer Responsibility (EPR) fees will be linked to recyclability performance grades—better grades, lower fees
- "Recyclable in theory" won't cut it—you'll need "recycled at scale" proof
- PFAS in food contact packaging will be restricted (25 ppb limit for any single PFAS, 250 ppb for total)
- Non-EU companies shipping directly to EU consumers must appoint an authorized representative within the EU
The regulation doesn't ban plastic. It bans unrecyclable plastic.
This is a critical distinction. The PPWR targets packaging that cannot be effectively recycled through existing infrastructure—including crosslinked (irradiated) films, complex multilayer structures, and materials with incompatible additives.
The crosslinked film problem
Crosslinked polyethylene films, despite sometimes being marketed as "recyclable," are incompatible with mechanical recycling. The irradiation process creates permanent bonds between polymer chains that don't break during reprocessing. These films contaminate recycling streams and produce lower-quality recyclate. Under PPWR's recyclability grades, they will likely fall into grade D—effectively banned from the EU market by 2030.
How Decofilm is positioned regarding to PPWR
Our DECOMAB and DECOLINE ranges have been certified by Interzero "Made for Recycling":
- Decoline: 19/20 points - "Very Good" classification
- Decomab: 17/20 points - "Good" classification
- 100% mass fraction available for recycling
This certification is based on testing by the Fraunhofer Institute (IVV) and methodology by bifa Umweltinstitut, with compliance to DIN EN 13430 and ZSVR minimum standards.
DECOMAB is the first barrier shrink film that achieves high mechanical performance without crosslinking—patented, non-irradiated, 100% recyclable, and fully compatible with standard PE recycling streams.
The bottom line
Companies working with certified recyclable films today won't need to scramble in 2028. Those still using crosslinked, multilayer, or otherwise non-recyclable materials will face supply chain disruptions, higher EPR fees, and potential market access restrictions.
We've been preparing for this for years. Are you?