The Packaging and Packaging Waste Regulation (PPWR for short) entered into force on 11 February 2025 has been directly applicable in all EU member states since 12 August 2026. With its application, it replaces the previous EU Packaging Directive. Individual provisions will be phased in until 2030.
The aim of the PPWR is to reduce packaging consumption, improve the recyclability and sustainability of packaging and strengthen the circular economy, for example through mandatory minimum recycled content for plastic packaging.
As a manufacturer of primary packaging for the food, pharmaceutical and cosmetics industries as well as the chemical and technical industries, JOMA Packaging is also significantly affected by the resulting developments and changes.
The company sees the new EU packaging regulation as both a challenge and a major opportunity: “The PPWR increases the pressure for change in the industry, but at the same time creates room for innovation and for companies that are already developing suitable solutions today,” says Paul Weissenstein, International Sales and Marketing Manager at Joma Service GmbH.
Change as an opportunity: what is the EU Packaging Regulation (PPWR)?
The new EU Packaging Regulation (PPWR) brings fundamental changes that will have a lasting impact on the entire life cycle of packaging.
- Stricter substance limits for food packaging: In addition to the existing restrictions, limit values for the often controversial per- and polyfluoroalkyl substances (PFAS) have applied since 12 August 2026. They apply whenever packaging comes into direct contact with food.
- Mandatory recyclability: From 2030, packaging must be designed so that its components can be separated, sorted and recycled. Its recyclability is assessed by the share of its weight that is recyclable: Grade A corresponds to at least 95 percent, Grade B to at least 80 percent and Grade C to at least 70 percent. If the share is below 70 percent, the packaging may no longer be placed on the EU market. From 2035, a second test is added: packaging must then not only be designed for recycling. All member states must also be able to demonstrate that packaging of this type is collected, sorted and recycled at scale. From 2038, Grade C will no longer be sufficient; at least Grade B will then be required.
- Recycled content obligation for plastic packaging: By 2030, plastic packaging must contain a minimum recycled content of 35 % (non-contact-sensitive packaging), 30 % (PET packaging) or 10 % (other contact-sensitive packaging).
- General obligation to demonstrate packaging compliance: Anyone placing packaging on the European market is now required under the PPWR to assess the conformity of their packaging with the sustainability requirements and to document this in an EU declaration of conformity.
- Reduction of packaging waste: Beyond the recycling requirements, the PPWR aims to prevent packaging waste from arising in the first place: compared with 2018, the volume of packaging is to fall by 5 % by 2030, by 10 % by 2035 and by 15 % by 2040.
Responsibility for waste prevention and closed-loop management is thus increasingly shifting to the start of the supply chain, towards the design and sourcing of innovative and sustainable packaging solutions.
To live up to this responsibility, JOMA began early, under the motto “re:thinking plastic”, to develop its processes and some of its products accordingly. The goals of the PPWR therefore coincide in many areas with the sustainability strategy that JOMA has already been pursuing for years.
A clear roadmap: why JOMA has been working on the PPWR for some time
JOMA is well prepared for the PPWR. The company’s goals have long been tied to a sustainability roadmap: a photovoltaic system on the roof of the new plant already covers a significant share of the energy needed for production, while an in-house recycling plant reintroduces production scrap into the manufacturing process as post-industrial recyclate (PIR).
Since 2022, recyclability and the use of recyclate have also been given even greater weight in the development and product strategy. One of the triggers was the UK plastic packaging tax on packaging with less than 30% recycled content. Since then, development, quality management and marketing have worked closely together to identify regulatory developments early and incorporate them into product development.
Recycling in practice: current solutions and next steps
As part of its sustainability strategy, JOMA has long offered its customers forward-looking packaging solutions with a correspondingly high recycled content through its re:cycle range. For example, the proven spice grinder with JOMA grinding mechanism is already available today as a variant made from 100% PCR (post-consumer recyclate), well ahead of the PPWR requirement for mandatory minimum recycled content in plastic packaging by 2030.
Recycled material types are also already available for other products, for example in the JOMA Securibox® range and the dispenser systems, and are used by individual customers. In the chemical and technical industries, sustainable packaging solutions made from PCR materials have been in use for several years owing to the respective regulatory framework.
JOMA ensures compliance with material requirements through rigorous selection and evaluation of qualified suppliers, as well as comprehensive material and testing documentation. Requirements for PCR are particularly stringent for food-contact applications, which is why JOMA carefully selects materials suited to each specific use. Where PCR or mono-materials are not yet available, JOMA aims to integrate such solutions into its range by 2030.
The JOMA Cream Dispenser: where functionality meets recyclability
The continuous development of the JOMA Cream Dispenser shows how demanding the path to recyclable packaging can be. The highly functional dispenser system with patented vacuum pump technology, which reliably dispenses even highly viscous media, has so far consisted of several different plastics and a metal spring. “The challenge here lies in particular in combining high functionality with recyclability,” explains Paul Weissenstein. A first prototype without a metal spring achieves comparable dispensing performance and is currently undergoing internal load and stress tests, as well as the patenting process.
According to JOMA, however, sustainability cannot be defined by material alone. With appropriate use, the dispenser can be reused up to five times and significantly reduces product emissions over its life cycle. JOMA thus not only relies on recycled materials but also promotes the conscious reuse of products that have already been placed on the market.
Manufacturer responsibility and collaboration along the supply chain
Under the former EU Directive on packaging and packaging waste (94/62/EC), member states were required, in line with extended producer responsibility (EPR), to ensure that those who first place packaging on the market are liable for its entire use phase through to disposal and also bear the financial cost of meeting the Europe-wide minimum recycling quotas. The first person placing packaging on the market (often referred to in legal terms as the “manufacturer”) was generally the natural or legal person who first placed packaging filled with goods on the respective national market in the course of business.
Under the PPWR (EU) 2025/40, the roles of the manufacturer and the producer are now more clearly distinguished: the manufacturer is responsible for the conformity of the packaging; the producer fulfils the EPR obligations in the respective member state.
| Criterion | Supplier | Manufacturer | Producer (EPR) |
| Core role | Supplies packaging or packaging material to the manufacturer. | Has packaging developed or manufactured under its own name or brand. | Responsible for EPR obligations in the respective member state under PPWR criteria. |
| Conformity | Provides the manufacturer with the required information and documents. | Responsible for the conformity assessment, technical documentation, and EU declaration of conformity. | Has no conformity assessment obligation of its own solely by virtue of the EPR role. |
| Reporting and information obligations | Provides the relevant material and product data. | Keeps the technical evidence available for the authorities. | Registers, reports packaging quantities and fulfils the EPR financing obligations. |
In practice, this means: JOMA manufactures packaging and supplies it to its customers. However, if a customer has packaging produced under its own name or brand and places it on the market under that brand, responsibility as manufacturer generally lies with the customer. This also applies to standard packaging without individual engraving or a customer logo.
JOMA provides the necessary technical information and available test documentation so that its customers can meet their regulatory obligations – and sees itself not only as a packaging producer but also as an advisory partner to its B2B customers. These include brand owners, contract manufacturers and fillers as well as retailers. Advice on material selection, recyclability and regulatory requirements is often provided by the field sales team responsible, complemented by the technical expertise of quality management and development.
Especially in long-term packaging projects, early coordination is crucial, as product development, validation, and material changeovers naturally require sufficient lead time
For example, JOMA uses a special product carbon footprint (PCF) tool to calculate packaging emissions across the recorded life cycle phases and to compare them within its own product portfolio. If a customer aims, for instance, to reduce its packaging emissions by 30% by 2030, the JOMA team provides concrete approaches and data for this.
Outlook: The PPWR and the future of the packaging industry
In JOMA’s assessment, the PPWR will fundamentally change the packaging industry, if only because it affects material selection, production, recyclability, and the entire life cycle of a packaging item.
What other companies can learn from JOMA:
- Packaging companies affected by the PPWR should agree on responsibilities, material requirements and required evidence with customers, suppliers and packaging manufacturers early on.
- Companies should not assess packaging solely by its recycled content but also include reuse and environmental impact across the entire life cycle in product development.
- Those who bring sustainability, technical feasibility and regulation together early can approach necessary adjustments strategically and even gain competitive advantages from them.