The 2024 updates to the EU Packaging and Packaging Waste Directive (PPWD), originally adopted in 2018, mark a significant tightening of sustainability obligations for businesses across the European Union. With the revised directive now enforcing higher recycled content targets for packaging, manufacturers, brand owners, and importers must enhance the transparency, traceability, and reporting of their packaging materials. The updated rules aim to accelerate the EU’s transition to a circular economy, minimize environmental harm from packaging waste, and promote the use of secondary raw materials in the production of packaging components.
Under the 2024 amendments, minimum recycled content thresholds have been raised across key packaging categories, including plastic bottles, films, and composite packaging. For example, PET beverage bottles must now contain at least 35% recycled plastic by 2025, with further increases scheduled through 2030. Similar targets apply to other plastic packaging types, while all materials must meet more stringent recyclability and reusability criteria. In response, packaging manufacturers must strengthen their supplier due diligence and data collection processes to verify the source and composition of packaging inputs. This verification extends beyond direct suppliers to the resin producers and recyclers that form the base of the packaging supply chain.
A critical enabler of compliance with the updated PPWD is the effective use of Extended Producer Responsibility (EPR) data. EPR schemes across EU member states collect and publish open data on packaging placed on the market, packaging waste collection, treatment outcomes, and recycling rates. Packaging manufacturers should integrate these datasets into their material sourcing and reporting workflows. By reconciling open EPR data with internal procurement records, manufacturers can validate that their packaging components meet recycled content requirements and that any discrepancies are identified and addressed proactively. This approach not only supports compliance but also demonstrates to regulators and customers that the company is committed to full supply chain transparency.
To implement this reconciliation, packaging manufacturers should first map their supplier network down to the resin source level, categorizing each supplier by polymer type, recycled content percentage, and certification status. This mapping should be cross-referenced against EPR data, which can provide evidence of aggregate recycling rates, national targets, and material flows within the EU. Any gaps or inconsistencies between supplier declarations and EPR records should trigger further inquiry or verification. In addition, manufacturers should document the origin of recycled materials, ensuring that secondary raw materials are sourced from approved recyclers and meet the quality and safety standards prescribed by EU law.
Once internal records and EPR data have been aligned, manufacturers must prepare and submit digital compliance reports to national waste authorities. The 2024 PPWD updates emphasize electronic reporting to improve data accuracy, standardization, and accessibility. Digital reports must detail the weight, composition, recycled content, and recyclability of all packaging placed on the market, along with evidence supporting these claims. Manufacturers should use standardized templates provided by national authorities or industry bodies to ensure consistency across submissions. Reports should be submitted according to the frequency specified by each member state’s transposition of the directive, typically on an annual basis, though some jurisdictions may require more frequent updates for high-volume producers.
A structured workflow is essential for efficient and accurate reporting under the updated directive. Manufacturers should begin by collecting supplier data through standardized forms that capture key information on material type, recycled content percentage, certification (e.g., EuCertPlast, Blue Angel), and batch numbers. This data should be consolidated in a central compliance management system, which can automatically reconcile supplier inputs with EPR open data and flag inconsistencies. Compliance teams should review flagged records, liaise with suppliers as needed to obtain clarifications, and approve data for inclusion in the final digital report. The reporting package should be reviewed by legal and sustainability teams before submission to ensure alignment with both regulatory requirements and corporate responsibility goals.
In parallel, packaging manufacturers should implement continuous improvement measures to enhance future compliance and reduce risk. These measures include establishing long-term agreements with certified recyclers, participating in voluntary industry initiatives that promote circular packaging design, and investing in traceability technologies such as blockchain or digital watermarking. Additionally, manufacturers should engage with EPR organizations and national authorities to stay informed of evolving requirements and best practices for reporting. Transparent communication of progress through sustainability reports or corporate websites can help strengthen brand reputation and reassure stakeholders of the company’s commitment to circularity.
The 2024 PPWD updates represent both a regulatory challenge and a strategic opportunity for packaging manufacturers. By leveraging open EPR data, rigorously verifying supplier claims, and adopting best practices in digital reporting, manufacturers can not only meet compliance obligations but also position themselves as leaders in sustainable packaging. In doing so, they contribute meaningfully to the EU’s vision of a low-waste, resource-efficient economy where packaging serves the needs of consumers without compromising environmental integrity.