If you think the regulatory burden for coatings firms is already high, get ready for the next big thing – the Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40). This new rule, which takes effect from August 12 this year, will treat most companies selling or distributing packaged products – including coatings – as the “manufacturer” of the packaging, with significant strategic, operational and cost impacts as a result. By Dirk Thelen, PPG Regional Director, EU Green Deal.
This represents a fundamental shift, as in most cases the compliance responsibility in the value chain is shifting from the packaging maker to the coatings maker or brand owner. Under the previous Packaging and Packaging Waste Directive (PPWD) in place since 2004, it is the packaging maker that is responsible for making sure that key requirements, such as heavy metal content, are met.
The goals of the PPWR are noble – reducing packaging waste, promoting circularity and harmonizing rules across EU Member States. Key targets include making all packaging recyclable by 2030, reducing packaging waste (5% by 2030, 15% by 2040), setting reuse and refill targets, and mandatory recycled content targets for plastics. The PPWR clearly defines the manufacturer obligations as a market entry condition from Aug 12 2026. Companies have to ensure compliance whether they manufacture within the EU or import into the EU. Non-EU competitors will have to comply as well; domestic players will probably have better regulatory understanding so they might have an initial advantage.
However, the PPWR definition of “manufacturer” brings costly obligations, gradually increasing, including compliance evaluation, technical documentation, EU declaration of conformity (DoC), labelling obligations and proof of recyclability, as well as responsibility for material composition. This will require the collection of information from the packaging makers. Many of those packaging firms, however, are not aware of the data disclosure requirements.
The responsibility for providing data should lie with those companies who actually manufacture the packaging materials, have influence on and control over their individual components, and are fully involved in the packaging production and quality process. Only under these conditions can users be sure that the packaging meets the PPWR requirements. This can only occur if valid declarations, data and other information are available and supplied from packaging makers prior to the use of their products.
New processes needed
The shift will require coatings makers, brand owners and other packaging users to develop and implement new processes, and it will add a significant challenge regarding data management and data quality. One key risk is that some companies may not be ready for the August 12, 2026 deadline to produce a DoC for each packaging item; additionally, the exact format of the DoC is still not clear. It is important that packaging suppliers actively support customers with data well in advance of that deadline. The initial requirements are around substances restrictions, including heavy metals for packaging and PFAS for food contact materials. From 2030 onward there will be additional requirements, including recyclable packaging, recycled content in packaging, and reuse of packaging. The Commission is required to establish the requirements before that date, but has not yet done so.
Packaging makers – and their material suppliers – could be reluctant to share information about their products, so it is essential that the EU Commission ensures effective enforcement of the PPWR’s Article 16 “Information obligations of suppliers of packaging or packaging materials,” so that coatings makers and other users receive all the necessary supporting information and documentation to meet their specific obligations. If this data is not supplied well ahead of time, the user may need to find an alternative packaging supplier in order to stay compliant. The PPWR does contain some important exceptions, most notably for small businesses, but overall, it is likely to bring huge issues to the coatings sector, including more bureaucracy, higher compliance costs, and increased dependence on packaging supply chain risks, and other uncertainties. The industry is facing imminent implementation, but without the information and support necessary for compliance.
Involved costs
For most companies, the costs will be huge. In cases such as specific safety data sheets or other product certificates and declarations, the costs for producing those can be as much as 1.000 euros per individual case, depending on complexity, data availability or the need to produce new data. It will largely depend on the complexity of packaging used. The cost per DoC will decrease with number of declarations, so the hit can be assumed to be bigger for SMEs than for larger companies that can leverage scale. Those costs result in a new document that is to be available to authorities for 5-10 years upon request, but without any real function in the value chain.
The Commission had promised a detailed Q&A on the PPWR a year ago to help provide some clarity, but this had still not been published as of early March. In this critical preparation phase, coatings makers need more support from the commission to ensure that packaging makers will provide relevant information timely so that we can perform the new technical evaluations and produce technical dossiers correctly on a timely basis. Otherwise supply disruption will be the consequence.
PPWR certainly has the potential to strengthen the positive contributions of the coatings sector to circularity. However, this will depend on the path the EU commission will take to develop the large number of secondary delegated acts and how much it will listen to industry to develop practical solutions. EU member states have an important role in the PPWR; although it is a regulation, it can be viewed as a kind of hybrid legislation requiring and allowing member states to develop national guidelines and rule. We must avoid that member states start to “gold-plate” already defined rules, otherwise fragmentation will counteract the positive benefits.