The European Union (EU) is planning a significant overhaul of its packaging and packaging waste policies, hoping that it would enhance sustainability and promote the circular economy, and ensure all packaging in the EU is reusable or recyclable by 2030. For ASEAN exporters to the EU, these changes will likely mean new compliance requirements in how they package their products.

Originally introduced in 1994 [1], the EU’s packaging and packaging waste directive has undergone multiple revisions over the years. The latest revision, which comes as part of the EU Green Deal, has, however, an overreaching effect outside of the EU as well, as it looks to apply packaging rules to imports from outside the EU.

Under the revised regulation, fruit and vegetables may no longer be wrapped in single-use plastic, nor may plastic sauce cachets be used in products, although paper cachets will still be permitted. Other measures include mandatory reductions in packaging volume, restrictions on certain packaging types, and the potential for a de facto ban on plastics recycled outside the EU in packaging for food and drink products, as a result of a “mirror clause” which requires non-EU exporters to meet EU recycled content standards [2]. The regulation encompasses the entire lifecycle of packaging, aiming to minimize the use of substances of concern, ensure packaging recyclability, and standardize labeling to enhance consumer information. It introduces stringent measures to reduce packaging waste, including binding re-use targets and restricting certain types of single-use packaging [3]. The regulation mandates reducing packaging by 5% by 2030, 10% by 2035, and 15% by 2040 [4]. The regulation also mandates deposit return schemes and bans the use of per- and polyfluoroalkyl substances (PFAS, “forever chemicals”) in food packaging [4]. Other impacts affecting cross-border travel include a ban on luggage being plastic-wrapped at airports.

The existing rules on packaging and packaging waste are in the form of a Directive, but the latest revisions converts this Directive into a Regulation, making it directly applicable in all EU member states. Pending the final adoptions of the revision by the EU Parliament and Council, (which are expected by the end of April), the PPWR is expected to come into force by 2024, and the new rules will be applied and enforced from 2026 onwards (18 months after entry into force).

While the regulation is being pushed strongly by the Council and Parliament, Commission officials have noted that “very few recycling plants outside the EU would be able to comply with the bloc’s packaging legislation”, hence leading to a de-facto ban on plastics recycled outside the EU [2].

ASEAN businesses should closely monitor the development of the PPWR and begin preparing for compliance to maintain access to the EU market.

[1] Directive 94/62, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31994L0062.
[2] Financial Times, https://www.ft.com/content/6c75ca96-ca6c-45d0-9853-dc825c066a28.
[3] Council of the EU, https://www.consilium.europa.eu/en/press/press-releases/2024/03/04/packaging-council-and-parliament-strike-a-deal-to-make-packaging-more-sustainable-and-reduce-packaging-waste-in-the-eu/.
[4] Food Packaging Forum, https://www.foodpackagingforum.org/news/provisional-agreement-reached-on-eus-packaging-and-packaging-waste-regulation.