At TheRockGroup, we provide large companies and SMEs with insights into the implications of the Packaging & Packaging Waste Regulation (PPWR) and advise on how companies can prepare for this new regulation.
‘Help us see the forest for the trees’ is a frequently asked PPWR-related question we are currently receiving, says colleague consultant Lettemieke in a new interview with Verpakkingsmanagement. ‘In other words: what do the requirements of the PPWR mean for our company? What can/should we already do? In doing so, we look at the company’s context and the packaging.’
Administrative Burden for Companies
Lettemieke Mulder finds it difficult to quantify the administrative burden that the PPWR brings. ‘It depends on the situation/context of the company in question and already existing processes and actions, and also whether the company is a packaging producer or a packaging company that imports packaging. What we can say is that these burdens can play out at different levels for companies, such as compliance with EPR schemes, documentation and reporting, and labeling and information.’
- Compliance with EPR Schemes Extended Producer Responsibility means that companies must take responsibility for the entire lifecycle of packaging, from production to the waste phase. This involves financial contributions to waste management systems in the countries/markets where the company operates and ensuring that the packaging design meets standards for recyclability, among others.
- Documentation and Reporting Both packaging producers and product manufacturers/importers must maintain documentation demonstrating compliance with PPWR standards and may be required to report this to regulatory authorities. Preparing for potential inspections/audits will also bring additional burdens.
- Labeling and Information New labeling requirements for packaging materials and recyclability can increase the complexity of packaging design and production. Companies must ensure that labels are accurate, informative, and compliant with regulations. Clear information must also be provided to consumers on how to responsibly dispose of packaging, which can lead to additional responsibilities, administration, and potential costs.
Costs Associated with PPWR
Asked about the costs associated with the PPWR, Lettemieke Mulder says: ‘It’s difficult to put a specific number on it. Costs can vary significantly from company to company, depending on factors such as the sector and market(s) in which the company operates and the type of packaging the company produces or uses. This includes materials, type, single-use or reusable, etc. It also depends on whether the company designs and produces its packaging and the extent to which a company, for example, needs to design new packaging or adapt existing ones to meet new standards for recyclability and reusability. This can lead to research and development costs and potential changes in supply chains.’
Indicative Costs of PPWR
‘Although the exact costs for PPWR will vary, and we do not make these estimates ourselves, we have encountered indicative figures in studies and industry reports. SMEs may face proportionally higher costs. Estimates suggest that compliance costs can range from €10,000 to €100,000 per year, depending on the complexity of their activities and the extent of required changes.’
‘Larger companies may incur higher absolute costs, running into millions of euros, but can benefit from economies of scale. Large multinational enterprises may face initial implementation costs of €1 to €5 million, with ongoing annual costs in the hundreds of thousands.’
‘Scan the Current Packaging Portfolio’
‘Conduct a scan of the current situation’, is often the first step TheRockGroup recommends, says Mulder. ‘Which packaging materials does the company purchase, and who are their suppliers? Then follows a high-level gap analysis. This involves examining how the regulations apply to the company’s specific situation and sector and when they take effect. Start documenting packaging information as soon as possible.’
‘We also advise conducting a cross-check with other potentially relevant EU legislation. Consider, for example, the EU CSRD and reporting on ESRS 5 – resource use and circular economy, and the EU Green Claims directive (under development).’
TheRockGroup Assists with Strategic Direction
Mulder advises closely following current PPWR developments. This can be done independently, through external advice, and/or via your sector organization. ‘Also, consider if there are themes on which you want to be active and parties with whom you should collaborate,’ she says. ‘For example, through your national or European sector association. Learn from best practices. Many companies are already very active. Identify good news sources that are relevant and specific to your company. Also, find out what support is available from the government.’
‘The previously mentioned scan and gap analysis provide insights into where a company stands. Based on this, create a strategy and phased plan. Keep in mind specific provisions and their effective dates. Assign responsibility for implementation to someone or a team who monitors new regulatory developments.’
‘Finally, follow trends and determine where you want to position your company in the long term. How can you turn risks/compliance into opportunities? You can, for example, anticipate future requirements and offer your customers what they will need to comply with in the near future.’
