How much does it cost to implement PPWR in a manufacturing company? Cost estimation

The costs of implementing PPWR in a manufacturing company may include a packaging audit, a recyclability analysis, a change in materials, testing of new formats, label updates, technical documentation, modifications to packaging machinery, adjustments to BDO and EPR, and staff training. There is no single, universal price for implementing the PPWR, as the budget for a company using just a few simple cardboard boxes will differ significantly from that of a plant which uses dozens of multi-material packaging types, exports products to the EU and utilises automated packaging lines.

The PPWR, or Regulation (EU) 2025/40, is intended, amongst other things, to ensure that all packaging on the EU market is recyclable in an economically viable manner by 2030, increase the proportion of recycled content in plastic packaging, reduce unnecessary packaging and develop reuse models.

For manufacturing companies, this means that the PPWR budget is not simply a single „consultancy” item. It is a packaging transformation project that may affect procurement, production, R&D, quality, logistics, marketing, compliance and finance.

Why is it not possible to quote a single price for implementing the PPWR?

The cost of implementing PPWR depends primarily on the scale and complexity of the packaging. A company that uses a few standard cartons and simple labels will incur costs that are completely different from those of a manufacturer of food, cosmetics, household chemicals or industrial components that uses laminates, films, trays, containers, closures, sleeves, fillers and transport packaging.

The cost is also influenced by the current level of preparation. If a company has up-to-date material specifications, packaging weights, supplier data, correct BDO records and label checks in place, implementation will be simpler. If the data is scattered across purchasing, the warehouse, production and accounts, the initial cost will be organising the information.

The biggest mistake when budgeting for PPWR is to ask only about the cost of the audit. The audit is just the start; the actual cost of implementation depends on how many changes will need to be made following the audit.

The main components of the costs of implementing the PPWR

The PPWR budget can be divided into several categories. Some costs are one-off, some will recur periodically, and some depend on the number of new packaging projects.

Cost category	Examples	Nature of the cost
Audit and assessment	analysis of packaging, risks, documents and suppliers	one-off or periodic
Data and documentation	packaging labels, declarations, specifications, BDO, EPR	one-off + updates
Packaging redesign	changes to the design, material, label or weight	design
Testing and validation	transport, quality, migration and recyclability tests	design
Raw materials and supplies	recycled material, single-material products, new cartons, returnable packaging	recurring OPEX
Packaging machines	changeovers, modules, formats, sealing, dosing	CAPEX / maintenance
Signage	new labels, pictograms, QR codes, print templates	project-based + cyclical
IT systems	ERP, WMS, stock data, reporting	implementation + maintenance
Training and procedures	purchasing, production, warehousing, marketing, compliance	periodic
EU Support	EPR and LUCID registrations, international reporting	cyclical

In practice, the cheapest implementation is not always the one with the lowest initial cost. Sometimes, a more thorough audit and a better redesign at the outset can reduce subsequent costs relating to materials, fees, complaints, label changes and issues with B2B customers.

The cost of a PPWR audit – what does it depend on?

The cost of a PPWR audit depends on its scope. A quick review of a few packaging items is priced differently from a full audit of a production plant’s packaging management system.

The cost of an audit is primarily influenced by:

– the number of SKUs and packaging variants,
– the number of packaging suppliers,
– the number of materials and components,
– the proportion of plastic packaging,
– the presence of multi-material packaging,
– sales to other EU countries,
– the number of packing lines,
– the quality of the available documentation,
– the need for a BDO, EPR or LUCID analysis,
– the need for workshops with the team,
– the level of detail in the recommendations.

EKOPRO describes the PPWR audit as a comprehensive assessment of a company’s readiness to meet the new requirements, involving an analysis of packaging in terms of its design, composition, recyclability, and environmental and legal compliance.

The simplest audit answers the question: „Where are the risks?”. A full audit should also identify what needs to be changed, in what order, what data to collect from suppliers, and which packaging is likely to incur the highest costs after 2030.

The cost of carrying out a stock-take of packaging

The first stage of implementation is usually an inventory of packaging. This is often an underestimated budget item, as many companies do not have a single up-to-date list of packaging.

We need to collect data on:

– individual packages,
– bulk packaging,
– transport packaging,
– e-commerce packaging,
– films, tapes and fillers,
– labels and closures,
– masses and materials,
– annual volumes,
– suppliers,
– sales markets.

If a company has its materials well documented in the ERP system, the cost of this stage will be lower. If data has to be collected manually from invoices, the warehouse, production and suppliers’ files, the cost increases.

EKOPRO’s environmental audit includes, amongst other things, an analysis of operational and production processes, taking into account the flow of materials, packaging and waste, as well as the identification of areas for optimisation and the reduction of waste generation at source.

The cost of the packaging redesign

Packaging redesign may be the most significant cost associated with implementing the PPWR. It does not always mean a complete change of material. Sometimes it is enough to change the label, the adhesive, the grammage, the carton size, the type of film or the way the product is secured.

A redesign may include:

– switching from multi-material packaging to single-material packaging,
– reducing the weight of the packaging,
– minimising empty space,
– a change to the label or sleeve,
– selection of a recyclable adhesive,
– a change in dyes, varnishes or coatings,
– the use of recycled material,
– the introduction of reusable packaging,
– redesign of the transport packaging,
– a change to the packaging for export.

The cost of a redesign depends on whether the packaging is simple or serves a protective, barrier, hygienic, marketing or logistical function. The most expensive changes usually occur where the packaging comes into contact with food, cosmetics, chemicals or products requiring stable protection.

The cost of new raw materials and supplies

The PPWR may increase demand for materials that are more suitable for recycling, recycled materials, paper and board meeting specific criteria, single-material products, reusable packaging and lighter-weight solutions.

The European Commission points out that the PPWR is intended to increase the use of recycled materials in packaging, and in the case of plastic packaging, the regulation sets out minimum levels of recycled content from 2030 and 2040.

New raw materials may be more expensive for several reasons:

– limited availability of high-quality recycled material,
– the need to comply with food contact requirements,
– a smaller number of certified suppliers,
– the need for qualitative tests,
– the variability of the properties of recycled materials,
– the need to order new formats,
– loss of discounts when moving away from the current arrangements.

At the same time, changing the material may reduce the total cost if the packaging is lighter, more recyclable, carries a lower risk of EPR and results in fewer complaints.

Changes to the PPWR production line – when are the costs of the machinery taken into account?

The cost of production line changes arises when the new packaging is not compatible with the existing machinery, packaging speed, sealing method, dosing, labelling, palletising or quality control.

The most common sources of machinery costs are:

– new carton sizes,
– a change in the thickness of the film,
– switching to a different type of weld,
– changing the label or sleeve,
– a new seal, pump or cap,
– changing the container, tray or bucket,
– the need to adjust the dosage of the product,
– a change to the palletising layout,
– the introduction of reusable packaging,
– adding a module for checking markings, QR codes or labels.

This is precisely why one should not order new packaging based solely on the cost of the material. Packaging that is cheaper to buy may end up being more expensive if it reduces line efficiency, increases production waste or necessitates costly changeovers.

In a manufacturing company, the cost of PPWR often does not lie in the packaging itself, but in the fact that the new packaging must be compatible with the existing packaging line.

The cost of testing and validation

Any significant change to the packaging should be tested. Testing involves a cost, but not testing could prove more expensive if the product starts to become damaged, leak, lose its shelf life or give rise to complaints.

The tests may include:

– transport tests,
– crush and puncture tests,
– leak tests,
– migration tests for food contact,
– tests to check that the product is compatible with its packaging,
– welding tests,
– labelling tests,
– tests for resistance to moisture, temperature and light,
– recyclability tests,
– a pilot project on the packaging line.

In regulated sectors such as food, cosmetics, pharmaceuticals, chemicals and medical devices, the cost of testing may be more significant than the price of the material itself.

The cost of signage and labels

The PPWR also introduces requirements regarding labelling and information on packaging. The European Commission points out that the new rules are intended to promote clear information on the sorting of packaging and to reduce unnecessary and misleading practices.

Costs may include:

– changes to graphic designs,
– updating templates, cutting dies and DTP files,
– new sorting pictograms,
– additional labelling for reusable packaging,
– QR codes or digital data carriers,
– translations for EU markets,
– verification of the compliance of environmental declarations,
– the disposal or use up of old stocks of labels.

In companies with multiple language variants for their labels, this cost can be significant, particularly when a single product has different versions for several countries.

The cost of BDO, EPR and overseas sales

The PPWR does not replace national obligations. The company must still account for packaging in Poland and analyse EPR in foreign markets. When selling to Germany, the LUCID scheme applies; for other countries, local registers, recovery organisations and reporting rules apply.

Costs in this area include:

– organising data on the weights of packaging,
– a correction to the material classification,
– an update to the BDO,
– EPR reporting,
– foreign registrations,
– LUCID audit,
– the administration of packaging charges,
– checking that sales data matches the reports.

Companies operating internationally should combine the implementation of PPWR with compliance with packaging obligations in EU markets and, for sales to Germany, with LUCID audit.

The cost of IT systems and data

In smaller companies, PPWR data may initially be recorded on spreadsheets and packaging labels. In larger organisations, integration with ERP, WMS, the procurement system, the supplier database and environmental reporting systems may be required.

IT costs may include:

– a database of packaging,
– material fields in the ERP system,
– a record of the weights of packaging,
– information on recycled material,
– label versioning,
– allocating packaging to sales markets,
– BDO and EPR reports,
– tracking reusable packaging,
– monitoring changes in suppliers.

If a company introduces reusable packaging, the associated costs may also include the identification of packaging, scanning, and the recording of turnover, losses and damage.

Training and procedural costs

PPWR affects many departments, so training should not be limited to the environmental protection officer. The changes must be understood by the procurement, production, warehousing, marketing, quality assurance, sales, logistics and finance departments.

The training should cover:

– the basics of PPWR,
– the classification of packaging,
– requirements for suppliers,
– recyclability,
– recycled content,
– signage,
– minimising packaging,
– BDO and EPR,
– approval of new labels,
– the procedure for changing the packaging.

Without proper procedures in place, the company may fall back into old habits: the marketing department will approve a label without checking compliance, the procurement department will choose a cheaper material without the necessary documentation, and the production department will accept packaging that cannot be reported correctly.

The cost-effectiveness of eco-packaging – how do you calculate the total cost?

The cost-effectiveness of eco-packaging should not be calculated solely on the basis of the unit price of the material. The total cost of ownership (TCO) of the packaging must be taken into account.

It is worth including the following in the calculation:

– the purchase price of the pack,
– weight and transport costs,
– storage costs,
– production waste,
– the capacity of the packaging line,
– the cost of the tests,
– BDO/EPR fees,
– the risk of higher product fees,
– the costs of handling complaints,
– the risk of a sales freeze,
– durability and number of uses for reusable packaging,
– the cost of disposal or recycling,
– the marketing and contractual value of standardised packaging.

Reuters points out that companies forced by regulations to redesign flexible plastics are faced with costly alternatives, limited recycling infrastructure and the need to invest in new technologies and materials.

Conclusion for manufacturers: more environmentally friendly packaging may be more expensive to purchase, but it is cheaper over its entire life cycle if it reduces weight, regulatory risks, charges and sales issues.

How do you draw up a budget for the implementation of the PPWR?

The best PPWR budget is drawn up in stages. A company should not assume that all packaging will need to be replaced straight away. First, the risks and priorities must be identified.

Stage 1: Diagnostic budget

It includes a PPWR audit, a packaging inventory, a review of documentation, risk identification and recommendations. This stage helps to avoid unnecessary expenditure.

Stage 2: the budget for rapid adjustments

This section covers tasks of low complexity: collecting data from suppliers, improving packaging labels, updating procedures, changing labelling, and standardising material classification.

Stage 3: the redesign budget

This includes packaging that needs to be redesigned or made from different materials: multi-material, difficult to recycle, too heavy, oversized, plastic or posing a risk for export.

Stage 4: Production and machinery budget

This applies to changeovers, line modifications, pilot tests, new cutting dies, formats, moulds, labelling modules and quality control.

Stage 5: Compliance maintenance budget

These are recurring costs: updating documentation, managing BDO/EPR, training, periodic audits, supplier verification and monitoring changes to regulations.

Example PPWR cost matrix

Level of risk	The nature of the company	Typical costs
Low	a few simple packages, a single market, good documentation	audit, packaging sheets, procedures, minor label corrections
Average	many SKUs, several materials, some sales in the EU	audit, redesign of selected packaging, testing, BDO/EPR, training
Tall	multi-material packaging, plastic, automated production lines, multiple markets	full implementation project, testing, suppliers, machinery, IT, EU ERP
Very high	food/cosmetics/chemicals, product contact, required barriers, export	testing, validation, certification, redesign, packaging lines, multi-market compliance

Such a matrix does not replace a valuation, but helps the management board determine whether the PPWR will be a compliance project or an operational and technical investment for the company.

The costs of implementing the PPWR versus the risk of inaction

Failure to implement measures also comes at a cost. The risks include:

– the need for an urgent replacement of packaging,
– loss of stock,
– a ban on sales within the retail chain,
– issues with the marketplace,
– higher EPR charges,
– no data submitted to BDO,
– administrative penalties,
– the loss of B2B customers,
– a costly last-minute redesign.

The PPWR requires Member States to lay down penalties for infringements of the Regulation, and these penalties must be effective, proportionate and dissuasive.

The cost of an audit and planned implementation is usually easier to control than the cost of a change imposed following an inspection, a customer complaint or a sales suspension.

How can we reduce the costs of implementing the PPWR?

The best way to cut costs is not to look for the cheapest material, but to prioritise tasks.

1. Start with an audit, not with purchases

Without an audit, the company may purchase new packaging that will still cause problems. PPWR audit It enables us to determine which packages actually need to be changed and which simply need to be documented.

2. Reduce the weight before changing the material

Sometimes, reducing the weight of the cardboard, film or filler results in greater savings than a complete change of raw material.

3. Standardise formats

Fewer formats mean simpler purchasing, storage, changeovers, documentation and reporting.

4. Talk to your suppliers in advance

Packaging suppliers can offer solutions that comply with the PPWR, but they need time for testing, documentation and stable volumes.

5. Link PPWR with GOZ

The implementation of the PPWR could form part of a broader circular economy. In this regard, it is worth looking into GOZ package, as cost savings often result from material efficiency rather than from simply changing the label.

6. Organise your data once, but use it repeatedly

The same data on weight, material and supplier is required for PPWR, BDO, EPR, LUCID, client audits and environmental declarations.

Who should be involved in the PPWR budgeting process?

The PPWR budget should not be drawn up solely by the environmental protection department. It is a cross-departmental project.

The following should take part in the process:

– the board of directors, because it approves the budget and assesses risks,
– finance, because they distinguish between CAPEX and OPEX,
– procurement, as they negotiate with suppliers and source materials,
– production, because he knows the line’s limitations,
– R&D or technology, as it is responsible for the packaging design,
– quality, as it assesses the safety of the product,
– logistics, as it analyses transport and warehousing,
– marketing, as it is responsible for labelling and communications,
– compliance, as it monitors compliance with the PPWR, BDO and EPR.

If a company does not have its own team capable of bringing these areas together, it is worth making use of comprehensive environmental consultancy for businesses and environmental audit.

Example: how should a manufacturing company estimate its costs?

The manufacturing company uses 40 different types of packaging: individual cartons, bulk packaging, plastic film, labels, fillers and transport packaging. It sells its products in Poland, Germany and the Czech Republic. Some of the packaging contains plastic components, whilst others are made from multiple materials.

A practical example of a cost estimate might look like this:

1. Audit and packaging map: reviewing 40 variants, weights, materials, suppliers and markets.
2. Risk assessment: a list of 10 packages requiring urgent replacement.
3. Quick corrections: improvements to the documentation and labelling for 20 packages.
4. Redesign: redesign 5–8 of the highest-volume packaging designs.
5. Tests: validation of new cartons, films or labels on the production line.
6. Machines: an assessment of whether the current production line can handle the new formats.
7. BDO/EPR: standardisation of data for Poland and foreign markets.
8. Procedures: implementation of the rules for approving new packaging.

In this model, an audit is not a final cost. It is a tool that helps to avoid spending money unwittingly on changes with little impact.

How should I prepare for a PPWR consultancy quotation?

To obtain a realistic quote, a company should provide some basic information. The better the data provided at the outset, the more accurate the cost estimate will be.

It’s worth collecting:

– the number of SKUs,
– a list of packages,
– photographs or packaging specifications,
– the weight of the packaging,
– information on materials,
– a list of suppliers,
– annual volumes,
– sales markets,
– information on BDO and EPR,
– description of the packaging lines,
– issues with complaints or damage,
– planned new products,
– current environmental claims on labels.

On this basis, the adviser can determine whether a simple audit, a full portfolio analysis, a redesign project, support with suppliers, a machine analysis or ongoing environmental support is required.

The most common errors in estimating PPWR costs

The first mistake is to focus solely on the cost of the audit. An audit reveals costs, but it does not replace them.

The second mistake is failing to take packaging machines into account. The new packaging must work on an actual production line, not just in the supplier’s catalogue.

The third mistake is overlooking stock levels. Old labels, plastic film and cardboard boxes may need to be used up, reprocessed or withdrawn.

The fourth mistake is not setting aside a budget for testing. Without testing, the company risks receiving complaints and having production halted.

The fifth mistake is separating PPWR from BDO and EPR. These same packaging types affect compliance, reporting and charges.

The sixth mistake is purchasing „eco-packaging” without assessing its cost-effectiveness. An environmental claim is no substitute for a total cost calculation.

FAQ - Frequently asked questions

How much does it cost to implement PPWR in a manufacturing company?

The cost depends on the number of packaging units, materials, packaging lines, sales markets, the quality of the documentation and the scope of the changes. Implementation may involve only an audit and documentation, or a complete redesign of the packaging, testing, a change of suppliers and modifications to the machinery.

What determines the price of a PPWR audit?

The cost of a PPWR audit depends on the number of SKUs, the number of packaging units, the complexity of the materials, the presence of multi-material packaging, overseas sales, the quality of the documentation, and whether the audit covers BDO, EPR, LUCID and technical recommendations.

Does PPWR require a change to the production line?

Not always. A line change is required when new packaging calls for a different format, sealing method, labelling, dosing, palletising or quality control. In many cases, it is sufficient to change the packaging specifications without the need for major investment in machinery.

Is eco-friendly packaging more expensive?

Not always. They may be more expensive per unit, particularly when using recycled or specialist materials, but they can reduce the total cost thanks to their lower weight, better recyclability, lower risk of levies, easier B2B sales and fewer changes in the future.

What is the most expensive part of implementing the PPWR?

The most costly aspects tend to be machine modifications, testing of sensitive products, changes to contact materials, the redesign of multi-material packaging, and the streamlining of large packaging portfolios across multiple EU markets.

How can the budget for implementing the PPWR be reduced?

It is best to start with an audit, identify high-risk packaging, reduce weight, standardise formats, collect data from suppliers and implement changes in order of priority. This approach avoids the need for a costly replacement of all packaging at once.

Find out the actual prices and adjust your budget

The costs of implementing PPWR depend on how complex the packaging is, how well the company understands its data, and whether the changes will affect only documentation or also materials, suppliers and packaging lines. The safest first step is an audit, which reveals where the costs actually arise and which measures have the greatest impact on compliance and cost-effectiveness.

If you would like to find out the actual cost of implementing PPWR in your manufacturing company, please use PPWR audit, environmental audit or Eko-Pro technical and environmental consultancy. You can also go to the tab Contact Eko-Pro and describe their packaging, volumes, packaging lines and sales markets.