The most common mistakes companies make when interpreting the PPWR regulations – how can they be avoided?

Mistakes in interpreting the PPWR could cost a company more than simply implementing the regulations. The most common problem is that managers reduce the regulation to a single slogan: „less plastic”, „more recycling” or „new labels”. However, the PPWR – Regulation (EU) 2025/40 – covers all packaging and packaging waste, regardless of material or origin. It therefore applies not only to plastic, but also to paper, cardboard, glass, metal, wood, multi-material packaging, transport packaging, e-commerce packaging and reusable packaging.

The greatest risk does not lie in the fact that a company is not familiar with every PPWR item. The risk lies in making the wrong decisions: switching to the wrong packaging material, ignoring data from suppliers, postponing an audit, labelling items incorrectly, or treating PPWR as a matter solely for the environmental department.

Why is it so difficult to interpret the PPWR?

The PPWR is not just a single, simple change to the regulations. It is a regulation that changes the approach to the entire life cycle of packaging: from design, through the purchase of materials, packaging, transport, labelling, sale, use, collection, recycling, recycled materials and reuse.

The European Commission points out that one of the objectives of the PPWR is for all packaging to be recyclable by 2030, and the new regulations are also intended to reduce unnecessary packaging, increase the use of recycled materials and promote reuse models.

This means that the PPWR cannot be implemented in one go. A company must understand which obligations apply to its packaging and which do not. The risks faced by a food manufacturer are different from those faced by an e-commerce business, an importer, a hotel, or a manufacturing plant using B2B transport packaging.

The worst interpretation of the PPWR is one that sounds simple, quick and convenient. In practice, the regulation requires an analysis of materials, packaging functions, data, suppliers and sales markets.

Mistake 1: „The PPWR applies only to plastic”

This is the most common myth about the PPWR. Plastic is indeed one of the key areas covered by the regulations, as the legislation introduces, amongst other things, requirements regarding the content of recycled material in plastic packaging. However, this does not mean that other materials fall outside the scope of the regulations.

The PPWR applies to all packaging. A company that uses only cardboard, paper fillers, glass or metal must also assess recyclability, packaging minimisation, labelling, documentation, EPR and any requirements for reuse.

Example of a mistake: a company stops using plastic packaging and switches to paper packaging with a barrier layer, a laminate and a plastic window. The marketing department publicises this as a success, but the compliance department fails to check whether the new packaging is actually easier to recycle.

How can you avoid making a mistake? Don’t start by asking, „Is this plastic?”. Start by asking, „What are the composition, function, weight, recyclability and documentation for this packaging?”.

Mistake 2: „All you need to do is swap plastic for paper”

Paper can be a good option, but it is not an automatic solution for PPWR. Paper packaging with a coating, barrier layer, varnish, laminate or permanent adhesive can be problematic to recycle. In contrast, simple plastic packaging, designed as a single-material product, may be easier to sort and recycle.

This is one of the most costly mistakes a company can make when purchasing. The company spends money on „more environmentally friendly” material, only for it to turn out that the new packaging is heavier, more expensive, harder to recycle or performs less well on the packaging line.

How can you avoid this mistake? Ensure that any change in material is preceded by a technical assessment. In the case of complex structures, it is worth analysing multi-material packaging, because it is these that most often reveal the difference between an eco-friendly appearance and actual recyclability.

Mistake 3: „We have until 2030”

The year 2030 is important, but it is not the only date mentioned in the PPWR. The Regulation entered into force on 11 February 2025 and, in principle, will apply from 12 August 2026.

Some of the obligations will be implemented in stages, and detailed implementing acts will set out the methods and formats. This does not mean that companies can sit back and wait. Changing packaging takes time: audits, data from suppliers, material testing, production line trials, label updates, BDO, EPR and, often, discussions with B2B customers.

Example of a mistake: the manufacturer does not plan to redesign the packaging until the end of 2029, and then discovers that the new material requires migration testing, a change of supplier and adjustments to the packaging machine.

How can you avoid making a mistake? Start with a risk map. You don’t need to replace all the packaging straight away, but you do need to know which items are most at risk. That’s exactly what this is for PPWR audit, which enables packaging to be assessed in terms of its design, composition, recyclability and compliance with environmental and legal requirements.

Mistake 4: „That’s the packaging manufacturer’s problem, not ours”

The packaging supplier is an important part of the process, but does not absolve the company of all its responsibilities. If a company places a packaged product on the market, imports products, sells under its own brand, or packs goods for dispatch, it must understand its obligations.

Example of an error: an importer purchases a finished product from a supplier outside the EU and assumes that, since the packaging was approved in the country of manufacture, it automatically complies with the PPWR. This assumption is risky, as EU regulations may require different data, labelling, documentation and an assessment of recyclability.

How can this mistake be avoided? Contracts with suppliers of packaging and products must include requirements regarding material specifications, component weights, recycled content, recyclability, labelling and the updating of data whenever there is a change in material.

Mistake 5: „If the packaging is recyclable, there’s no problem”

The word „recyclable” alone is not enough. The PPWR aims to establish a formal assessment of recyclability, in which the design of the entire packaging unit is taken into account: the predominant material, label, adhesive, colourant, closure, coating, laminate, sortability and the quality of the resulting secondary raw material.

Industry sources describing the PPWR indicate that, from 2030, packaging is to be designed for recycling in accordance with specific criteria, and that, from 2035, large-scale recycling will also be a key factor.

Example of an error: a PET bottle has a body that is theoretically recyclable, but a full sleeve, unsuitable adhesive and dark colourant make sorting difficult. The company promotes the packaging as „recyclable”, even though the entire unit may have a lower recyclability rating.

How can you avoid this mistake? Assess the entire packaging, not just the main material. A good starting point is to analyse the ‘Design for Recycling’ guidelines and the documentation provided by component suppliers.

Mistake 6: „All you need to do is add the recycling symbol to the label”

Labelling does not make up for poor packaging design. The recycling symbol may even increase the risk if it suggests to the consumer an incorrect method of sorting waste or makes an environmental claim that is not backed up by data.

The PPWR provides for the harmonisation of marking and labelling of packaging throughout the product life cycle, including information to facilitate the correct sorting of packaging waste.

Example of a problem: multi-material packaging bears a general recycling symbol, but the consumer does not know whether to separate the components, which bin to put the packaging in, or whether the material is actually recyclable.

How can you avoid this mistake? First, determine the composition and waste stream, then design the labelling. Within the company, the label approval procedure should involve marketing, compliance, quality control and the person responsible for packaging data.

Mistake 7: „BDO, LUCID and EPR will cease to be relevant”

The PPWR harmonises many requirements, but does not automatically remove national registration, reporting and fee obligations. Companies must still analyse the BDO in Poland, LUCID in Germany and other EPR schemes in the countries where they sell their products.

This is particularly important for e-commerce businesses, importers and companies that export packaged goods. EKOPRO points out that an online shop should verify its BDO registration if it stocks packaged products, packs goods for dispatch, imports packaged products, sells under its own brand or uses shipping packaging such as cardboard boxes, envelopes, plastic film and packing materials.

How can you avoid this mistake? Treat PPWR as an EU-level requirement, and BDO, LUCID and EPR as parallel operational obligations. When selling abroad, it is worth making use of compliance with packaging obligations in EU markets and LUCID audit.

Mistake 8: „E-commerce does not produce packaging, so the PPWR does not apply to it”

An online shop may not manufacture cardboard boxes, plastic film or packing materials, but in practice it often puts them into circulation: it packs goods, dispatches parcels, and uses envelopes, labels, tape and security seals. This is precisely why the e-commerce sector should analyse PPWR, BDO and EPR in parallel.

Example of a mistake: an online shop focuses solely on the manufacturer’s product packaging, whilst ignoring the shipping box, packing material, tape and courier label. Meanwhile, the packaging process can result in empty spaces, excess material and additional packaging requirements.

How can you avoid this mistake? Carry out a separate analysis of the shipping packaging. It will be helpful to e-commerce audit and a piece on how to understand Packaging in e-commerce: BDO and LUCID.

Error 9: „A filler solves the problem of empty space”

Filler material protects the product, but it should not be used as a way of disguising an oversized parcel. If a company sends a small product in a large cardboard box and fills the empty space with paper, air cushions or plastic film, the problem remains. Often, it is simply the type of waste that changes.

The PPWR introduces requirements to reduce excessive packaging and empty space, particularly in transport, bulk and e-commerce packaging. The European Commission states that the new regulations are intended to reduce unnecessary packaging, including excessive packaging in online deliveries.

How can you avoid this mistake? Optimise the choice of cardboard box for the product, rather than just the type of packing material. In practice, this means analysing product dimensions, shopping baskets, packaging formats, transport-related complaints and warehouse operations.

Mistake 10: „Reusable packaging is any sturdier type of packaging”

Reusable packaging does not become consistent with the principle of reuse simply because it is durable. It must function within a reuse system: it must be returned, inspected, cleaned, repaired and put back into circulation.

Example of a mistake: a company buys reusable crates but fails to agree on return policies with its customers. After a few months, some of the crates go missing, some remain with customers, and the procurement department orders more. Formally, the company was „reusing” them; in practice, it had created a costly system of wastage.

How can you avoid this mistake? Design the system, not just the packaging. You need data on turnover, packaging ownership, returns, damage, cleaning and settlements between B2B partners.

Error 11: „The PPWR is the responsibility of the environmental protection department”

The environmental protection department can coordinate compliance, but will not implement the PPWR on its own. Decisions regarding packaging are made by the procurement, production, marketing, R&D, quality, logistics and sales departments.

Example of a mistake: the compliance team has identified a risk with the packaging, but the marketing department has already approved the design, the procurement team has ordered a year’s supply, and the production team has tested the format on the production line. Making a change is now costly because it has come too late.

How can this error be avoided? Introduce an approval procedure for new packaging. Any change to the material, label, supplier, format or country of sale should trigger an assessment of PPWR, BDO, EPR, quality and production.

Mistake 12: „We’ll buy the new packaging first, then carry out an audit”

That’s the wrong order. The audit should take place before any purchases are made, as it shows which packaging actually needs to be changed and which simply needs to be better documented or optimised.

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

Example of a mistake: a company replaces all its plastic films with more expensive paper alternatives, only to discover later that the greatest risk lay not in the film, but in the multi-material label, the lack of data on recycled content, and errors in packaging reporting.

How can you avoid making a mistake? First, carry out an audit; then draw up an action plan; next, carry out tests; and only then make any major purchases.

Mistake 13: „ESG declarations are sufficient as proof of compliance”

ESG and PPWR can complement each other, but they are not the same thing. A statement in a sustainability report does not replace the packaging’s technical documentation, data from the supplier, an assessment of recyclability, the proportion of recycled content, or correct labelling.

Example of an error: a company claims to offer „100% eco-friendly packaging”, but has no data on component weights, recyclability assessment results or evidence of recycled content. Such communication can be risky from both a regulatory and a reputational perspective.

How can you avoid making a mistake? Only communicate what can be proven. It is better to make a specific statement such as „we have reduced the weight of the packaging by 18%” than to use a general slogan like „we care for the planet”.

Mistake 14: „The implementation of PPWR is a one-off project”

PPWR is not a one-off initiative. It is a packaging management system. Every new product line, change of supplier, entry into a new market, new label or new sales model may result in changes to the obligations.

How can you avoid this mistake? Put a standard process in place:

1. packaging label,
2. data from the supplier,
3. assessment of recyclability,
4. analysis of recycled material,
5. inspection of signage,
6. BDO/EPR verification,
7. production tests,
8. document archiving,
9. update following a change in material.

In companies with a wide range of products, it is worth combining environmental audit z comprehensive environmental consultancy, as PPWR affects both documentation and operations.

How can PPWR be implemented without making the most common mistakes?

The safest implementation starts with the data, not with the replacement of materials. A company should know what packaging it uses, what it is made of, how much it weighs, who supplies it and in which markets it is used.

1. Make a map of the packaging

Take into account individual, bulk, transport, dispatch, e-commerce, promotional and reusable packaging.

2. Identify high-risk packaging

Start by analysing multi-material, plastic, oversized, export and hard-to-recycle packaging, as well as packaging used in large volumes.

3. Collect documents from suppliers

We require material specifications, component weights, information on recycled content, details of adhesives, labels and coatings, and declarations of conformity.

4. Evaluate the packaging design

Check whether the packaging is designed to be recycled, whether it contains any problematic components, and whether its labelling is misleading.

5. Link PPWR with BDO, EPR and exports

The same data will be needed for several systems. Do not maintain separate, inconsistent tables for different tasks.

6. Introduce a procedure for changing packaging

Any change to the material, supplier, label, weight or sales market must undergo a PPWR assessment.

7. Only communicate confirmed results

Eco-marketing should be based on data relating to: weight reduction, improved recyclability, the proportion of recycled content, or the reuse system in place.

Table: myth and correct interpretation

The myth of the PPWR	Correct interpretation
The PPWR applies only to plastic	Applies to all packaging and packaging waste
Paper is always better	What matters is the actual recyclability and composition of the entire unit
All we need to do is wait until 2030.	Some of the responsibilities begin earlier, and the preparations take months
The packaging supplier is responsible for everything	A company must have the relevant data and its own compliance documentation
The recycling symbol is enough	Labelling must be based on the composition and actual waste stream
BDO and LUCID will disappear after PPWR	The national obligations under the EPR still need to be analysed
An e-commerce business is not a manufacturer, so it has no obligations	Online shops often introduce shipping packaging
Reusable packaging is sturdy packaging	A system for return, inspection and reuse is needed
ESG replaces the documentation	The ESG report is not a substitute for technical data
You can carry out the audit after you’ve done your shopping	An audit should be carried out before any purchasing decisions are made

FAQ - Frequently asked questions

Does the PPWR apply only to plastic packaging?

No. The PPWR covers all packaging and packaging waste, regardless of material or origin. Plastic is a key area of regulation, but the rules also apply to paper, glass, metal, wood, multi-material packaging, transport packaging and e-commerce packaging.

What is the biggest mistake in interpreting the PPWR?

The biggest mistake is to treat the PPWR as simply a matter of replacing plastic with paper. The regulation requires an analysis of the packaging as a whole: its composition, weight, function, recyclability, labelling, recycled content, documentation and sales market.

Can a company wait until 2030 to implement the PPWR?

That’s risky. The PPWR came into force on 11 February 2025 and is generally due to be applied from 12 August 2026, whilst preparing packaging to meet the 2030 requirements involves audits, testing, suppliers, documentation and process changes.

Is the packaging supplier responsible for compliance with the PPWR?

The supplier is an important source of data, but a company placing a packaged product on the market should have its own documentation and verification procedure. Compliance cannot be based solely on a general declaration from the supplier.

Will PPWR replace BDO and LUCID?

No. The PPWR is an EU regulation, but national obligations such as BDO, LUCID and other EPR schemes still need to be analysed. Companies selling in several EU countries should check the obligations for each market.

What is the best way to start implementing the PPWR?

It is best to start with a packaging audit and a risk assessment. Only once data has been gathered on materials, weights, suppliers, recyclability and sales markets is it worth making decisions about redesign, new materials or changes to packaging lines.

Avoid costly business mistakes

Errors in interpreting the PPWR most often stem from rushing and oversimplification. A company should not assume that the problem concerns only plastic, that paper will automatically eliminate the risk, or that simply adding a recycling symbol to the label is sufficient. What matters in the PPWR is the entire packaging unit, the data, the documentation, the process and accountability throughout the supply chain.

Avoid costly business mistakes — go for PPWR audit i Eko-Pro’s professional technical consultancy. You can also go to the tab Contact Eko-Pro and describe their packaging, sales channels and the main points of interpretation.