Key pillars shaping the Packaging
2026
• CEN Design for Recycling (DfR) guidelines published as standard
• Proposal for traffic light translation into recyclability score criteria A-D and Eco-Modulation ratio
2028
• Delegate acts to transform CEN DfR guidelines into regulation Packaging assessment will be mandatory Declaration if material is A-D
• Extended Producer Responsibility system will be eco-modulated and based on weight and material type, recycling score (A-C) and Post Consumer Recycled (PCR) content (plastic packaging)
2030* (1 JANUARY 2030)
• All packaging must be designed for recycling (DfR)
• Must have an adequate recyclability score A-C
• Material classified as D will be banned in the EU market
* Primary pharmaceutical packaging, medical devices, diagnostic devices, infant formula, and dangerous goods are excluded
Mandatory Deposit Return Scheme (DRS)
• The DRS is a collection system that can support the reusable targets or the recyclable targets
• By 2029, it will be mandatory to introduce a DRS for single-use plastic bottles and cans
• Member states that may be excluded from this are those that collect more than 80% in 2026, and have a plan for more than 90% in 2028
LABEL IMPACT
DRS Harmonization logo and serialization necessary to identify the reuse cycle
LABEL IMPACT
• Label = Integrated component of packaging
• Label can impact sortability and recycling
• Dependent on the container material + use (single use vs reuse)
Targets for Reuse
Beverages (excludes wine, sparkling wine, spirits, milk and other highly perishable beverages)
The packaging needs to be designed in a reusable format to be collected, cleaned, and refilled
and Packaging Waste Regulation
Calculation of the post consumer recycled content (PCR content) will be done as an average % of packaging type and format, per manufacturing plant, and per year.
PCR Considerations:
PCR content will affect the eco-modulated EPR fee
PCR content can only come from EU or certified by a third party to comply with EU requirements
Exceptions include packaging containing less than 5% plastic or compostable plastic
Harmonized logos guidelines publication
Coexists with identification system CD97/129
Clear logo to identify DRS in compliance with local law
Harmonized logo matching packaging and waste bins National label information will not be allowed
color for DRS packaging
Contact-sensitive PET as major component
Contact-sensitive All other than PET
Non-contact-sensitive All plastics
Single-use plastic beverage bottles SUPD
LABEL IMPACT
If the plastic parts of the packaging unit equal more than 5% of the total weight, PCR is mandatory in the label
LABEL IMPACT
Need for data accessible to customers (supply chain information and disposal/reuse guide)
Use of digital readability (serialization, watermarks, QR, Data Matrix)
Timeline & Milestones
Milestones:
Actions:
Publication of DfR Guidelines as Standard
Draft EcoModulation Fees
Regulation of DfR Guidelines
Eco-Modulation Fees
Deposit Return Scheme (DRS)
D-Classified Products Banned from the Market
New Recyclability Definition
Collecting, Sorting, and Recycling at Scale
Only A and B Packaging will be Allowed
Aug 2026 End 2026 2028 2029 2030 2035 2038
Packaging Declaration of Conformity: PFAs REACH
Analyze Packaging Recyclability
Label Harmonization
Pay Eco-Modulation Fees on Packaging (A-D)
Redesign D Packaging
Dates are based on our understanding of the current proposal and are subject to change dependent on the publication dates of the delegated acts.
Simplify Products & Materials to Ensure Recyclability at Scale
Redesign C Packaging
Packaging and Packaging Waste Regulation is a publication from MCC.
DISCLAIMER: This presentation is based on our understanding of the regulation. It may be subject to change.