MCC PPWR Overview - Updated April 2026

Packaging and Packaging Waste Regulation (PPWR)

PUBLISHED APRIL 2026

Key pillars shaping the Packaging 2026

LABEL IMPACT

• CEN Design for Recycling (DfR) guidelines published as standard • Proposal for traffic light translation into recyclability score criteria A-D and Eco-Modulation ratio

• Label = Integrated component of packaging • Label can impact sortability and recycling

2028

• Dependent on the container material + use (single use vs reuse)

• 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)

Recyclability

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)

Packaging waste reduction

• 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

Targets for Reuse

2030

2040

>10%

>40%

Beverages

LABEL IMPACT DRS Harmonization logo and serialization necessary to identify the reuse cycle

(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

2030 Contact-sensitive

PET as major component

Recycled content in plastic packaging

50%

Contact-sensitive All other than PET

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

30%

2040

Non-contact-sensitive All plastics

Single-use plastic beverage bottles

10%

35%

30%

25%

65%

65%

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 Harmonization

2026

Harmonized logos guidelines publication Coexists with identification system CD97/129 Clear logo to identify DRS in compliance with local law

2028

Harmonized logo matching packaging and waste bins National label information will not be allowed

2029

Harmonized color for DRS packaging

2030

Label/QR code on packaging reusability use and composition

* Dates are based on our understanding of the regulation and are subject to change

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

Aug 2026

End 2026

Packaging Declaration of Conformity: PFAs REACH

Regulation of DfR Guidelines

Deposit Return Scheme (DRS)

D-Classified Products Banned from the Market

New Recyclability Definition

2029

2030

2035

Eco-Modulation Fees

2028

Analyze Packaging Recyclability

Pay Eco-Modulation Fees on Packaging (A-D)

Label Harmonization

Redesign D Packaging

Collecting, Sorting, and Recycling at Scale

Simplify Products & Materials to Ensure Recyclability at Scale

2038 Redesign C 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.

For more information or additional guidance, please contact sustainability@mcclabel.com

Packaging and Packaging Waste Regulation is a publication from MCC. D ISCLAIMER: This presentation is based on our understanding of the regulation. It may be subject to change.

Only A and B Packaging will be Allowed