Packaging regulation moves from policy to practice as EPR requirements accelerate

Companies operating across global markets will need to rethink packaging strategies as new producer responsibility rules reshape compliance, procurement and demand for recycled plastics materials. Duncan MacRae reports.

Packaging regulations are moving rapidly from policy discussions into operational challenges for businesses, with companies facing new requirements around documentation, recycled content, recyclability, and Extended Producer Responsibility (EPR).

These were among the key themes discussed during Trioworld’s Policy to Practice webinar series, which examined how packaging regulation is developing across Europe and North America.

With European manufacturers required to complete formal compliance assessments and hold documentation demonstrating compliance with the EU Packaging and Packaging Waste Regulation (PPWR) by August 2026, businesses are now being urged to understand how the new rules will affect their responsibilities.

Lena Lundberg, public affairs and regulatory director at Trioworld, a producer of high-performance plastics films and sustainable packaging solutions, explained that the PPWR represents a shift away from the fragmented approach created by previous European legislation.

Earlier packaging waste rules were implemented through national legislation, creating different systems, labelling requirements and definitions across EU member states.

“This has created administrative burdens for companies operating across different member states,” Lundberg said during the webinar.

The PPWR aims to create a more harmonised framework across the European Economic Area, allowing businesses to work with common packaging design, labelling and compliance requirements.

However, while the regulation will introduce greater alignment, it will not replace national EPR systems entirely. “It will not replace, but it will harmonise the schemes in very important ways,” Lundberg explained.

Collection systems and fee levels will continue to vary between countries, reflecting differences in national infrastructure and market conditions.

Understanding producer responsibility

One of the most significant changes under PPWR is the introduction of a harmonised definition of producer responsibility.

Previously, individual member states were responsible for defining who qualified as the producer, resulting in different interpretations across markets.

Under PPWR, the regulation seeks to clearly identify one producer per packaging unit. Lundberg said companies will need to analyse their responsibilities carefully, particularly those operating across multiple countries.

A key challenge is understanding whether responsibility sits with the company placing packaged products on the market or with the supplier of empty packaging.

stretch film in warehouse
Stretch film does not become packaging until it has been applied around a pallet

The distinction depends on the type of packaging involved. Sales and group packaging become packaging when filled, while transport packaging becomes packaging when it reaches its final format.

For example, stretch film does not become packaging until it has been applied around a pallet. This distinction will be important for companies assessing their obligations under EPR schemes.

Different approaches across the Atlantic

While Europe is moving towards greater harmonisation, the United States is developing EPR legislation through individual states.

Crystal Bayliss, interim executive director of the US Plastics Pact, highlighted that EPR legislation has now been passed in seven US states, with further states examining potential approaches.

The differences between states reflect variations in political priorities, existing infrastructure and local conditions.

Bayliss explained that some states are focused on reducing plastics waste for environmental reasons, while others are addressing issues such as landfill capacity and waste management costs.

Although the approaches differ, the result is increasing pressure on companies to manage a more complex regulatory landscape.

California has become a particular focus because of the scale and ambition of its legislation.

By 2032, California’s rules require 100 per cent of plastics packaging to be recyclable or compostable, a 25 per cent source reduction target for plastics packaging and a 65 per cent recycling rate for single-use plastics packaging.

Transport packaging, including stretch film, is included within the scope.

Bayliss said companies are prioritising California because of its size, its deadlines and the impact compliance could have on future regulatory approaches.

“If you’re compliant in the state of California, it sets you up well for success in other states,” she said, while noting that requirements still differ between jurisdictions.

Closing the recycled content gap

One of the biggest challenges highlighted during the webinar was the need to create stronger demand for recycled plastics materials.

Bayliss warned that improving collection and sorting systems alone will not deliver higher recycling rates unless there is sufficient demand for recycled content.

plastic bottle collection
Improving collection and sorting systems alone will not deliver higher recycling rates, according to Bayliss

“You cannot just assume that because it got collected and sorted and sent to the recycler, that it is going to get bought and put into a new product,” she said. “If there is not a demand pull there, you will not hit your recycling rate requirements.”

She said several plastics film reclaimers had closed during 2025 amid weak demand for recycled content, raising concerns about the long-term viability of recycling systems.

For recycling targets to be achieved, companies placing packaging on the market will need to actively purchase recycled materials and support the development of end markets.

Bayliss suggested recycled content requirements could become more common as governments assess whether current incentives are strong enough to drive demand.

“Folks respond to what they’re incentivised to do,” she said.

From compliance to packaging strategy

The webinar also examined how regulations are changing the way companies approach packaging design and procurement.

Drew White, technical product and training specialist at Trioworld, argued that businesses need to move away from viewing packaging decisions purely through the lens of purchase price.

Instead, companies should consider the total cost of ownership and how different elements of a packaging system work together.

He highlighted lightweighting as one potential approach, explaining that high-performance packaging materials can allow companies to reduce material use while maintaining performance.

However, he said packaging decisions should not be made in isolation. The focus, instead, should be on total cost and on system optimisation.

This approach requires greater collaboration between procurement teams, packaging engineers, sustainability teams and other functions involved in packaging decisions.

A global packaging challenge

The webinar highlighted that companies can no longer approach packaging compliance market by market in isolation.

While regulatory systems are developing differently across Europe and North America, the overall direction is similar: greater accountability for packaging placed on the market, increased demand for recyclable designs and a stronger focus on circularity.

For businesses, preparing for these changes will require better data, clearer understanding of responsibilities and packaging strategies that consider compliance alongside performance, supply continuity and cost.

As Bayliss concluded, companies need to think beyond collection and recycling infrastructure alone.

Without demand for recycled plastics materials, the circular economy cannot function.

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