What the Packaging & Packaging Waste Regulation means for deposit return schemes

The European Union has voted into law the new Packaging & Packaging Waste Regulation (PPWR). Bilyana Ignatova, VP Public Affairs and Head of EU Policy at TOMRA, walks through the new regulation, and how it impacts deposit return systems (DRSs) for drink container recycling.
Packaging waste is a global issue, contributing to a substantial portion of the world’s waste. In the European Union, an estimated 84.3 million tonnes of packaging waste produced in 2021. Plastic packaging is particularly problematic, as it represents about 40% of all plastic waste globally.
These staggering figures highlight the urgent need for effective waste management strategies and increased recycling efforts to mitigate the environmental impact of packaging waste.

What is the Packaging & Packaging Waste Regulation?
The Packaging & Packaging Waste Regulation (PPWR) is legislation that revises the previous rules around packaging and package waste across the European Union’s 27 member states. The regulation considers packaging’s entire life cycle, from its design to its post-consumer recovery, setting enforceable targets.
“The PPWR aims to reduce the environmental impact of packaging, and boost high-quality recycling and the circular economy. It harmonizes rules across the EU to create a level playing field for producers, waste management companies and other stakeholders,” shares Bilyana Ignatova. “The PPWR will be the most transformational piece of legislation for the packaging sector in the last 30 years, setting wide-ranging requirements and enablers for packaging circularity.”
The PPWR evolved out of, and replaces, the EU Packaging & Packaging Waste Directive (PPWD). Introduced in 1994, the PPWD also set targets for packaging waste recovery. The directive was reviewed approximately every five years. 2020’s European Green Deal (policy initiatives to make the EU climate neutral) triggered the most recent revision of the PPWD, which was becoming untidy: as well as seeing higher waste generation, the EU “single market” had been fragmented by a wide range of national solutions, making it difficult for brands and producers to navigate different national rules. In November 2022, the European Commission proposed an EU regulation to replace the directive.
The PPWR is an outcome of the previous Green Deal era, and heralds the shift from a previous mandate to a new mandate.

So, what exactly is the difference as rules for packaging waste move from a directive to a regulation? A directive is a legal act that sets a goal, which means member states can devise their own laws on how to achieve the goal, whereas a regulation is a binding legal act that can also specify the means to achieve the goal. Directives must be transposed into national laws, while regulations apply simultaneously across all of the EU.
The PPWR also builds upon the EU’s Single-Use Plastics Directive (SUPD), which focuses on waste from plastic products. The PPWR expands on the targets set for the SUPD, and adds a number of new obligations. While the PPWR replaces the PPWD, the SUPD continues to stand independently.
Packaging & Packaging Waste Regulation and deposit return schemes
Collection targets
The SUPD required 77% of all single-use plastic beverage bottles to be separately collected (that is, not including containers extracted from mixed waste) by 2025, and 90% by 2029. The PPWR retains those obligations, while adding metal beverage cans to the 2029 target. It also adds a requirement that member states set up a deposit return system (DRS) by 2029 to achieve those targets.

A deposit return system, also called a deposit return scheme or container deposit scheme, incentivizes the return of drink containers for recycling – by charging a deposit when a drink is purchased, and refunding it when the empty container is brought back. “Adding a financial value to the used container motivates people to return them, and communicates that materials also have a value to society as a resource,” describes Bilyana Ignatova. “High-performing DRSs achieve collection rates over 90%, and experts stated it would be difficult to impossible to achieve the SUPD’s targets without a DRS.”
The PPWR also considers the scope for these DRSs. The DRS should span drinks in plastic or metal containers up to three liters in size, but member states can exempt those under 0.1 liters. Member states should also endeavor to include glass and drink cartons in their DRS, and packaging made of other materials (or packaging for other products) may be included. The PPWR allows an exemption for milk and wine, but member states can include them if they wish.
The minimum requirements for DRSs set out in the PPWR include:
- A non-profit, independent system operator for the administration of the DRS (or ensured coordination in case of multiple operators).
- Data collection procedures for control.
- A deposit/refund value set at a sufficient level to motivate consumer returns to achieve the 90% collection target.
- A percentage of annual DRS revenues re-invested into public awareness campaigns on the DRS.
- Final distributors (stores selling drinks to the public) having an obligation to take back the empty containers.
- Consumer opportunity to return containers and redeem their deposit without the need to purchase goods at the final distributor.
- All deposit-eligible containers clearly labelled as such.
- Regions with high transboundary/border business allowing return of packaging from other member states’ DRSs, and endeavoring to enable refunding the deposit on those returns.

Newly established DRSs will need to meet these minimum criteria. Member states may be exempted from setting up a DRS if they can achieve an 80% separate collection rate by 2026, and if they by 2028 submit a plan showing concrete actions and a timeline for how they will reach 90% by 2029. However, the exemption is cancelled if collection falls below 90% for three consecutive years. Existing DRSs should aim to meet the minimum criteria when they are first reviewed, but can be exempted if they achieve the 90% separate collection target by 2029. Otherwise, they need to comply with the criteria by 2035.
Recycled content targets
The separate collection of drink containers, which keeps the material stream “pure” and of high enough quality that it can be used again for food storage, means the materials can be used as recycled content in new drink containers – in what TOMRA calls Clean Loop Recycling.
Under the SUPD, there was a 2025 target for 25% recycled content in single-use plastic beverage bottles, rising to 30% by 2030. The PPWR extends upon these by adding a target of 65% recycled content by 2040. The SUPD gave responsibility for achieving these targets to member states under the SUPD, but the PPWR assigns it to economic operators (ie, beverage producers), and makes the targets the average across the operator’s portfolio rather that the average across the member state’s territory.

"Assigning responsibility for recycled content to beverage producers as economic operators gives them greater ownership and accountability around the production of their own packaging, and also makes most sense in terms of traceability and implementation,” explains Bilyana Ignatova.
Reuse for beverage packaging
The PPWR also encourages including reusable beverage bottles in DRS collection infrastructure established for single-use drink packaging. The regulation states that any DRS for single-use beverage containers should be equally available for reusable containers, and return points for reusable packaging should be equally as convenient.
It also says at least 10% of beverages placed in the market should be in reusable packaging and a system of reuse from 2030, endeavoring to reach 40% by 2040. These targets, however, do not apply to highly perishable beverages, milk and milk products, wine or spirits.
Beyond drink containers: Other targets and timelines for the Packaging & Packaging Waste Regulation
The PPWR is far broader, however, than drink containers and deposit return systems. “The PPWR means truly being part of something bigger: the regulation is pioneering in setting concrete quantitative targets on the highest levels of the waste hierarchy, across the board for all packaging,” explains Bilyana Ignatova. “This includes targets to prevent the generation of packaging waste, requirements for all packaging placed on the EU market to be recyclable (both by design and in practice), and targets for recycled content.”
As such, the PPWR creates a number of new obligations for different packaging materials beyond drink containers. It also applies many of those obligations to economic operators and not solely the member states themselves.

The EU has mechanisms if member states or economic operators do not comply with the targets, as an incentive to ensure these activities are implemented. Member states can face financial penalties reflecting the country’s inflation, population and gross domestic product. Penalties for economic operators include fines and prohibiting/recalling packaging that does not comply.
Legislation accelerating a shift
The new PPWR marks a meaningful step forward in addressing packaging waste, by setting enforceable targets for recovery and promoting high-quality recycling across the European Union. By harmonizing rules and mandating deposit return for drink containers, the PPWR aims to reduce the environmental impact of packaging waste and foster a circular economy. It not only builds on previous legislation but also introduces new obligations, ensuring a more cohesive and effective approach to managing packaging waste. The PPWR will play a crucial role in mitigating waste and advancing sustainability efforts within the EU.
“The Packaging & Packaging Waste Regulation is a decisive and much-needed step towards packaging circularity and sustainability. This legislation promotes a change in perspective among governments, businesses, and consumers regarding packaging waste, ensuring more valuable materials remain within a closed-loop system and are kept out of the environment, landfills and incinerators.

Learn more about the Packaging & Packaging Waste Regulation

Unpacking the EU’s new packaging regulation: A turning point for packaging

Recycled content targets: What the PPWR means for packagings future
