The discussions held in March, May and July 2026 provide important insights into how the PPWR will affect packaging design, recycled content, labelling, hazardous substances and the information companies will need to provide about their packaging.

These developments are particularly relevant to the CircSyst project and its packaging-related demonstration activities, especially Demo 9 – Eco-Design Solutions for Food Packaging.

PPWR implementation is becoming increasingly concrete

During the March meeting, the European Commission presented some of the key implementation measures planned for 2026. These include implementing acts on the harmonised labelling of packaging, rules concerning recycled plastic content, and standardisation requests related to industrially and home-compostable packaging.

One of the main topics was the development of a harmonised labelling system for packaging and waste receptacles. The proposal presented by the Joint Research Centre (JRC) foresees a common pictogram system designed to make waste sorting easier and more understandable for consumers.

The discussion highlighted one of the key challenges of PPWR implementation: creating a system that is clear for consumers and supports more efficient waste sorting while also remaining technically feasible and economically proportionate for industry.

 PFAS: regulation is only part of the challenge

Another major topic was the implementation of restrictions on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging.

Under Article 5 of the PPWR, strict limit values for PFAS in food-contact packaging apply from 12 August 2026. However, the practical enforcement of these limits remains challenging.

The Commission highlighted that harmonised testing methodologies are still being developed and that laboratory capacities may also be limited. A dedicated PFAS Task Force has therefore been established to develop a common sampling and testing methodology.

This issue was taken further during the May meeting, when the Commission presented a draft methodology developed by the Task Force. A key principle is the use of a risk-based approach by manufacturers. This may include verifying supplier declarations, identifying potential contamination sources and carrying out appropriate laboratory testing.

The methodology is expected to remain a “living document”, allowing it to evolve as new analytical methods and implementation experience become available.

Recycled content and European recycling capacity

Recycled plastics, and particularly recycled PET (rPET), were another important focus of the discussions.

According to information presented by the Commission, current European mechanical recycling capacity, together with planned investments, could be sufficient to meet the 2030 targets.

The analysis also indicated that the additional cost of using 30% EU-produced rPET, compared with imported recycled PET, could amount to only around EUR 0.001 per bottle.

The May discussions also clarified that the recycled content requirements under Article 7 of the PPWR apply to any plastic component of packaging, not only to packaging made entirely from plastic.

This clarification is particularly important for multi-material packaging solutions and for companies redesigning their packaging portfolios in preparation for future PPWR requirements.

Recyclability and packaging minimisation

The Commission also provided further clarification on recyclability and packaging minimisation.

Until the new PPWR-specific requirements and standards become applicable, existing standards may continue to provide guidance on recyclability. Similarly, the current packaging minimisation standard will remain relevant until 2030 while preparations for a new standard are already underway.

For companies, this means that compliance with the PPWR will increasingly require packaging decisions to be considered from several perspectives simultaneously: material choice, recyclability, recycled content, hazardous substances, packaging minimisation and end-of-life management.

July meeting: PPWR moves into practical implementation

The fifth meeting of the Expert Group on Waste took place on 1 July 2026, at a particularly important moment, shortly before most PPWR provisions became applicable on 12 August 2026.

The Commission explained that the implementation of the PPWR requires a substantial number of supporting measures, including 11 implementing acts, four delegated acts, three mandatory guidelines and three standardisation requests, in addition to reporting and evaluation activities.

The implementation plan also foresees the creation of a new Reuse Observatory, reflecting the growing importance of reusable packaging systems within the EU packaging framework.

For the third quarter of 2026, Commission priorities include the PFAS protocol, standardisation requests for industrial and home composting, and measures concerning harmonised registration and reporting under Extended Producer Responsibility schemes.

Further rules on labelling, the calculation and verification of recycled content and sustainability criteria for plastic recycling are expected to remain major priorities towards the end of the year.

PFAS testing: important practical questions remain

The July meeting confirmed that work on the harmonised PFAS testing protocol is continuing.

Stakeholders raised several practical questions, including how food-contact packaging should be defined in specific situations, how sampling strategies and testing frequencies should be established, what analytical methods should be used, and what documentation manufacturers will need to provide.

Particular attention was also given to multi-layer and multi-material packaging, where identifying and testing potential PFAS contamination may be considerably more complex.

These discussions demonstrate that compliance will increasingly depend not only on packaging materials themselves but also on documentation, supply-chain information and appropriate testing strategies.

A new focus on harmonised packaging labelling

Labelling under Articles 12 and 13 of the PPWR was another central topic of the July meeting.

The consultancy Ramboll, working on behalf of the European Commission, presented proposals for both physical and digital labels.

The physical labelling concepts covered reusable packaging, packaging covered by Deposit Return Systems, recycled plastic content and bio-based plastic content. Digital labelling concepts were also presented for reusable packaging, recycled and bio-based plastic content, substances of concern and waste-sorting information.

The proposals presented in July were still under development and did not represent the final position of the European Commission.

Nevertheless, they provide a strong indication of the direction in which packaging information requirements may evolve.

Digital information could become a key part of circular packaging systems

One of the most significant developments is the growing role of digital information associated with packaging.

Digital labels could provide information about recycled plastic content, third-party certification, bio-based content, substances of concern, reuse systems and waste-sorting instructions.

For reusable packaging, digital systems could also provide information on collection points, reuse schemes and return rates.

However, the analysis also highlighted an important technical challenge: there is currently no single digital carrier capable of optimally serving both consumer information needs and the tracking requirements of reusable packaging in a B2B environment.

For this reason, different technologies, including QR codes, Data Matrix, RFID and NFC, are being considered.

Why does this matter for CircSyst?

The work of the Expert Group on Waste is directly relevant to the CircSyst packaging demonstrations, and especially to Demo 9 – Eco-Design Solutions for Food Packaging.

Demo 9 explores practical solutions that can reduce the use of non-recyclable polymers while maintaining packaging functionality and product safety. The increasingly detailed PPWR implementation rules therefore provide an important regulatory and technical framework for the demonstration.

They also have direct relevance for the ecodesign guideline to be developed within CircSyst by the end of the project.

Based on the discussions taking place at EU level, such guidance will need to consider not only recyclability, but also material composition, recycled content, packaging minimisation, hazardous substances such as PFAS, labelling requirements, digital information and appropriate end-of-life management.

The Expert Group discussions therefore provide more than regulatory background for CircSyst. They help identify the practical requirements that companies will increasingly need to address when designing and placing packaging on the European market.

Through its demonstration activities, CircSyst can contribute to translating these evolving regulatory requirements into practical, industry-oriented solutions and recommendations.

As PPWR implementation progresses, this connection between policy, technology and real-life demonstration will become increasingly important. The project’s future ecodesign guideline can therefore help companies not only respond to current regulatory requirements, but also prepare for the way those requirements are likely to be applied in practice.