The PPWR is a key regulation proposed by the European Union aimed at reducing packaging waste and the environmental impact of packaging. The adoption of the PPWR as a regulation highlights the E.U.’s commitment to ensuring faster and more consistent implementation of sustainability standards across all Member States. It reduces administrative complexity and provides clear, unified rules for businesses and governments, ensuring everyone works toward the same environmental goals.
The European Commission formally proposed the PPWR on 30 November 2022, setting the essential requirements for the packaging materials to which all packaged products must adhere. Establishing uniform rules across all E.U. Member States, the PPWR replaces the Packaging and Packaging Waste Directive (PPWD) (Directive 94/62/EC), modernising and strengthening the framework to meet today’s environmental and market challenges.
These are the overarching goals of the PPWR:
Latest Changes
Afera’s advocacy on process films was successful: The European Commission will clarify in its FAQ that such films used during manufacturing are not packaging.
On release liners, uncertainty remains. Some Member States already classify RL as packaging, and the Commission may follow. Afera, FINAT and CELAB, with support from consultancy FleishmanHillard, are preparing a joint position paper. Two drafts have circulated, evolving from a direct advocacy approach to a focus on clarifying supply chain complexity and the technical function of RL. Mondi provided input from a legal assessment, and a schematic of the supply chain was developed. The aim is to finalise the paper next week and submit it before the Commission’s FAQ, expected in October.
Afera has produced draft DfR guidelines including decision trees to determine whether tapes are packaging and, if so, their recyclability requirements.
Afera are active participants in CEN TC261/WG3/SG2 discussions. Current debates focus on paper recycling processes: conventional pulp/cardboard, liquid packaging, laminated papers and de-inking processes — the latter potentially relevant for siliconised release liners.
A red/yellow/green classification is being developed: green = recyclable, yellow = acceptable with penalties, red = non-recyclable. Items not covered will require testing with annual updates of the tables foreseen. A new draft will be circulated to CEN participants on 22 September, with a final draft version expected by year-end.
Advocacy on process films
PPWR – advocacy on process films Mr. Englebienne reported on a 7 May 2025 meeting with European Commission officials, where it was confirmed that films used solely for protection during manufacturing processes do not qualify as packaging under PPWR. This important clarification, though not included in Annex I of the legal text, is expected in an upcoming Commission FAQ. The publication date is not fixed but is anticipated later in 2025.
Release liner advocacy
Afera, together with FINAT and CELAB, is advancing a joint initiative to clarify the regulatory status of release liners under PPWR. There is significant uncertainty as some Member States classify them as packaging, while others do not. Mondi is providing a legal review and FleishmanHillard is supporting advocacy efforts. A task force meeting is planned for 8 July 2025, and Members were encouraged to volunteer. The initiative’s objective is to secure regulatory clarity even if consensus is not achievable at the E.U. level.
Design for recycling (DfR) guidelines
Afera is contributing actively to the CEN TC261/WG3/SG2 drafting process on paper packaging design for recycling (DfR) guidelines. Its draft internal guidance includes a decision-making workflow to determine whether tapes are packaging and, if so, their recyclability requirements. The workflow accounts for packaging type (sales, group, transport, e-commerce), whether the tape is a standalone item or integrated component, and the primary material determining the appropriate recycling stream. Examples include carton-sealing tape on cardboard boxes (paper stream) and reclosure tabs on plastic pouches (plastic stream). Finalisation of this guidance is expected later in 2025.
Detailed information
For the adhesive tape industry, the PPWR has several important implications:
Sustainability and recycling requirements
Adhesive tapes used in packaging must meet stricter recyclability criteria. This means adhesive tapes used in packaging must be designed to not hinder the sorting and recycling of the packaging waste streams.
Recycled content mandates
The regulation imposes minimum recycled content requirements for plastic components of packaging, which may affect packaging tapes. Adhesive tape manufacturers will need to incorporate post-consumer recycled plastics where necessary.
Reduction of excess packaging
Tapes must align with efforts to reduce unnecessary packaging waste, potentially influencing design considerations such as adhesive strength, size, and efficiency. The shift toward lightweight and high-performance tapes may become critical as companies aim to meet waste reduction goals without compromising functionality.
Labelling and reporting
Packaging materials will be identified in a harmonized way to facilitate their recycling. Suppliers of packaging tapes will need to provide their customers with information on sustainability to fullfill the reporting requirements.
Cross-sector collaboration
PPWR emphasises the importance of collaboration across the supply chain, meaning adhesive tape manufacturers must work closely with packaging producers, recyclers, and end-users to ensure compliance and optimise recycling systems.
As of January 2025, the PPWR has been officially adopted by the European Union. The regulation was published in the Official Journal of the European Union on 22 January 2025 and entered into force on 11 February 2025. Its general application will commence 18 months after this date, around August 2026, with certain provisions having longer transition periods.
While the core Regulation has been approved, the measures will only be implemented according to several reports and secondary pieces of legislation.
Where are we now?
December 2025: Deadline for draft DfR guidelines, which are currently being discussed by two working groups in CEN (European Committee for Standardisation): CEN TC261/SC4/WG10 plastic packaging and CEN TC261/SC4/WG3 for the other packaging materials. Afera participates of CEN discussions.
By 2026: ECHA will prepare a report on Substances of concern for packaging. This means substances that are hazardous for human health or the environment or that hinder recycling. The report is expected to build on the negative list from an earlier draft of the legislation.
6 December 2024: Under the PPWR, it is ultimately the responsibility of the manufacturer of the packaged product to ensure packaging is compliant with PPWR requirements. Suppliers of packaging material must provide manufacturers with necessary information to ensure compliance. This document, a common position of the European adhesive tape and film industry grouped under Afera, aims to clarify the status of adhesive tapes and films within the PPWR for our entire supply chain, including for users of adhesive tapes.
July 2025: Afera’s PPWR taskforce within the Regulatory Affairs Working Group has developed a concise, user friendly guidance document featuring decision trees to help manufacturers and converters interpret the PPWR as it pertains to adhesive tapes and films. This document simplifies regulatory classification and helps companies determine whether their products are considered “packaging”—and what compliance obligations apply if they are.
Adhesive films marketed as “surface protection products”, “process films” and “protective films” make up the biggest grey area in the definition of packaging. This document will also serve as the starting point for drafting a decision tree for the Afera Design for Recycling (DfR) Guidelines which the RAWG is working on.
Businesses involved in packaging within the E.U. should prepare for compliance by reviewing the regulation's requirements and planning necessary adjustments to their packaging processes and materials. Afera’s aim is to translate the PPWR for the adhesive tape industry so that it is aware of what the regulation will mean in the packing of the own product, regardless of whether it is considered packaging or not. Afera Members need to learn how to follow DfR criteria, i.e. what types of packaging are prohibited from use. They also need to understand the requirements of imported products and how fair competition can be ensured between European and imported products. Afera is working to provide valuable feedback to legislators in these areas.
23 April 2023: Based on input from our Members, Afera submitted 
