For much of the past decade, packaging sustainability was dominated by targets.

Reduce virgin plastic.

Increase recycled content.

Make packaging recyclable.

Introduce reusable formats.

Replace difficult materials.

Set a 2025 or 2030 commitment and build a roadmap toward it.

Those commitments have not disappeared.

But the operating environment around them has changed.

In 2026, packaging companies are increasingly being asked to demonstrate something much harder:

Does the package actually work—in regulation, on the filling line, in the recycling plant and on the balance sheet?

That question is changing the role of sustainability inside packaging businesses.

It is moving away from being primarily a corporate ESG commitment and becoming an engineering and commercial specification involving material suppliers, converters, machinery companies, compliance teams, procurement departments, recyclers and finance functions.

Europe’s Packaging and Packaging Waste Regulation is one of the clearest examples.

The UK’s packaging EPR system adds a direct financial consequence to recyclability.

California’s disputed recyclability-labeling rules demonstrate how environmental claims themselves are becoming subject to evidence.

And emerging reuse systems show that designing a durable package is only a fraction of what is required to make reuse work.

Together, these developments point toward a new phase for packaging.

The industry is moving from sustainability by intention to sustainability by verification.

PPWR has moved from a future deadline to a current operating requirement

For years, European packaging teams could discuss PPWR largely as something they needed to prepare for.

That period is ending.

Regulation (EU) 2025/40 entered into force on February 11, 2025, and its provisions began applying from August 12, 2026, replacing the previous Packaging and Packaging Waste Directive with a directly applicable EU regulation.

Not every requirement takes effect at the same time.

Many of the provisions with the greatest effect on packaging design—including mandatory recyclability and minimum recycled-content requirements for plastic packaging—begin from 2030.

But other requirements are already relevant.

From August 12, food-contact packaging containing PFAS at or above specified thresholds cannot be placed on the EU market.

The regulation establishes limits of 25 ppb for an individual targeted PFAS, 250 ppb for the sum of targeted PFAS and 50 ppm for PFAS including polymeric forms under the conditions specified in the legislation. It also maintains a combined maximum concentration of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium in packaging and packaging components.

For packaging manufacturers, that shifts chemical compliance upstream.

A company cannot wait until the finished package reaches the regulatory department and then ask whether it complies.

The ink supplier matters.

The coating formulation matters.

The adhesive matters.

The grease barrier matters.

The polymer additive package matters.

And documentation proving composition increasingly matters.

That changes packaging development.

Compliance is becoming one of the material properties the engineer has to design for.

The package specification is becoming a regulatory document

Historically, a packaging specification might focus heavily on physical performance.

Basis weight.

Thickness.

Seal strength.

Coefficient of friction.

Oxygen transmission.

Water-vapor transmission.

Compression strength.

Print quality.

Dimensions.

Those specifications remain essential.

But the modern packaging specification increasingly needs another layer of information:

polymer composition,

recycled content,

coating chemistry,

adhesive type,

heavy-metal compliance,

PFAS status,

component weights,

recyclability classification,

and potentially evidence explaining how those conclusions were reached.

That creates a fundamental change for converters and material suppliers.

A converter may no longer be supplying only a printed film, carton or pouch.

It may effectively be supplying part of the customer’s regulatory evidence package.

This could eventually become an important competitive distinction.

Two films may deliver equivalent barrier and sealing performance.

But if one supplier can provide reliable composition data, recyclability testing, conformity documentation and market-specific compliance support while the other cannot, the products are no longer commercially equivalent.

The same applies to paper packaging.

A fibre-based format cannot simply be described as sustainable because the substrate is paper.

If it contains a dispersion coating, extrusion layer, wet-strength chemistry, adhesive, window, metallization or plastic closure, those components can influence how the complete package behaves in a recycling process.

Material identity is becoming less important than system performance.

EPR turns design decisions into financial decisions

Regulation does not only restrict materials.

Increasingly, it puts a price on difficult packaging.

The UK’s packaging Extended Producer Responsibility system illustrates the shift particularly clearly.

From the 2026–27 financial year, household packaging waste disposal fees are being modulated according to recyclability under PackUK’s Recyclability Assessment Methodology.

Packaging receives a red, amber or green rating.

Red represents the least recyclable packaging.

Amber carries the base fee.

Green packaging receives a discount funded from the additional amounts charged to red packaging.

The difference becomes progressively larger.

For red-rated packaging, the modulation multiplier is:

1.2 in 2026–27,

1.6 in 2027–28,

and 2.0 in 2028–29.

That means packaging design can now directly influence producer cost.

This changes the conversation inside the company.

A laminate that is difficult to recycle is no longer solely a sustainability concern.

It can become a finance concern.

An unnecessary component is not just additional material.

It may influence EPR exposure.

Changing an adhesive, reducing coating coverage or redesigning a component might therefore affect both environmental performance and the P&L.

This is an important transition.

For years, packaging sustainability teams often had to justify investments through indirect benefits such as brand reputation, carbon reduction or progress toward voluntary targets.

EPR creates a more immediate economic signal.

The waste system is beginning to send part of its cost back toward the packaging specification.

The fee gap could become large enough to influence packaging development

The UK’s illustrative 2026–27 fees show what this can mean in practice.

For paper and board, the illustrative amber rate was £210 per tonne, compared with £250 for red-rated packaging and £190 for green.

For plastic, the corresponding illustrative figures were £455, £545 and £415 per tonne.

For fibre-based composite packaging, they were £525, £630 and £475 per tonne.

These figures have to be treated carefully because fee levels can change as reporting data and scheme calculations develop.

But the direction is clear.

Recyclability is beginning to have an explicit monetary value.

This also means sustainability decisions will increasingly require better cost modeling.

Suppose a converter proposes replacing a difficult multilayer package with a simpler structure that costs slightly more per thousand units.

In the past, procurement might reject that change on material price alone.

Now the correct comparison may also need to include:

EPR fees,

recycled-content obligations,

waste costs,

line efficiency,

package weight,

product loss,

compliance administration,

and future regulatory exposure.

The cheapest package leaving the converter may not remain the cheapest package over its entire regulatory and waste-management life.

This will be especially difficult for multinational packaging portfolios

A second problem follows immediately.

There is no single global definition of recyclable packaging.

A package can encounter different:

collection systems,

sorting technology,

recycling infrastructure,

EPR methodologies,

material classifications,

and environmental-labeling laws

depending on where it is sold.

The Sustainable Packaging Coalition identified this fragmentation as one of the defining issues facing packaging in 2026, highlighting the need to close data gaps and harmonize recyclability assessments and design guidelines.

For a global FMCG company, that creates an awkward possibility.

One package design may perform well in one country’s recycling assessment and poorly in another.

That limits the industry’s desire to create universal global packaging specifications.

The technically elegant solution—a single pack used in dozens of markets—can conflict with local waste infrastructure.

Packaging teams therefore have to decide whether to:

standardize around the strictest market,

create regional specifications,

or maintain multiple variants.

Every option carries cost.

This is why packaging sustainability is becoming an operational issue rather than simply a material-selection exercise.

Recyclability claims themselves are becoming an evidence problem

Another shift is happening in environmental communication.

For many years, companies could describe packaging as recyclable largely because the constituent material could theoretically be recycled.

That assumption is increasingly being challenged.

California’s SB 343 is one prominent example.

The law was designed to restrict the use of the chasing-arrows symbol and other recyclability claims unless the material meets specified collection, sorting and recycling criteria based on California’s waste system.

However, its current legal status requires careful reporting.

On July 14, 2026, a federal court issued a preliminary injunction blocking enforcement of SB 343 while litigation proceeds. CalRecycle continues to perform the underlying material-characterization work required by the law, but enforcement is currently restrained.

That distinction matters.

It would be inaccurate to describe SB 343 today as though enforcement were proceeding normally.

But the policy direction behind it remains relevant.

Governments and regulators are increasingly asking:

Can consumers realistically expect this package to be collected and processed where it is sold?

rather than merely:

Could someone recycle this material under ideal laboratory conditions?

That is a much more demanding standard.

“Technically recyclable” is becoming less valuable

This distinction is particularly important in flexible packaging.

A mono-PE pouch may be technically recyclable through polyethylene-film recycling.

But whether it is actually recovered depends on:

collection,

consumer participation,

sorting,

contamination,

local infrastructure,

and the existence of recyclers willing to buy the material.

Likewise, a fibre-based package may repulp successfully in a laboratory but encounter recycling systems that do not accept its format or cannot economically separate its non-fibre components.

A compostable package faces a similar problem.

Its material properties may allow industrial composting.

That does not matter much if it is sold in a market without collection and industrial composting access.

Sustainability is therefore moving toward a more uncomfortable question:

Not “what can this material theoretically do?” but “what is likely to happen to this package after a consumer throws it away?”

Packaging companies do not control the entire answer.

But they increasingly need evidence that they understand it.

This creates a new data burden throughout the value chain

The physical package is now generating a parallel information requirement.

Brand owners need information from converters.

Converters need information from film, paper, resin, coating, ink and adhesive suppliers.

Recyclability assessors need component weights and material composition.

Compliance teams need chemical declarations.

EPR reporting systems need packaging tonnage and format data.

Recyclers need to know how structures behave in their process.

That means an adhesive that represents less than 5% of package weight can generate disproportionately important data.

So can an ink.

Or a barrier coating.

Or a closure.

A packaging component can be physically tiny while becoming highly significant to compliance.

This will likely favor supply chains capable of maintaining detailed, reliable material records.

The next packaging-management problem may therefore be as much about data architecture as material architecture.

Paper substitution will face more scrutiny, not less

The regulatory shift also complicates one of the industry’s most visible sustainability strategies:

replacing plastic with paper.

Paper and moulded fibre will continue to gain opportunities in packaging.

They benefit from mature collection systems in many markets and strong consumer recognition.

But greater regulatory scrutiny means fibre formats will increasingly have to prove their own performance.

A paper package may require:

grease resistance,

moisture resistance,

heat sealing,

oxygen barrier,

wet strength,

or transparency.

Providing those properties frequently means adding something to the fibre structure.

A coating.

A laminate.

A polymer dispersion.

An adhesive.

A film window.

Those additions can determine whether the package remains compatible with paper recycling.

This makes the simplistic question—paper or plastic?—less useful.

The better question is:

Which structure protects the product using the least unnecessary material while remaining compatible with the recovery system available in that market?

Sometimes the answer will be paper.

Sometimes mono-material plastic.

Sometimes lightweighting an existing package may outperform replacing it entirely.

Sustainable packaging is becoming increasingly application-specific.

The next sustainability filter is the production line

Even a package that performs perfectly in a recyclability assessment still has another test to pass.

It has to run.

A film might look excellent in development but produce an unstable seal window.

A new coating may increase friction and reduce converting speed.

A fibre structure may require additional drying.

A mono-material laminate may have lower stiffness than the structure it replaces.

A thinner bottle may deform during filling or distribution.

A new recycled resin may introduce visual or processing variability.

These are not minor engineering problems.

If a line that normally operates at 300 packs per minute has to be slowed materially to accommodate a new package, the environmental and commercial calculation changes.

More downtime may be required.

More scrap may be produced.

Capital modifications may become necessary.

Production cost can rise.

This is why sustainable packaging has to move from pilot to commercial manufacturing before its performance can really be judged.

A laboratory sample proves that something can be made.

A stable production line proves that a business can make it.

Those are different milestones.

Product protection remains the non-negotiable requirement

Packaging exists primarily because the product needs protection.

That sounds obvious, but it is easy to lose sight of during material-reduction discussions.

A yogurt pouch needs barrier performance.

A pharmaceutical blister requires product stability.

A coffee pack has to control oxygen and moisture.

A detergent bottle must resist chemical attack.

A corrugated box must survive stacking and distribution.

If sustainability changes reduce the package’s ability to perform those functions, product loss can erase part or all of the intended environmental benefit.

This is particularly important in food.

Removing material from a pack while increasing spoilage is not automatically environmental progress.

The engineering objective therefore is not minimum packaging.

It is closer to:

minimum packaging required to deliver the product safely through its intended life cycle.

That is a more difficult target.

It is also a more useful one.

Reuse exposes the difference between packaging and packaging systems

Reusable packaging takes the same logic even further.

A reusable bottle can be beautifully engineered and still fail as a sustainability system.

The package needs to come back.

That requires:

consumer participation,

collection points,

reverse logistics,

sorting,

washing,

inspection,

redistribution,

tracking,

and enough repeat cycles to justify the additional material and logistics involved.

The PPWR puts some of those questions directly into future commercial requirements.

From January 1, 2030, economic operators using specified forms of transport packaging within the EU must ensure at least 40% is reusable within a reuse system.

For certain movements between sites of the same or linked companies, and deliveries between businesses within the same Member State, the regulation imposes a 100% reuse requirement, subject to specified exemptions and subsequent implementation measures.

That is no longer a packaging-design target.

It is a logistics target.

A reusable pallet box that never comes back cannot satisfy the purpose of the system.

The packaging is only one asset inside a reverse supply chain.

One reuse example also shows why real-world trials matter

A useful European example is the Citeo ReUse project.

One correction is important here: this project is in France, not the Netherlands.

Its first phase launched in June 2025 across several French regions, bringing standardized reusable packaging into grocery retail.

One year after launch, the Ellen MacArthur Foundation reported more than 169 products in reusable packaging on shelves, with monthly sales having increased approximately 13-fold from the project’s starting point.

Those numbers are encouraging.

But they are not proof that reuse has already achieved economic or environmental superiority across all applications.

The value of the project is that it allows the industry to study the variables that PowerPoint presentations cannot answer adequately:

How often do consumers return containers?

How many cycles do containers survive?

What does washing cost?

How much transport is required?

How many packages disappear from the pool?

Which formats standardize well?

What does a retailer need to change operationally?

A 2025 study of reusable primary packaging systems similarly found that return rates and scrap rates can be decisive to environmental and economic performance, highlighting how tightly packaging design is connected to reverse-logistics architecture.

This is where reuse becomes engineering rather than ideology.

Sustainable packaging is becoming a qualification process

Taken together, these changes point toward something larger.

Packaging development is beginning to resemble a qualification process.

Before a new format is commercially credible, companies increasingly need to answer several different questions.

Can it protect the product?

Can it run on the production line?

Can it satisfy chemical and packaging regulation?

Can the material be purchased at the required scale?

Can claims about it be substantiated?

Can it pass the relevant recyclability assessment?

Can it be collected in the intended market?

Can recyclers process it?

If reusable, will it return often enough?

And does the total economic case still work?

Failure at any one stage can stop commercialization.

This may make sustainable packaging development slower and more demanding.

It should also make successful innovation more defensible.

The winners may not be the companies with the most sustainability claims

For material suppliers and packaging converters, this creates a different competitive environment.

The strongest supplier may not be the company offering the most novel substrate.

It may be the one capable of proving:

composition,

performance,

compliance,

machine compatibility,

recyclability,

and consistent supply.

For machinery manufacturers, sustainable packaging development increasingly creates a need for wider processing windows, more precise controls and equipment capable of handling changing material structures.

For recyclers, it creates an opportunity to influence package design before materials arrive at the sorting plant.

And for brand owners, it pushes sustainability further into the core packaging-development process.

The silo between sustainability and engineering becomes harder to maintain.

That may be one of the most important changes currently taking place.

2030 is closer than it looks

Many of the biggest PPWR requirements still carry a 2030 date.

That can create a false sense of distance.

Packaging qualification takes time.

A new material may require laboratory evaluation.

Then pilot production.

Then shelf-life testing.

Then machinery trials.

Then supplier qualification.

Then artwork changes.

Then commercial rollout.

For multinational companies, that process can repeat across multiple plants and markets.

A package intended to be compliant in 2030 may therefore need to be under development several years earlier.

The same applies to reuse infrastructure.

Companies cannot create return networks, washing capacity and standardized packaging pools overnight on December 31, 2029.

EPR provides an even nearer financial signal because modulated fees are already being introduced.

The transition is therefore no longer theoretical.

The question has changed

The packaging industry’s sustainability ambitions remain substantial.

Less virgin material.

More recycled content.

More recyclable structures.

More reuse.

Lower emissions.

Less waste.

But ambition is no longer the difficult part.

Execution is.

A decade ago, a company could generate attention by announcing that all of its packaging would become recyclable, reusable or compostable by a future date.

The next generation of packaging leadership will be judged differently.

Can the company document what the package contains?

Can it prove the claim?

Can the converter manufacture it economically?

Can the filling line run it?

Can the product survive inside it?

Can a consumer dispose of it correctly?

Can the recycling or reuse system actually process it?

And can the economics survive all of those requirements at once?

That is why packaging sustainability is entering a more demanding phase.

It is becoming less visible in corporate slogans precisely because it is becoming more deeply embedded in everyday engineering.

The defining question is no longer whether a package sounds sustainable.

It is whether the entire packaging system can prove that it works.

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Last Updated on 15/09/2026 by Jota Machinery