The EU is on track to apply new packaging rules before the end of the summer. What does it mean to consumers, and what will change for businesses offering packaged baked goods?
On August 12, the EU Regulation 2025/40 on packaging and packaging waste, known as PPWRi, will be applied. It aims at leveling the ground with common rules on packaging across the EU. To help simplify compliance efforts, the European Commission issued guidance to help Member States implement the provisions of the law, bringing clarity to the regulation where needed (but not changes)
For bakeries offering packaged goods and products wrapped for consumption, this means the transition to easily recycled solutions is urgently underway. Challenges include paper containers with film windows or composite trays – with a clear trend for packaging solutions made of mono-materials or designed in a way that allows different materials to be easily separated. Labeling is also subject to change in 2028, as packaging must carry information about its materials and how they should be recycled, in addition to the information about the product enclosed.
Consumers add to the pressure to switch to more sustainable packaging choices, too. Extensive surveys carried out by ERM Shelton, a marketing and communication company specializing in packaging sustainability, show that, when given a list of different environmental issues, people have ranked plastic in the ocean as their greatest climate concern, every single time they were asked, everywhere in the world, says Suzanne Shelton, the company’s founder. Moreover, when asked to assess their position regarding other issues, including inflation or war, plastic in the ocean is among the top three concerns, in every country surveyed.
Shelton explains the reasoning behind this perception: “Plastics and packaging are key issues for the consumer. While climate change is the more existential threat and arguably the bigger issue, people are more concerned about waste and specifically plastics. We believe it’s because it is tangible: people can see it, and perceive themselves as accomplices to the crime when they see animals affected by plastics in nature. And they feel guilty as they wonder if it was, perhaps, their beer ring or bread bag that hurt a cute sea creature, for example.“ At the same time, consumers, unsure how to solve this issue by themselves, look to companies to solve this problem. To add another layer to the issue, consumers are often confused about how and what to recycle in the absence of transparent communication regarding the available infrastructure – in different countries and cities, with different rules applied even to different areas of a city.
“People have a false sense of security that they know how to recycle. ”
Suzanne Shelton, founder, ERM Shelton
ERM recently surveyed US consumers in partnership with the Flexible Film Recycling Alliance for a study that set out to understand why people do not recycle their flexible plastics more, and how they could be motivated to do so. The research found that 70% of people in America claim they regularly recycle at least one type of flexible plastic; but only about 5% of them are actually recycled, according to statisticsii. And, although almost everyone claims they know what they are (91%), only about 6% of the US consumers can actually describe them correctly, which explains the low recycling rate.
“People have a false sense of security that they know how to recycle,” she adds, when over 70% of US consumers state they know everything about how to recycle correctly. In reality, the category of people who are conscientious recyclers is fundamentally confused about what counts as correct recycling, for their efforts to have the intended results. Around 35-40% of the American population is interested in educating themselves, according to the researchiii. One issue is the lack of consistent language: what is flexible packaging? What is plastic packaging? What are plastic films? And, once identified, what kinds of plastic can be recycled?
Since PPWR was introduced, manufacturers have come forward with questions of their own. They need to make packaging easy to recycle for consumers, include an information component, and comply with the regulations. While ‘flexible plastics’ is without a legal, universally applied definition, looking at this example, PPWR does offer a working interpretation of what they encompass: non-rigid plastic in shape, film-like in thickness, and easy to bend while holding products, including pouches, bags and wrapping materials.
The newly released guidance and its Annex offer clarity and necessary definitions to help with uniformity in packaging sustainability efforts.
Mono-materials
An essential packaging principle to aim for is mono-material packaging, made predominantly of a single type of material, with minimal additions such as inks, according to the PPWR. Mono-materials make sense because they simplify recycling for the consumer. Adequate labeling – recyclable in itself – communicates clear disposal instructions and contributes to easier recycling.
“The packaging choice comes down to following design guidelines that take into consideration what will be most recyclable from what is
available. The material itself is one choice, and so is the way it is modified, from the inks to the colors and labels associated with it. ”
Viktoria Pakhnyuk, PhD, Sustainable Product Development Manager,
Kwik Lok
Identifying the best material choice starts with its core functionality, maintaining product freshness. An important variable also plays a key role here – sustainability practices active in each region.
“The packaging choice comes down to following design guidelines that take into consideration what will be most recyclable from what is available. The material itself is one choice, and so is the way it is modified, from the inks to the colors and labels associated with it. Every aspect is taken into consideration in the design,” explains Viktoria Pakhnyuk, PhD, Sustainable Product Development Manager at Kwik Lok. Dedicated organizations assess what kind of packaging is best for recycling after use, offering practical resources. For instance, the American Forestry and Paper Association and the European 4evergreen Alliance provide design guidance for paper packaging, while the North American Association of Plastic Recyclers and RecyClass in Europe focus on plastic packaging. The Consumer Goods Forum also provides useful documentation shaping the Golden Design Rules, aligning and implementing them for plastic packaging. In addition, the Plastic Pacts network and other NGOs can also help bakeries understand their options, with well-documented, science-based reference data.
PPRW timeline
PPWR provisions
+ ‘All packaging placed on the market shall be recyclable.’ (Art. 6.1)
+ ‘Packaging shall be considered to be recyclable if it fulfils the following conditions (Art 6.2):
• it is designed for material recycling
• when it becomes waste, it can be collected separately, sorted into specific waste streams without affecting the recyclability of other waste streams and recycled at scale
European Commission’s interpretation:
+ Article 6(1) requires that all packaging placed on the market is recyclable without providing a specific deadline for the application of this provision, which means that it applies from August 12, 2026.
+ Article 6(2)(a) ‘shall apply from January 1, 2030, or 24 months from the date of entry into force of the delegated acts adopted pursuant to the first subparagraph of paragraph 4, whichever is the latest’. According to Article 6(4), this delegated act, which will fully harmonize design for recycling requirements and the related assessment methodology, should be adopted by the EC by January 1, 2028.
In Europe, the PPWR brings a suite of measures ambitiously aimed at transforming packaging entirely, rather than imposing stricter recycling rules. What does this mean for bakeries operating in both markets (and beyond)? Regulations are already overlapping, to a certain extent, which helps businesses manage production and supply across production facilities worldwide. And efforts will be made to align them even more, to avoid them even more, complicating international operations.
Regulations such as the PPWR aim to guide and narrow the search for packaging materials.
PPWR aim
+ To prevent unnecessary packaging and promote reuse, refill and recycling;
+ To harmonize national measures to avoid trade barriers and competition distortions;
+ To contribute to the circular economy and climate neutrality by 2050.
For example, Kwik Lok is working on moving away from polystyrene, which is included on the Problematic and Unnecessary Materials list from the Plastics Pacts. “We are shifting toward polyolefins, and now offer the number 5 plastic, which is more commonly recycled,” Pakhnyuk
explains. The number 5 plastic, polypropylene (PP), is a tough, rigid and lightweight polymer used in many food packaging applications, including bread bags in the bakery industry. This polymer is the basis for Kwik Lok’s Enviro-Lok PP closures. “Where polyolefin films are recycled, closures can be placed in the same recycling stream as the bags, without having to separate and throw the closure in the trash,” Kwik Lok’s Dr. Pakhnyuk illustrates. A bakery choosing the Enviro-Lok closure can support its recycling goals, and request information about emissions and the impact of the packaging throughout its life cycle. Kwik Lok can provide such resources to guide packaging choices that take into account environmental impact data.
83%
of people around the world
believecompanies bear
responsibility for the end of life of
their products and packages.
Source: ERM, Global Eco Pulse®, 2024
Circularity in plastics
When circularity is the goal, an interesting distinction is made from the producers’ perspective for offering products packaged with recyclable materials vs. packaging incorporating recycled content. Closing the loop can be challenging because pricing is a factor: “It takes more work to reprocess the plastic than it does to use new, and sometimes the quality of the results is not on par, as plastic loses some quality with every recycling cycle (this degradation also occurs in fibers),” notes Pakhnyuk. Packaging that comes into contact with food will need to have the highest degree of purity, so recycled content will need to meet the highest quality standards. Here, the opportunity for bakeries will come from both recycling their packaging and using materials with recycled content.
When recycled plastic is suitable for use, the big challenge is sourcing enough of it, in the quality required for its application, and at the price that buyers are willing to accept. Simply put, there is not enough price-competitive recycled plastic in the marketplace that tips to higher percentages of recycled content. At the same time, circularity only works if there is enough demand for the recycled material that gets collected. This, in turn, means that producing materials with recycled content increases related costs. Creating uniformity across different markets can only benefit circularity goals, by ensuring each segment of the cycle fulfills its purpose
All design choices impact the success of recyclability, including the use of colors. For instance, intensely colored plastics are less desirable than white and clear scraps, because they will make it harder to achieve certain colors when reused. On the other hand, it’s worth considering keeping it clear or light colored, to ensure it can be, again, recycled after use – an argument that would entail using bright, lively colors considerably less, as a general rule, or in a different format such as ink. It would take advanced (and costly) recycling to separate colors and avoid grey or black material colors, which has less appeal for food packaging products.
Another distinction to be made is compostability – if the infrastructure is in place, it can also be a solution to the packaging waste problem. Again, standardization is key, so the consumer can easily understand which packaging items go where, when they are no longer needed. Labels are a powerful tool in this process.
Packaging minimalism
Working on the reduction of packaging is a clear direction that is not only compulsory, but also money-saving. Looking at material choices, for now and tomorrow, “Consumers expect manufacturers to take responsibility for the end-of-life of their products and packages. In fact, in the US, 73% of people believe manufacturers bear responsibility for the appropriate end of life of their products and packages (and only 16% think manufacturers are doing a good job with this),” Shelton notes.
“Consumers expect manufacturers to take responsibility for the end-of-life of their products and packages.”
Suzanne Shelton, founder, ERM Shelton
As the PPWR starts being applied, step by step, packaging enters an era of efficient minimalism, by necessity. Overpackaging with several layers of different materials will draw scrutiny, while using recyclable materials becomes a must, mono-materials a preference, and PFAS a no-go – to name some of the upcoming changes. Bakeries look for packaging solutions that answer several needs, starting with product safety and integrity, as always, but now also including PPWR compliance requirements. The design challenge is simplifying packaging while increasing functional efficiency with updated material options, communicating the needed and desired messages, and retaining the brand’s identity in this profound transformation process.
Resources:
i The Packaging and Packaging Waste Regulation 2025/40 (PPWR), 2025
ii Suzanne Shelton, June 2025, Unlocking the future of plastic recycling: A call to action
iii Suzanne Shelton, November 2025, ‘What’s in the way of recycling flexible plastics’
iv ANNEX to the Communication to the Commission, Approval of the draft Commission Notice on the Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste, March 2026, Brussels