Five questions importers and manufacturers are still asking about PPWR — and the one nobody is asking loudly enough.
If you sell packaged goods into both the UK and the EU, you have almost certainly spent the last year on recyclability. Gathering component data, splitting packs into hand-separable parts, getting to a RAM rating you can defend.
This is the challenge facing sales and operations directors: that work does not carry across. A green UK RAM result does not convert into an EU recyclability grade. The two systems are at different stages, ask different questions, measure different things, and punish you in different currencies. From 2030 you will be running both, on the same pack, with two separate evidence sets.
That was echoed in a thread running through a recent webinar i joined Amcor’s PPWR is here Q&A session in July, where 23 questions were put to Dr Gerald Rebitzer and his team — questions the original webinar had not had time to cover. Asked directly whether UK Design for Recycling would align with PPWR, the answer was blunt: “the UK RAM is not aligned up to now.”
Below are the five questions that came up there and that are still circulating across the industry, ranked by how much trouble they are currently causing.
- Will our UK RAM work satisfy the EU?
No. They are not the same assessment and they are not graded on the same thing.
UK RAM rates packaging red, amber or green based on what actually happens to it in UK infrastructure today — collection, sortation, reprocessing. PackUK published RAM 2027 on 1 July 2026; RAM 1.1 governs the 2026 reporting year and RAM 2027 governs 2027. A red rating costs you money, through higher pEPR fees.
PPWR Article 6 grades packaging A, B or C against design-for-recycling criteria — A at 95% or above, B at 80%, C at 70%, and anything below 70% is treated as technically non-recyclable. From 2035 it also factors in whether the material is recycled at scale in practice. A bad grade there does not cost you money. It costs you market access and therefore a sales risk: from 2030, packaging that cannot reach grade A, B or C cannot be placed on the EU market at all. From 2038 only A and B are permitted.
So one system is a fee. The other is a border.
What to do: stop treating recyclability as one workstream with one output. Map your portfolio against both sets of criteria and find the packs where the two disagree — those are where your 2030 exposure sits, and they are rarely the packs people expect.
- How can we design for recycling when the final method is not published?
This was asked twice in the session, in two different forms, and it is the most common objection I hear from technical teams. It is a fair objection. It is also not a reason to wait.
The design criteria that will drive the grades are being developed through CEN standardisation work, and the detailed calculation method is not finished. But the direction is not in doubt — mono-material structures, removal of problematic components, separability — and none of that changes when the final percentages land. Redesign cycles in packaging run 18 to 36 months. Waiting for certainty means starting the clock after the deadline.
What to do: begin work to redesign following the direction of travel now, and structure the evidence so it can be re-scored when the method is published. This would then only require minor adjustment and avoid the bottleneck when the entire market is making the same request of suppliers.
- PFAS limits and heavy metal restrictions are already live. How do we prove compliance?
This is the one that is genuinely urgent, and it is underweighted in most of the coverage.
Since 12 August 2026, food-contact packaging placed on the EU market must sit under 25 ppb for any individual PFAS, 250 ppb for the sum of PFAS, and 50 ppm total fluorine. There is no transition period. It applies whether or not PFAS were intentionally added — a point that is still widely misunderstood.
The difficulty is evidential. The Commission has not prescribed a definitive test method. In April 2026, more than 100 companies — including Coca-Cola, Heineken, McDonald’s, Mondelez and Carlsberg — wrote asking for exactly that clarification, among four other points. They did not get it before the date landed. The recommended approach is a cascade: total fluorine first, then targeted PFAS analysis if the threshold is exceeded, then TOP analysis.
And the obligation does not sit where many assume. The packaging manufacturer is the economic operator responsible for demonstrating conformity. A verbal assurance from a supplier, or a declaration with no test report behind it, is not evidence a regulator will accept.
What to do: identify every food-contact pack in your portfolio, establish which have test-backed evidence rather than supplier statements, and put warranties and indemnities into supply contracts for the rest.
- Will there be enough recycled content to hit the 2030 targets?
Probably not, at least not right away. Analysis of the European market points to a shortfall of over one million tonnes of PCR in 2030 against PPWR requirements — roughly the output of ten new large-scale plants — and more than two-thirds of market participants already describe mechanical PCR availability as scarce or insufficient. Food-grade PCR, polypropylene and multilayer structures are at greatest risk.
The commercial consequence seems obvious: when a regulated input is short in supply, price and contract terms move against whoever secures it last.
What to do: treat PCR as a procurement and supply-security problem with a 2030 horizon, not a 2029 purchasing decision.
- Does “banned” actually mean banned — and does it catch imports?
Yes. As the webinar panel put it, it is “a hard requirement that has to be met”, and it “applies to everything that is placed on the market in the European Union, whether from Asia, US, UK, etc.” — imported packaged products as well as imported packaging.
For UK exporters that is the whole point. Leaving the EU means added a regulation through variation between where the UK is and direction of travel for EU market.
One correction worth noting for the pet food sector. The packaging is classified as animal feed, not food. So the PFAS limits, which apply strictly to food packaging, do not bite. It does attract contact-sensitive status, the recyclability requirements apply in full, and it carries a 10% recycled content target in 2030. If you have been scoping pet food packs against food-contact PFAS thresholds, you have been solving a problem you do not have — and possibly missing the one you do.
Where this leaves you
Three things apply right now: the PFAS & heavy metal restrictions, the general recyclability requirement, and the conformity evidence that sits behind them. Others are existing standards and requirements that already applied under PPWD. Most of the rest — design-for-recycling grades, recycled content, reuse targets, single-use format bans — starts in 2030, with harmonised labelling in August 2028.
That gap needs to be quickly seized. It is just enough time to redesign properly, but not enough time to redesign twice — Who wants to pay twice anyway? To avoid your businesses getting hurt by 2030, test your recyclability assessments against both PPWR and UK EPR. If you sell elsewhere, like the US, don’t forget those markets are also ramping up on recyclability.
If you want to know where your UK and EU positions diverge, I’ll look at your portfolio and tell you. A scoping call takes thirty minutes and you will come out of it knowing which packs are the problem and what order to fix them in.
Contact Mark Sayers via the link above — Circumetrics. EPR and packaging compliance, UK and EU. Member of PackUK’s Technical Advisory Committee.