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Head of UKRPEС Speaks at Seminar on New EU Regulation Held as Part of IFFIP–2025 in Kyiv
The seminar “EU Regulation 2025/40 on Packaging and Packaging Waste (PPWR) – Ambitious Tasks for Packaging Market Participants,” held within the framework of the International Forum of Food Industry and Packaging in Kyiv, generated significant interest. The event was attended by industry representatives and government officials. An active discussion followed the presentation by Volodymyr Slabyi, Head of the Executive Committee of UKRPEС.
As the speaker noted, the preparation of the new Regulation in the EU took two years. Its adoption was the result of intensive joint work by the European Commission, businesses, and environmental organizations. The environmental component precisely defined the main direction of packaging policy development in the EU.
The Regulation consolidates almost the entire regulatory framework governing the industry. It will have a decisive impact not only on the activities of producers of packaging and packaged goods but also on importers, distributors, distance selling providers, and others. To unite all these categories of obligated entities (regarding compliance with the Regulation’s requirements), the document even introduces a new term – “economic operator.”
Unified Requirements for 27 Countries
The new norms will come into effect on August 12, 2026. Many details will also be defined by by-laws that the European Commission and Member States still need to adopt. At the same time, the key principles, terminology, and approaches are now identical throughout the EU. The Regulation is a directly applicable document, binding for all 27 Member States. Previously, such a degree of unification did not exist in the EU, and local legislation could differ significantly between countries.
According to the document, for packaging to be placed on the market, it must not only meet defined requirements but also go through a series of established sequential and interconnected procedures and approvals. This encompasses the entire life cycle of the product, from raw material sourcing and production to recycling or reuse. The requirements consider materials, labeling, and many other indicators.
Producers Will Pay More and Report More Often
Despite significant innovations, the “ideology” of packaging industry regulation in the EU remains unchanged. It is based on the principles of the circular economy and Extended Producer Responsibility (EPR).
The obligations for producers in the context of EPR are expanding, becoming more complex and stringent, including:
- The scope and categories of responsible producers are expanding.
- Producers will cover 100% of the costs of collection, transportation, sorting, and recycling of packaging.
- A unified labeling system is being introduced with the use of digital passports and unique QR codes.
- Producers will submit annual reports on packaging volumes, materials, and their recycling rate.
- Financial responsibility for inefficient recovery systems is increasing (financial penalties, activity restrictions).
- By 2027, 80%, and by 2030, all packaging must be recyclable.
- In 2025, all plastic bottles must contain at least 25% recycled content, in 2030 – 30%, and in 2040 – 50%.
- By 2035, the volume of plastic packaging must be reduced by 10%, and by 2040 – by 15%.
- Total packaging volumes must decrease by at least 5% by 2030 and by 10% by 2035.
- All plastic bottles in the EU must have caps attached to the body.
- Producers must finance information campaigns for consumers regarding proper packaging recovery.
- By 2029, all EU countries must introduce a Deposit Return System (DRS) for plastic bottles and aluminum cans with a return rate of at least 90%.
Furthermore, the PPWR prohibits the use of:
- Single-use plastic packaging in restaurants from 2026.
- Microplastic fillers in packaging from 2028.
- Unjustifiably large packaging (e.g., excessive packaging for cosmetic products).
- Single-use plastic bags for packaging fruits and vegetables.
- BPA and per- and polyfluoroalkyl substances (from August 12, 2026) in food packaging.
One of the main innovations of Regulation 2025/40 is the clearly defined mechanisms for controlling compliance with its requirements. The document introduces a mandatory electronic reporting system for used packaging. Control will be exercised not only by state bodies but also by independent environmental organizations. This approach ensures impartiality and allows for prompt response to risks associated with non-compliance with environmental standards.
Who Wins and Who Loses?
The PPWR fundamentally changes the rules of the game for businesses. The biggest beneficiaries will be producers of ecological packaging and companies that implement reusable systems. Market leaders capable of quickly adapting to the new requirements and offering sustainable packaging as a competitive advantage will also benefit.
Conversely, producers of single-use plastic packaging are under threat. Businesses that lack a clear strategy for transitioning to a circular economy will also lose out. For them, the new requirements mean not only additional costs but also potential restrictions on market access.
Overall business expenditures on the activities of EPR organizations in EU countries are expected to increase by 20–30% by 2027.
Ukrainian legislation is lagging behind EU requirements
The first question that came from the audience after the speech of the Chairman of the Executive Committee of the UkrPOK was the prospects of implementing the norms of the new Regulation in Ukraine. The main obstacle to this, according to Vladimir Slag, is the lack of relevant legislation.
Prior to the introduction of PPWR in the EU, there were more than 70 other regulations that became the basis for the Regulation. In Ukraine, in addition to the framework of waste management, the legal framework in the sphere of waste of packaging is practically absent. The bill “On packaging and packaging waste”, which has been under consideration of parliament for years, has already lost its relevance. After all, the benchmark for him was the Packing Directive and Waste of Packaging, which has been operating in the EU since 1994. After adopting the Regulation, it has become invalid. Other normative legal documents of Ukraine do not meet modern European environmental requirements.
Meanwhile, the packaging of Ukrainian manufacturers should comply with the rules of the regulations today – because it continues to be exported to the European market. Entrepreneurs are forced to refer to certified laboratories in Poland or other EU countries to undergo an appropriate assessment and receive permits and documents on compliance with the European requirements. There are no such certified institutions in our country today.
“Integration of PPWR rules into Ukrainian legislation is not only a strategic need, but also a survival issue for a national producer,” – Volodymyr Slabyi emphasizes.
Processors are looking for raw materials abroad
Despite the difficult situation, there is a positive aspect – there are already significant capacity in Ukraine for recycling certain types of packaging waste: glass, paper, metal and plastic varieties. At the same time, problems occur with some types of composite and plastic packaging. For example, the only Ukrainian capacity for the recycling of Tetra Pak’s waste of waste is in Snake of Kharkiv region – in the eastern part of Ukraine, near the war zone, which makes logistics from other regions too costly.
The key call is the absence of a proper system of separate collection and sorting of waste. Due to the lack of recyclables, Ukrainian processors use only half of their capacities and are forced to import paper, polymer and other waste from abroad.
“The 2025/40 Regulation is not just about new requirements, it is about a new philosophy of storage waste. It changes the conditions for all – from small business to transnational companies. The cost of inconsistency with requirements – not only fines, but also lost markets and reputation. Those who can quickly adapt to the circular economy will win. But to make it possible, a clear, coordinated state strategy is needed. Ukrainian entrepreneurs have the right to count on such legislation, which does not hinder their adaptation to European requirements, but supports and encourages it, ” – said the head of the Executive Committee of UKRPEC Vladimir Slabyi.
