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Packaging waste

EU rules on packaging and packaging waste address both the design of packaging and its waste management.

These regulations aim to reduce the increasing amounts of packaging waste, mitigate environmental problems, and harmonize the internal market by preventing varying national rules on packaging design.

Although these rules have achieved significant results, the volume of packaging waste in the EU continues to rise, leading to wasted finite resources that are not reintroduced into the economy.

EU packaging regulations apply to all packaging types and materials across sectors, including industrial, commercial, and household.

These rules establish:

Essential requirements for the manufacturing, composition, and recoverability of packaging.
Measures to manage and prevent packaging waste.

Key amendments include:

Adding examples of packaging to Annex I.
Introducing measures to reduce plastic carrier bag consumption in 2015.
Raising recycling targets and waste prevention obligations.
Establishing mandatory Extended Producer Responsibility (EPR) schemes under the 2018 Circular Economy Package.

Key Objectives

The Packaging Directive aims to:

Harmonize national measures for packaging and packaging waste.
Provide high environmental protection standards.
Ensure the effective functioning of the EU internal market.
The latest updates emphasize waste prevention, promoting reuse and recycling, and aligning with the European Green Deal.

Packaging waste in the European Union has been on an upward trajectory, posing significant environmental challenges.

Here's an overview of the latest statistics:
Total Packaging Waste Generation

2021: The EU generated approximately 84.3 million tonnes of packaging waste, marking a 6% increase from 2020.
Per Capita: This equates to 188.7 kg of packaging waste per inhabitant, an increase of 10.8 kg per person compared to 2020—the largest rise in a decade.

Packaging Waste by Material Type (2021)

Paper and Cardboard: Constituted 40.3% of the total packaging waste.
Plastic: Accounted for 19.0%.
Glass: Made up 18.5%.
Wood: Comprised 17.1%.
Metal: Represented 4.9%.

Plastic Packaging Waste

Generation: In 2021, each EU resident generated an average of 35.9 kg of plastic packaging waste, a 4.0% increase from 2020.
Recycling: Out of this, 14.2 kg were recycled per person, reflecting a 9.5% improvement from the previous year.

Recycling Rates by Country (2021)

Highest: Belgium led with a recycling rate of approximately 80% for packaging waste.
EU Average: The overall recycling rate across the EU was 65%.

Trends Over Time

Between 2010 and 2021, the EU experienced a 24.2% increase in packaging waste, amounting to an additional 16.4 million tonnes.
The most significant growth was observed in wood packaging (32.7%), followed by plastic (29.9%) and paper and cardboard (23.5%).

Legislative Framework

Key legislative frameworks include:

Packaging Directive 94/62/EC implements those general principles for packaging, adding concrete recycling targets and basic design requirements. (The Directive will be fully repealed by 2030. by Regulation (EU) 2025/40/EC)
Packaging Directive 2008/98/EC is the general ‘constitution’ of EU waste law
Regulation (EU) 2025/40 on packaging and packaging waste moves from a Directive (flexible transposition) to directly applicable EU law, while the Waste-Framework Directive will continue to govern all wastes and uphold the overarching hierarchy, prevention and EPR principles

Directive 2008/98/EC (Waste-Framework) vs. Directive 94/62/EC (Packaging & Packaging-Waste)

Dimension	Directive 2008/98/EC Waste-Framework Directive (WFD)	Directive 2008/98/EC Waste-Framework Directive (WFD)
Legal role	Horizontal “umbrella” law for all waste streams in the EU.	Sector-specific law focused only on packaging and its waste
Main policy focus	• Establish the waste hierarchy (prevention → pre-use → recycle → recover → dispose). • Set general rules on Extended Producer Responsibility (EPR), separate collection, by-products, end-of-waste criteria.	• Prevent and manage packaging waste; ensure free circulation of packaged goods. • Introduce material-specific recycling & recovery targets and “essential requirements” for packaging design.
Scope of obligations	Applies to municipal, industrial, hazardous, food, packaging, WEEE, etc.	Applies to all packaging placed on the EU market (household, commercial, industrial).
Targets	Generic municipal-waste recycling targets: 55 % by 2025; 60 % by 2030.	Material targets (to be met 2025/2030): Glass 75 %, Paper/board 75 %, Metals 70 %, Plastic 50 %, Wood 25 %.
Design provisions	No detailed product rules; only demands prevention and eco-design “where appropriate.”	Annex II “Essential Requirements” (minimise weight/volume, hazardous substances, encourage reuse).
EPR details	Mandates that Member States establish EPR schemes, but the fee structure/modulation is left to national discretion.	Makes EPR mandatory for the packaging sector and links fee modulation to recyclability (post-2018 amendment).
Relation to one another	WFD sets the general framework; PPWD provides specific rules that sit under that framework for one waste stream.	More specialised; must comply with the overarching principles (waste hierarchy, EPR) laid down in the WFD.
Reporting & data	Sets baseline reporting obligations for all wastes (Eurostat); defines common calculation methods.	Requires Member States to report packaging-specific data and meet PPWD recycling benchmarks.
Transposition flexibility	Both are directives—Member States implement via national law—but WFD is broader;	PPWD adds sector detail that can differ by material.
Current status	Still in force; last major amendment 2018 (Circular-Economy package).	Still in force but being replaced by the forthcoming Packaging & Packaging-Waste Regulation (PPWR), which will supersede the 94/62/EC directive.

Directive 2008/98/EC establishes a comprehensive legal framework for waste management in the European Union. Its goals include protecting the environment and human health, promoting sustainable waste management practices, and supporting resource efficiency.

Key Points

Waste Hierarchy: The directive defines a five-step hierarchy: prevention, preparing for reuse, recycling, other recovery (e.g., energy recovery), and disposal.
Polluter-Pays Principle: Waste producers bear the cost of waste management.
Extended Producer Responsibility: Manufacturers are held responsible for managing the waste lifecycle of their products.
By-products vs. Waste: Clarifies when a substance is classified as a by-product rather than waste.
Waste Management Standards: Operations must prevent harm to water, air, soil, plants, and animals.

Implementation Requirements

Waste must be treated by authorized operators holding valid permits.
EU countries must develop waste-management plans and prevention programs.
Special provisions apply to hazardous waste, waste oils, and bio-waste.
Recycling and recovery targets include:
- 50% recycling for household waste by 2020.
- 70% recovery of construction and demolition waste by 2020.

Amendments by Directive (EU) 2018/851
This amendment aligns waste management rules with the EU's Circular Economy Action Plan, introducing:

Minimum operating requirements for extended producer-responsibility schemes.
Measures to support sustainable production and consumption, including:
- Resource-efficient product design.
- Repairability and reusability of products.
- Reduction of food waste and hazardous substances.
New recycling targets:
- 55% of municipal waste recycled by 2025, 60% by 2030, and 65% by 2035.
Separate collection of textiles and hazardous household waste by 2025.
Mandatory separate collection or on-site recycling of bio-waste by 2023.

Application Timeline

Directive 2008/98/EC: Transposed into national laws by 12 December 2010.
Directive (EU) 2018/851: Transposed by 5 July 2020.

Background
EU waste generation used to be tied to economic growth. Modern waste management aims to decouple this link, emphasizing recovery, recycling, and sustainable resource use.

Key Terms

By-product: A secondary result of a production process, not considered waste under specific conditions.
Extended Producer Responsibility: Ensures manufacturers bear the financial and/or organizational responsibility for waste management.

Regulation (EU) 2025/40

Recognising these challenges, the EU has introduced a new Regulation (EU) 2025/40 which was adopted on 22 January 2025. This new Regulation introduces harmonised rules to ensure uniform compliance across all 27 Member States.

The adoption of Regulation (EU) 2025/40 is not just another policy update—it is a firm political commitment to tackling the mounting crisis of packaging waste. It reflects the EU’s resolve to lead the global transition toward sustainability, setting ambitious standards that will shape the future of production, trade, and environmental responsibility.

This new regulation marks a paradigm shift, reinforcing the Directive 94/62/EC with legally binding and harmonised measures across all 27 Member States. It strengthens the internal market by eliminating regulatory disparities, providing businesses with clear and uniform rules, and ensuring that sustainability is no longer an option but an obligation. As Europe asserts itself as a global leader in environmental governance, industries must now rise to the challenge of adapting to these rigorous new standards. The transition to a circular economy is no longer an abstract goal—it is now a legal and economic imperative.

The existing Directive 94/62/EC, which governs packaging and packaging waste, has not fully achieved its environmental and internal market objectives. Disparate national regulatory frameworks and varied implementation across Member States have hindered progress toward a circular economy.

Targets

The Directive also sets the following specific targets for recycling.

Implementation

EU countries must ensure compliance with the directive, including:

Monitoring and reporting recycling rates.
Establishing producer responsibility schemes.
Adopting harmonized standards.