Emiliano Morgia // 16 September 2026

This briefing examines the European Union’s Packaging and Packaging Waste Regulation (PPWR) and its approach to reducing packaging waste through greater reuse, recycling and resource efficiency. While reducing waste and environmental impacts is a legitimate policy objective, the regulation risks assuming that policymakers can determine in advance which packaging solutions will deliver the best outcomes, rather than allowing businesses, engineers and consumers to discover them through innovation and competition.

The paper examines the trade-offs involved in reuse, recycling and different packaging solutions, arguing that environmental performance depends on the specific conditions in which products are designed, transported, used and disposed of. Applying the waste hierarchy too rigidly can therefore prioritise formally ‘circular’ solutions even where they require more energy, water or transport and result in a higher overall environmental impact. The briefing argues that regulation should focus on environmental outcomes rather than prescribing the means through which those outcomes must be achieved.

The briefing also considers the economic and administrative costs of the PPWR, particularly for small and medium-sized enterprises. Additional requirements for data collection, certification, recycled content and recyclability, alongside national registers and extended producer responsibility schemes, can increase the costs of operating across the Single Market. While the European Commission estimates substantial net savings from the regulation, these projections depend on modelled assumptions and do not fully capture the costs associated with reuse systems, deposit-return schemes, logistics, washing and compliance.

The briefing argues that a more effective approach would establish clear environmental objectives while leaving businesses and innovators greater freedom to determine how those objectives can best be achieved. By allowing competing solutions to be tested against their actual environmental performance, policymakers can avoid prematurely locking in particular technologies or business models and preserve the process of discovery through which more efficient and sustainable solutions can emerge.

The main findings of the briefing include:

• The PPWR reflects an assumption that policymakers can determine in advance which packaging solutions are environmentally preferable, despite the information needed to make such judgements being dispersed across engineers, manufacturers, distributors and consumers.
• Reuse is not automatically more environmentally beneficial than single-use packaging. Its impact depends on factors including the number of uses, energy and water consumption, washing requirements, transport and the length of time products remain in use.
• The waste hierarchy can become counterproductive when applied rigidly, as recycling, reuse and other ‘circular’ solutions can involve higher energy, water or transport costs than alternative waste-management approaches in particular circumstances.
• Regulation should focus on environmental outcomes rather than prescribing specific methods. Allowing entrepreneurs, engineers and businesses to compete over different approaches can encourage innovation and reveal solutions that policymakers cannot identify in advance.
• The PPWR imposes significant administrative and compliance costs, with a disproportionate impact on SMEs that lack the dedicated compliance departments and resources available to larger firms.
• Higher operating and compliance costs can raise barriers to entry, potentially reducing competition and experimentation while strengthening the position of larger, established businesses.
• The European Commission’s projected economic benefits from the PPWR should be treated with caution, as they represent a comparison between modelled future scenarios and depend on assumptions about packaging consumption, waste management and the costs of reuse and deposit-return systems.
• The environmental objective of reducing waste and resource consumption is legitimate, but achieving it requires regulatory humility and sufficient space for businesses and innovators to discover better solutions.