Navigating legislation implementation for flexible packaging: ‘Mission Circular’ or ‘Mission Impossible’?
If PPWR sets targets, it is the numerous pieces of implementing legislation being defined between now and 2030 that will define whether they can be met, by who, and in what conditions.
Methodologies, criteria and definitions are being developed across multiple files and will determine how the system operates. For companies, this creates a practical challenge. Decisions on design, materials and investment are being taken now, while key elements of the system are still being defined. The volume of technical policy work is high, and the connections between files are not always clear.
Companies tell us they are facing challenges on multiple fronts including tracking how upcoming decisions will shape system conditions; and needing an effective advocate to accelerate progress on collection, sorting and recycling infrastructure across Europe. They also need better visibility on how recycled material will be used and where demand will come from. And they need practical design understanding, grounded in testing, shared evidence and compatible with evolving criteria.
This is where a core CEFLEX mission becomes critical: structured, evidence-based insight from across the value chain.
The aim is to assess how policies interconnect and have the most impact – and to influence decisions while they are still open, giving evidence and direction to shape policy, industry action and environmental outcomes in practice.
Let’s look at a few of the priority issues, their role and how the flexible value chain has been giving constructive input.
Design for recycling: aligning standards, assessment and application in movement
Design for recycling is progressing through several interconnected processes, including a first set of CEN standards for plastic packaging and their assessment and adoption into legislative requirements. The interaction between these elements is important and an interplay that will continue to evolve over time.
CEN standards (EN 18120) provide a structured European reference, based on a consensus process, with defined scope and technical boundaries. CEFLEX has actively contributed to the development of the Design for Recycling (DfR) standard series EN18120; providing the project leadership for the polyethylene (PE) and polypropylene (PP) flexible packaging standards EN18120-7 and EN18120-13 and providing insights and data from its Designing for a Circular Economy (D4ACE) testing programme, conducted with independent laboratories and academia across Europe.
In parallel, the Joint Research Centre is assessing technical inputs that will inform the Commission’s recyclability criteria under PPWR. The final requirements will be set through delegated acts. These will draw on standards but also need to reflect recycling technologies’ performance and policy objectives.
In practice, we see CEN deliverables and CEFLEX design guidance (D4ACE) as complementary: CEN provides the formal framework and minimum design requirements, while D4ACE brings practical, clear and educational guidance, explaining not only what design elements are compatible with recycling, but also why and how.
In addition to this practical advice, continued testing delivering shared data from CEFLEX will also be needed to drive future progress and expected revisions.
Key dates, files and decisions to watch out for:
- Finalisation and publication of CEN EN 18120 standard series (Spring 2026 and ongoing)
- JRC technical assessments supporting thresholds and design requirements
- Adoption of CEN standards into PPWR recyclability criteria via delegated acts (indicative 2027)
- Future revisions driven by testing data and system performance feedback
Recyclability assessment: linking criteria to real system performance
The European recyclability performance assessment methodology (RAM) will determine how packaging design-for-recycling is evaluated under PPWR.
It will determine how packaging designs are scored and classified in recyclability grades. This directly affects which packaging remains on the market and how Extended producer Responsibility (EPR) fees are modulated to incentivise recycling. Given how key these issues are, CEFLEX has been working with organisations across sectors and materials to bring approaches together. The objectives are to obtain a simple methodology that supports circularity for flexibles and other formats, and that can be applied consistently by all manufacturers without bias.
Two points are central for the flexible packaging value chain. First, incentivising improvements to packaging design. The methodology should ensure that non-recyclable packaging is removed from the market. Sustainable designs should be rewarded, while ensuring that packaging that is compatible with recycling is allowed to remain on the market.
Second, RAM needs to avoid incentivising the addition of unnecessary packaging material to improve the recyclability score.
Our input has drawn on input from CEFLEX’s stakeholders from across the value chain, own analysis and modelling work as well as engagement with multiple material sectors. This work contributes to the development of models by the Joint Research Centre (JRC) and others that reflect how packaging behaves in real systems and can be applied effectively by industry. The aim is to contribute to a coherent, open framework that supports consistent assessment across materials.
Key dates, files and decisions to watch out for:
- JRC technical work and recommendations feeding into methodology design (report due end 2026)
- Expected delegated acts on recyclability criteria and grading (indicative 2027)
- Alignment between RAM outcomes and EPR fee modulation across Member States
EPR systems: from fragmentation to harmonised performance?
EPR is a strategic and enabling mechanism for collection, sorting and recycling, and arguably the designated driver of circular materials in Europe.
However, performance across Member States remains uneven, with differences in structure and funding. This can generate a significant difference in outcomes, not to mention complexity for companies operating across markets.
Design, collection and recycling need to operate as a system in practice. A more harmonised approach to how Packaging Recovery Organisations (PROs) will be governed, funded and operate across Europe needs to emerge in the near term.
Work on the Circular Economy Act is expected to address some of these points. The direction of travel must be towards roles that are more consistent with legislative obligations, clear fee modulation and more strategic perspectives. Without this, improvements in one part of the circular economy system will not translate into overall progress.
Key dates, files and decisions to watch out for:
- Adoption of the Commission’s proposal for a Circular Economy Act and EPR harmonisation (Q3-Q4 2026)
- Evolution of eco-modulation frameworks linked to recyclability and, potentially, recycled content
- Discussions on minimum requirements for PROs
Recycling technologies and sustainability criteria: quality and quantity
Flexible packaging cannot rely on a single recycling pathway and meeting PPWR targets requires a combination of mechanical recycling, upgrading processes and chemical recycling. Each plays a different role in handling material streams and delivering the required quality.
Sustainability criteria required by the PPWR for plastics recycling will determine which technologies can contribute to achieving recycled content targets.
CEFLEX input has focused on avoiding disqualification of certain technologies, suggesting that criteria need to recognise the different roles of technologies across fractions and applications. If certain pathways are excluded, this creates a capacity and quality gap, with consequences for compliance, investment and the feasibility of a circular economy for flexible packaging.
The issue is not only volume, but quality. Recycled material needs to meet end-market requirements to be used.
CEFLEX analysis indicates that delivering both the quality and quantity required for 2030 PPWR targets for flexible packaging will require: between 3.3 – 4.7 million tonnes / year (MTPA) of conventional mechanical recycling and 2.2 – 3.1 MTPA of advanced decontamination quality mechanical recycling. Complemented by 0.5-0.7 MTPA of physical purification such as extraction and dissolution, and 0.7 – 1.1 MTPA of chemical recycling.
Key dates, files and decisions to watch out for:
- JRC technical recommendations for sustainability criteria (report due Q3-Q4 2026)
- Delegated Act on sustainability criteria for recycling technologies under PPWR (due end 2026 but may be delayed)
- Decisions on which recycling pathways qualify for recycled content targets
- Investment signals linked to regulatory recognition of different technologies (ongoing)
End-of-waste and market conditions: maintaining material circulation
EU harmonised end-of-waste criteria will determine when recycled plastics can circulate as products throughout the Single Market.
Harmonisation is needed to remove barriers to transport of recycled plastics. Crossing borders is part of the normal movement of materials as they are sorted, recycled and returned to replace virgin.
As currently drafted, there is a risk that technically usable recycled polymers could be classified as waste, particularly for polyolefin-based flexible packaging. This would reduce demand, increase administrative burden and negatively affect investment.
In collaboration with other value chain partners, CEFLEX input has focused on workable definitions, clear concepts and realistic implementation timelines. The objective is to prevent potentially far-reaching negative impacts of text that is open to interpretation.
Key dates, files and decisions to watch out for:
- Adoption of EU-wide End-of-Waste criteria for plastics (Q3-Q4 2026)
- Clarification of cross-border movement conditions for recycled materials
- Implementation timelines and transition periods affecting current material flows
Functioning markets for recycled content in secondary applications: a condition for circularity
Recycling can only scale if there is demand for the output. Secondary applications play a central role in absorbing recycled material. For flexible packaging, applications such as stretch and shrink films represent a significant share of expected demand.
Changes affecting these applications have system-wide effects. For example, removing a proportion of pallet wrap as an outlet would reduce both the volume and value of recycled material, and increase pressure elsewhere in the system.
These interconnected issues shape the availability, quality and cost of recycled materials across the system.
Our insights work helps make these dynamics visible and actionable. By translating legislative targets into material flows, end-market demand and quality requirements, it provides policy makers with a clearer view of where recycled content can realistically be used, at what scale and under what conditions. It identifies the applications that matter most, highlights where constraints will emerge and shows how choices in one part of the system affect outcomes elsewhere.
This enables more aligned decisions on design, investment and procurement across the value chain, reducing the risk of stranded material or misallocated capacity, and supporting the development of stable, functioning markets for recycled content.
Key dates, files and decisions to watch out for:
- Adoption and publication of Delegated Act exempting pallet wrapping and straps from 100% reuse targets (expected end May 2026)
- Implementation of PPWR recycled content targets (first milestones from 2030)
- Clarification of calculation rules and mass balance approaches (end 2026 / early 2027)
- Market development for secondary applications and their regulatory treatment
Working together to make ‘Mission Circular’ and EU legislative targets a reality
Implementation is taking place while key elements of the system are still being defined. For companies, this means decisions are taken with partial visibility. For policymakers, it means frameworks need to be connected to how the system works in practice.
CEFLEX’s role in this phase is to work upstream of decisions to the benefit of all. This includes bringing together evidence from across the value chain, testing insights, and contributing perspectives on methodologies and frameworks while they are still being developed.
The focus is on shaping the conditions under which the system will operate. Ensuring criteria reflect real performance, that design requirements can be applied, and recycling pathways and end markets are recognised.
To assist, a legislative dashboard to complement our advocacy working group is being developed for stakeholders. It provides visibility on how key files are evolving, where engagement can still influence outcomes and how well EU policy is doing on enabling the transition to circularity.
Stakeholders already engaged in CEFLEX will receive further updates through the legislative dashboard and ongoing working group exchanges.
Not yet participating and keen to make sense of 2026 – 2030 and beyond? Drop us a message to find out how to stay ahead: info@ceflex.eu