Miron’s Position Paper
on the PPWR
Interview with Martijn R. Otten
COO - Sustainability
Our Vision on PPWR
“We support the goal of the PPWR, the Packaging and Packaging Waste Regulation, to reduce the environmental impact of packaging. It fits well with our mission to restore the connection between people, product, and nature. The main challenge is clarity. We still need clear rules on the details, how things are measured, and how they are enforced. This is complex because there are many types of packaging, from single-use food wrappers to oversized shipping boxes, and every EU country has different policies, cultures, and infrastructure.
We expect the PPWR to focus first on the biggest impact, which is single-use, non-recyclable plastic packaging. That is not what we do. Glass is already seen as a clean material that can be recycled over and over, with its own recycling stream. Also, our products are not single-use. Think about it, how often do you open a vitamin jar or use a room spray?
One point to watch is the unique light-filtering property of Miron glass. This can make it harder for optical sorting machines to detect it. We also see big differences in recycling rates across Europe. Finland is very high at about 99%, while Portugal is closer to 57% (source). So, the technology already exists, and it will keep improving, especially with AI as we move toward the 2035 deadline. To help speed things up, we are testing small changes to our glass formula. The goal is to improve detectability without losing the protective function or the look of the glass.
With our leading European partners, we are also focusing on our plastic closures. We are moving away from thermoset plastics, while also adopting solutions such as non-glued liners. As the market adapts to the new law, we expect to offer more alternatives. We will support and guide our customers through these changes in the coming years.
We see a strong future ahead and will keep investing in Miron to stay true to our purpose”.
Executive Summary
The PPWR (Packaging and Packaging Waste Regulation) is an EU law for all packaged products sold in the EU. Its goal is to reduce the environmental impact of packaging and create the same rules across all EU member states.
The PPWR focuses on five main goals: reducing packaging, increasing reuse, improving recyclability, using more recycled material, and limiting compostable packaging to cases where it is truly useful.
The first key deadlines begin on August 12, 2026, when the PPWR starts to apply in practice. Major design and compliance rules will follow from 2030, with stricter reuse and recycling targets coming later.
For Miron, the outlook is very positive. Glass already aligns well with the goals of the PPWR because it is durable and fully recyclable. Miron glass is also widely collected across Europe as colored glass, and its design already avoids unnecessary weight. We also continue to work on further reducing unnecessary weight and improving optical sort detection to support even better recycling performance. Its strong ingredient protection and premium appearance can also support reuse. This gives Miron and its customers a strong starting point.
Since the PPWR looks at the full pack, the main area of change will be the closure rather than the glass itself. Components such as caps, pumps, and pipettes are often more complex and harder to recycle, so they will need the most attention. That is why Miron is already working with leading European partners to develop improved solutions, including more mono-material closures, alternatives to plastics such as UREA and SAN, and options like non-glued liners.
Miron customers are already ahead of the curve; no major disruption is expected. In some cases, customers may be guided toward improved closure options over time, but the transition is expected to be gradual and manageable. Before August 12, 2026, Miron will provide customers with a ‘Declaration of Conformity’ (packaging passport) and, where relevant, information on PFAS content.
Miron glass is already well aligned with the future of packaging in Europe, and customers can expect practical guidance, limited disruption, and steady support as the rules continue to develop.
Introducing the PPWR as the New EU Packaging Law
The Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40 is a mandatory, directly applicable regulation whose objective is to reduce the environmental impact of packaging. At the same time, it aims to align rules across all EU member states to ensure the free movement of products. If your business puts something in a package and sells it in the EU, this rule applies to you.
The full text of the regulation can be found here.
.The PPWR Is Built on 5 Key Pillars
These five pillars aim to reduce packaging waste by making packaging smaller and smarter, genuinely reusable, recyclable at scale, richer in recycled content, and compostable only in clearly justified cases.
1. Prevention
“Use less packaging, but keep it functional.”
The first pillar focuses on reducing packaging waste at the source through smarter design. Packaging must be limited to the minimum weight and volume necessary to do its job, while still protecting the product, ensuring safety and hygiene, and supporting usability and presentation. This means unnecessary features such as false bottoms, double walls, excessive empty space, or unnecessary layers will be restricted.
At the same time, prevention is not just about stripping packaging down at all costs. The PPWR recognizes that packaging must still serve key functions such as product protection, consumer convenience, ergonomics, brand recognition, and market presentation. In other words, packaging should be minimal, but not dumb. A pack that protects less, works worse, or loses its identity may not be compliant either.
The detailed technical criteria for minimization are expected by 2028, and the requirements become mandatory from 1 January 2030. Certain registered and legally protected packaging designs, including shapes protected as trademarks or design rights before 11 February 2025, may benefit from exemptions. From 2030, some packaging formats will also be banned, including single-use condiment sachets, miniature hotel toiletry bottles, and certain plastic packs for fresh fruit and vegetables.
2. Reuse
“Packaging must not only be reusable in theory but also reused in practice.”
The second pillar promotes the transition from single-use to real, operational reuse systems. Under the PPWR, packaging is only considered reusable if it is part of a structured system that includes collection, return, cleaning, reconditioning, traceability, and incentives for return. Simply making packaging durable is no longer enough.
From 1 January 2030, reusable packaging placed on the market must be integrated into a compliant reuse system and supported by documentation proving that it is actually being reused. Producers and importers will need to provide evidence of participation, maintain technical documentation, and report relevant data through extended producer responsibility systems.
The Regulation also introduces reuse targets, especially for beverages. From 2030, 10% of alcoholic and non-alcoholic beverages must be sold in reusable packaging or refill systems, rising to 40% by 2040. These targets apply at the EU member state level, but companies may still be expected to contribute operationally and administratively.
For materials like glass, this pillar may create a strong opportunity. Glass is naturally durable, stable, and easy to clean, but it will only qualify as reusable when it is part of a documented and functioning reuse loop.
3. Recyclability
“Packaging must be designed for recycling and, later, actually recycled at scale.”
The third pillar requires all packaging to become recyclable in a practical and measurable way. From 1 January 2030, packaging must meet design-for-recycling requirements and achieve at least Grade C recyclability, meaning a minimum of 70% recyclability. The PPWR introduces a classification system with Grades A, B, and C, based on how effectively packaging can be recycled.
This framework becomes stricter over time. From 2035, recyclability will no longer depend only on design, but also on whether the packaging is actually collected, sorted, and recycled at scale within real industrial systems in the EU. From 2038, only Grade A and Grade B packaging will be allowed on the market, while Grade C packaging will be phased out.
The official methodology for classification is still to come and is expected before 2028, but the direction is clear already. Packaging that is technically recyclable but not recycled in practice will come under increasing pressure.
Material choice matters here. Glass is widely expected to perform strongly and is already recognized as recyclable at scale. Aluminum is also well-positioned. Plastics, on the other hand, face tighter scrutiny, especially multilayer, multi-material, polystyrene-based or poorly recycled formats. Paper and cardboard remain important, but they too must meet rising performance thresholds.
4. Recycled Content
“Use more recycled material, especially in plastics.”
The fourth pillar is about reducing dependence on virgin raw materials by increasing the use of post-consumer recycled content, especially in plastic packaging. The PPWR introduces mandatory minimum recycled content targets for plastics from 2030, with stricter targets from 2040.
From 2030, the main targets include:
30% recycled content for food-contact PET packaging
10% for food-contact non-PET plastic packaging, excluding single-use beverage bottles
30% for single-use plastic beverage bottles
35% for other plastic packaging
From 2040, these targets increase further:
50% for food-contact PET packaging
25% for food-contact non-PET packaging
65% for single-use plastic beverage bottles
For now, these obligations apply mainly to plastics. There is no mandatory recycled content requirement yet for glass, aluminum, wood, or paper-based packaging, although the European Commission may assess this in the future. This means materials already performing well in recycling systems, such as glass and aluminum, could gain a further competitive advantage if future rules expand beyond plastics.
The regulation also leaves room for future developments around biobased plastics, which may eventually receive specific sustainability criteria or, in some cases, count towards recycled content goals if recycling routes remain limited.
5. Compostability
“Only compost where it genuinely makes sense.”
The fifth pillar does not make all packaging compostable. Quite the opposite. It limits compostability requirements to specific packaging types that are likely to end up mixed with organic waste, or that would otherwise contaminate recycling streams.
By 12 February 2028, the following packaging types must be compostable in industrial composting facilities:
single-use coffee or tea capsules containing organic content
adhesive labels attached directly to fresh fruit and vegetables
tea and infusion filter bags
carrier bags used for household organic waste collection, where accepted locally
These products must comply with harmonized technical standards and carry clear mandatory labelling explaining compostability, composition, and any other required information. Importantly, the requirement is for industrial compostability, not home composting.
The detailed criteria and verification methods are expected before 2028, while guidance on application and labelling is due in August 2026. Producers and importers will be responsible for both technical compliance and labelling.
For most packaging categories, compostability will remain the exception rather than the rule. The PPWR makes clear that compostable packaging should only be used where it delivers a real environmental benefit and where suitable collection and treatment systems exist.
PPWR Timeline Milestones
The PPWR started in 2025, became applicable in 2026, defines the technical rulebook by 2027 to 2028, drives major compliance changes from 2030, and tightens towards fully circular packaging by 2040.
2025: Regulation adopted and enters into force
The PPWR is officially published on 22 January 2025 and enters into force on 11 February 2025. This is the legal starting point of the new EU packaging framework. The first annual reporting cycle is also set up by the end of this year.
2026: EU-wide application begins
From 12 August 2026, the regulation will become mandatory across all EU member states. This is also the year when the commission starts issuing further guidance, including on areas such as chemical substances in packaging and future compostability interpretation.
2027 to 2028: The technical framework is defined
This is the rule-setting phase. Before 12 February 2027, the commission asks the European Committee for Standardization to develop or update harmonized standards for the five pillars. By 1 January 2028, the commission is expected to adopt delegated acts that define the technical criteria and assessment methods behind the PPWR. This will shape how packaging is officially evaluated in practice, including recyclability grades, minimization rules, reuse requirements, compostability criteria, and possible treatment of biobased or innovative materials.
2029: Deposit-return systems become the norm
From 1 January 2029, member states must introduce deposit-return systems (DRS) for relevant packaging formats such as plastic beverage bottles and metal cans, unless they can prove they already achieve a 90% separate collection rate.
2030: First major compliance deadline for design for recycling
From 1 January 2030, the PPWR shifts from preparation to hard requirements. This is the first major turning point.
By then:
Packaging must be designed to use no more material than necessary
All packaging must meet minimum design-for-recycling requirements
Only packaging with at least Grade C recyclability (≥70%) can remain on the market
Plastic packaging must meet mandatory recycled content targets
Certain single-use packaging formats are banned
Reuse obligations begin to apply in practice in relevant sectors
This is the year when the PPWR starts to materially affect packaging design, format choice, and compliance documentation.
2032 to 2034: Review and adjustment phase
By 2032, the PPWR undergoes its first major review, looking at the effect of the measures already introduced and whether recyclability and recycled content rules need to be adjusted. By 1 January 2034, another review point is built in for packaging design and recyclability criteria.
2035: Recycling at scale becomes mandatory
From 1 January 2035, it will no longer be enough for packaging to be recyclable in theory. It must also be recycled at scale in real industrial systems.
That means packaging must actually be collected, sorted, and recycled through functioning infrastructure, not just pass a technical design test. This is a key shift from design for recycling to proven recycling performance.
2038: Low-recyclability packaging is phased out
From 1 January 2038, the rules tighten again:
Only Grade A (≥95%) and Grade B (≥80%) packaging may be placed on the market
Grade C packaging is no longer allowed
This is where the PPWR sharply raises the bar and pushes harder against lower-performing materials and formats.
2040: Reuse targets become much more ambitious
From 1 January 2040, reuse targets increase significantly, especially for beverage packaging and some transport and sales packaging. For beverages in particular, the reuse target rises to 40%, making reuse one of the biggest long-term structural shifts in the regulation.
Miron’s Position on the PPWR
The PPWR mainly supports the direction Miron is already taking. Miron glass is well-positioned because it is durable, reusable, and recyclable, while the biggest improvement areas are continued lightweighting, better sorting compatibility, and especially simpler, more recyclable closures.
1. Prevention and Waste Reduction
The PPWR starts with a simple idea: use no more packaging than necessary, but leaves room for packaging to function as brand recognition.
For Miron glass, this is already a strong position. Glass packaging is durable and functional, and Miron designs already avoid unnecessary mass. The main opportunity is continued lightweighting and improving optical sorting detection, without compromising its premium feel or protective properties.
This pillar also goes beyond the product itself. The PPWR targets inefficiencies in transport and logistics, so reducing unnecessary empty space in secondary packaging matters too. Miron’s custom AI shipping calculator already supports this by helping reduce “shipping air,” improve pack-out, and optimize transport efficiency.
2. Reuse and Refill
The PPWR pushes packaging beyond one-time use toward real reuse systems.
Miron glass fits this direction well. Customers already reuse Miron packaging because of its quality, appearance, and preservative properties. Refill models are also emerging, for example, with pouches.
The next step is making reuse more scalable. That will likely depend less on the glass itself and more on closure durability, standardization, and system readiness. In reuse and refill models, closures often become the weak point, especially pumps and pipettes that are not built for repeated long-term use.
3. Recyclability and System Compatibility
This is one of the core PPWR pillars: packaging must not just be recyclable in theory, but also work in real recycling systems.
Glass is already strong here. It is infinitely recyclable, widely collected, and benefits from established European recycling infrastructure. For Miron glass, the focus is therefore not on reinventing recyclability, but on maintaining compatibility with sorting and recycling systems.
A specific point of attention is Miron’s unique light-filtering glass, which can present challenges in optical sorting. This is why current testing and validation are important, especially as the PPWR moves toward stricter real-world recycling performance requirements from 2035 onward. Labels, coatings, and component choices will also need to support this system compatibility.
4. Smarter Closures and Material Simplification
The biggest impact of the PPWR is expected to be on plastic-heavy components such as closures, where there is more room for improvement than in glass, which already performs strongly on durability and recyclability.
Caps, pumps, pipettes, sprays, and lids are often more complex than the bottle or jar. They tend to combine multiple materials, contain more virgin plastic, and are harder to sort and recycle. This makes them a key focus area under the PPWR.
The direction of travel is clear:
simpler, more mono-material designs
better separability
less unnecessary plastic
fewer glued or mixed-material components
stronger alignment with real collection and sorting systems
Miron is already moving in this direction by optimizing its portfolio away from materials such as UREA and SAN, while working with leading European partners, and expanding more future-proof options such as wood, aluminum, mono-material designs, and non-glued liners.
5. Strategic Fit With the Goals of the Regulation
Beyond technical compliance, Miron glass aligns well with the broader logic behind the PPWR. Miron’s mission is to restore the connection between people, product, and nature, and that fits naturally with packaging that is durable, protective, reusable, and recyclable.
The regulation increasingly rewards packaging that supports durability, reusability, recyclability, and product protection. Miron glass performs strongly across these themes. Its premium quality supports reuse, its material performs well in recycling systems, and its preservative function strengthens the case that packaging should do more than just exist prettily on a shelf.
As regulatory interpretation develops, this may create a relatively favorable position for Miron compared with more complex or lower-performing packaging formats. That does not remove the need for continuous improvement, but it does mean Miron starts from a strong place.
PPWR Timing for Miron
The PPWR entered into force in 2025 and starts applying from August 12, 2026, with technical rules becoming clearer in 2027 to 2028, major design and recyclability requirements taking effect in 2030, real-world recycling performance becoming critical from 2035, and stricter packaging and reuse standards following toward 2040.
2025 to 2026: legal start and first customer communication
The regulation entered into force in February 2025 and became applicable across the EU on 12 August 2026.
For Miron, this is the preparation and communication phase. Before the August 12th, 2026, start date, customers should receive a clear PPWR compliance statement explaining how Miron packaging aligns with the regulation and where any future adjustments may be expected.
2027 to 2028: technical rules are defined
Between 2027 and 2028, the commission and standard-setting bodies will define the detailed methodology behind the PPWR. This is the phase in which the real rulebook becomes clearer for the five pillars.
For Miron, this means continued monitoring, validation, and refinement, especially around sorting compatibility, closure design, and reuse-readiness.
2030: first major compliance deadline
1 January 2030 is the first real turning point.
By then, packaging must:
Use no more material than necessary
Meet design-for-recycling requirements
Achieve at least Grade C recyclability
Comply with relevant reuse obligations
Meet plastic recycled-content rules where applicable
For Miron glass, the main pressure by 2030 will likely fall on closures and accessory components, rather than the glass body itself.
2035: recycling at scale becomes decisive
2035 marks an important shift: packaging will no longer only need to be recyclable by design, but also recycled at scale in real systems. For Miron, this makes system compatibility increasingly important, especially because its unique light-filtering glass can present challenges in optical sorting. That is why ongoing testing and validation are essential, alongside careful choices in labels, coatings, and components to support strong real-world recycling performance.
2038 to 2040: the bar rises further
From 2038, only higher-performing packaging grades remain on the market, and by 2040, reuse targets become much more ambitious.
For Miron, this points to a long-term direction:
Keep glass highly compatible with real recycling systems
Make closures simpler and more recyclable
Improve refill and reuse performance where relevant
Keep helping customers transition without major disruption
What This Means for Customers
For Miron customers, the impact of the PPWR is expected to be manageable and well supported. Miron glass is already strongly aligned with the direction of the regulation through its durability, recyclability, and suitability for reuse, so no major disruptions are expected for most customers. Ahead of the August 12th, 2026, start date, customers will receive a clear compliance statement outlining how their packaging aligns with the regulation. Miron is also working closely with leading EU partners to ensure future-proof solutions across its closure range. While some minor adjustments to products may occur over time, these are expected to be limited and carefully guided. As the rules become clearer, especially toward 2030 and beyond, customers will be kept informed and supported by their sales representative in making the right packaging choices.
Disclaimer
This document shows Miron’s current understanding of the PPWR as of the date below. It is for general information only and is not legal, technical, or regulatory advice. Because some PPWR rules and guidance are still being developed, the requirements may change over time. Miron may update this document as new information becomes available. Customers are responsible for checking what the PPWR means for their own products and packaging, and should seek independent advice if needed.
Updated: April 2026
FAQ About PPWR
Clear answers to your PPWR questions, from regulation basics to what it means for your packaging.
Understanding the PPWR
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What is the PPWR?The PPWR is a new EU packaging law. It applies to all packaging sold in the EU and aims to reduce waste, improve real-life recycling, and increase reuse over time.
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Why is the PPWR relevant to packaging supplied by Miron?It is relevant because Miron supplies packaging that is sold in the EU. If a business puts a product in packaging and sells it in the EU, the PPWR applies.
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Does the PPWR already fully define the rules for glass packaging?No. The law is in place, but some detailed technical rules and methods are still being developed. More guidance and technical criteria are expected between 2026 and 2028.
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Is Miron glass banned under the PPWR?No. Miron glass is strongly aligned with the direction of the regulation and starts from a strong place.
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What are the most important PPWR dates and milestones for customers?The key dates are February 11, 2025, when the regulation entered into force, August 12th, 2026, when it becomes applicable across the EU, January 1, 2030, when the first major hard requirements begin, January 1, 2035, when recycling at scale becomes important, and 2038 to 2040, when the rules become stricter.
Impact on Miron Products
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How does the PPWR affect Miron glass products and their customers?Miron glass is already in a strong position because it is recyclable, widely collected as colored glass in the EU, and well-suited for reuse. The biggest changes are more likely to affect closures such as caps, pumps, and pipettes. Customers are not expected to face major disruption and will be guided to alternative closures when needed.
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Should customers continue using Miron dark violet glass or consider alternative packaging formats to support future compliance?Customers can continue using Miron dark violet glass. Miron glass is described as well aligned with the regulation, and no major disruption is expected. The main focus for improvement is more likely to be closures and accessory parts.
Compliance & Documentation
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What is Miron’s current PPWR compliance status?Miron’s position is strong based on its current understanding of the PPWR. Miron glass already aligns well with the law’s goals in recyclability, durability, and reuse, but some rules are still being finalized. With our leading European partners, we are also focusing on our plastic closures. We are already moving away from materials like UREA and SAN plastics and switching to options like non-glued liners. As the market adapts to the new law, we expect to offer more alternatives. We will support and guide our customers through these changes in the coming years.
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What information can Miron already provide today regarding PPWR readiness?Miron can already explain how its packaging aligns with the direction of the PPWR and where future changes may be expected. It can also provide a clear ‘Declaration of Conformity’ (packaging passport) before August 12, 2026.
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What documentation can Miron provide to support PPWR readiness and future compliance?Miron will provide customers with a clear PPWR ‘Declaration of Conformity’ (packaging passport) for their packaging before August 12, 2026.
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Can customers continue to do business with Miron while the PPWR requirements are still being finalized?Yes. No major changes are expected for most customers, and Miron will keep supporting customers as the rules become clearer.
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Will Miron keep customers informed as the rules, guidance, and implementation details become clearer?Yes. Customers will be kept informed and supported by their sales representative, and Miron may update its document as new information becomes available.
Recycling & Environmental Performance
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Is Miron glass designed for recycling in line with EU design-for-recycling criteria?Yes, for Miron glass, this is already a strong position. Glass packaging is durable and functional, and Miron designs already avoid unnecessary mass. The main opportunity is continued lightweighting and improving optical sorting detection, without compromising its premium feel or protective properties.
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What recyclability class applies to Miron packaging, if available?Not defined yet. The official EU method and grading system are still being finalized.
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Is Miron glass effectively collected, sorted, and recycled at scale in existing EU waste systems?Yes. Miron glass is widely collected as colored glass and recycled across Europe, though performance varies by country. One point to watch is the unique light-filtering property of Miron glass. This can make it harder for optical sorting machines to detect it. The technique is already there and will improve with AI towards the 2035 deadline.
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How does dark violet glass perform in optical sorting systems and recycling facilities?It can be harder for sorting machines to detect due to its light-filtering properties. Some countries, like Finland, have better optical sorting machines. The technique is already there and will improve with AI towards the 2035 deadline.
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How does Miron address concerns that dark violet glass may not be properly detected and could end up in residual waste streams?Countries like Finland already have a glass recycling percentage of 98%. The technique is already there and will improve with AI towards the 2035 deadline. To help speed things up, we are testing small changes to our glass formula. The goal is to improve detectability without losing the protective function or the look of the glass.
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How does Miron address the difference between theoretical recyclability and recyclability at scale?Miron focuses on real-world performance, not just theory. Countries like Finland already have a glass recycling percentage of 98%. The technique is already there and will improve with AI towards the 2035 deadline. To help speed things up, we are testing small changes to our glass formula. The goal is to improve detectability without losing the protective function or the look of the glass.
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How does Miron ensure traceability of recycled content and provide supporting evidence?Miron is already ahead of the curve and has been providing traceability for many years.
Materials & Regulatory Requirements
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Does Miron packaging comply with restrictions on substances of concern, including REACH, SVHC, PFAS, or similar requirements?Glass does not contain PFAS. Where relevant, Miron will provide a PFAS statement before August 12, 2026, and offer alternative closure options.
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Does Miron packaging meet PPWR requirements for minimization of packaging weight and volume?Miron already has a strong position because its designs avoid unnecessary mass. It also says there is an opportunity for continued lightweighting without reducing protection, premium feel, or product preservation.
Closures & Component Design
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Are closures, pumps, caps, droppers, and other packaging components also relevant under the PPWR?Yes. Closures and other components are highly relevant and may face more pressure than the glass itself because they are often more complex and harder to recycle.
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How is Miron responding with regard to closures and other packaging components?Miron is working on simpler, more mono-material designs, better separability, less unnecessary plastic, fewer glued parts, and better alignment with real sorting and recycling systems. It is also moving away from materials such as UREA and SAN and switching to options like non-glued liners.
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How does Miron manage product or material changes that could affect composition, recyclability, or regulatory compliance?Miron is monitoring, validating, and refining its packaging and working with partners on improved solutions. It also says customers will be informed and guided if product or closure adjustments are needed over time.
Guidance for Customers
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What actions is Miron currently taking to prepare for PPWR compliance?Miron is monitoring the rules, validating its packaging, refining closure design, improving sorting compatibility, and working with European partners on simpler and more future-proof solutions.
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What should customers consider when selecting packaging under the upcoming PPWR requirements?Customers should consider recyclability, reuse potential, material simplicity, and closure design. They should also think about how packaging performs in real collection, sorting, and recycling systems, not just in theory. Miron can help you.