Fenton Fitzwilliam

For packaging manufacturers, this marks a pivotal turning point. The EU Packaging and Packaging Waste Regulation (PPWR), which begins to apply from this August, will fundamentally reshape how packaging is designed, produced, used and recovered. While the Regulation presents significant challenges, it also opens the door to innovation, competitiveness and long‑term sustainability across the sector.

With the Government preparing to publish an updated Waste Action Plan for a Circular Economy (WAPCE) later this year, the coming months offer a crucial window for industry to work collaboratively with policymakers. Constructive engagement now will help ensure that Ireland’s approach to PPWR is both ambitious and practical, enabling the country to meet its recycling and waste‑reduction targets.

EU Packaging and Packaging Waste Regulation

At the beginning of 2025, the EU Packaging and Packaging Waste Regulation (PPWR) was published. The regulation replaces the existing Packaging Waste Directive and sets out far-reaching measures to prevent packaging waste and promote recycling and reuse. PPWR sits within the broader ambitions of the EU’s circular economy agenda, reflecting growing concern about rising levels of packaging waste.

PPWR mandates that all packaging be recyclable or reusable, introduces strict recyclability grades that create standards that packaging is both recyclable and made of high-quality materials that can be efficiently processed and reused, and emphasises Extended Producer Responsibility (EPR), shifting more responsibility onto producers for managing their packaging throughout its entire lifecycle.

Recycling targets

The European Green Deal emphasises the need for waste reduction. Therefore, the EU’s waste hierarchy gives highest priority to waste prevention, followed by preparing for re-use and recycling.

In line with this, the headline target of the PPWR is to reduce packaging waste by 15% by 2040 per Member State compared to 2018 levels. In practice, this will mean reducing unnecessary packaging, encouraging reuse and refill systems, and redesigning products to minimise material use.

PPWR also sets out binding recycling targets by material. All packaging must reach a 65% recycling rate by 2025 and 70% by 2030.

Specific material targets include:

Plastics: 50% by 2025 and 55% by 2030.
Wood: 25% by 2025 and 30% by 2030.
Ferrous metals: 70% by 2025 and 80% by 2030.
Aluminium: 50% by 2025 and 60% by 2030.
Glass: 70% by 2025 and 75% by 2030.
Paper and cardboard: 75% by 2025 and 85% by 2030.

These targets are legally enforceable and apply across the EU.

While Ireland has undertaken a number of measures to improve packaging recycling rates, such as the introduction of the Deposit Return Scheme (DRS), the Environmental Protection Agency (EPA) has reported that without a significant increase in recycling, we are not going to meet the targets set out in PPWR.

EPA data shows that since 2016, packaging waste generation has increased almost four times faster than packaging waste recycling has increased. Recycling, therefore, cannot keep up with packaging waste generation. Ireland’s overall packaging recycling rate in 2023 was 59%, 6% behind the 2025 target of 65%. Nonetheless, this stagnation in recycling rates means that it will be challenging for all material streams, except wood and glass, to meet their targets.

Ireland’s waste management landscape

The recently published Whole of Government Circular Economy Strategy 2026-2028 notes progressing towards PPWR targets as a key action in relation to packaging. However, it is unclear exactly how this progress will be achieved. The Strategy states that many of the details regarding PPWR implementation remain to be elaborated in secondary legislation (implementing and delegated Acts) to be agreed at a European level. Until these measures are finalised, a degree of regulatory uncertainty will persist for both policymakers and industry.

As noted above, there have been positive policy developments in the waste management space in Ireland. The DRS is an example of this, with over 2.4 billion bottles and cans returned for recycling via the scheme. However, the scheme addresses only a fraction of overall packaging placed on the market. PPWR targets apply to all packaging streams, including commercial and industrial packaging, and therefore require a broader systemic response.

Shaping Ireland’s path to PPWR compliance

The upcoming update of the Waste Action Plan for a Circular Economy (WAPCE) offers Government a critical opportunity to set out a clear, credible pathway to PPWR compliance. While the Regulation sets binding EU‑wide targets, Member States retain significant discretion in how those targets are achieved. Ireland’s national approach will therefore be shaped by decisions made in the months ahead.

The drafting of the WAPCE is a crucial moment for industry to engage with Government regarding how Ireland will meet its PPWR targets to ensure that the Action Plan sets out a realistic and supportive framework.

There are a number of innovative solutions that can improve recycling rates in Ireland and move us closer to meeting the PPWR targets. However, collaboration between the packaging industry and Government is essential to ensure these solutions can be rolled out throughout the country in a sustainable way. Knowledge sharing between industry and policymakers is also essential in understanding how to further change consumer behaviour

Although PPWR targets are fixed, how Ireland delivers on them is still to be determined. For packaging manufacturers, this is the time to step forward, contribute practical insights and help shape an implementation model that works.

Grace Donnellan

Fenton Fitzwilliam supports organisations in engaging Government strategically, communicating their expertise, and influencing the development of national policy. If your organisation wants to play a proactive role in shaping Ireland’s approach to PPWR, our team can help you lead that conversation and ensure your voice is heard.