Navigating the evolving landscape of packaging regulation is like charting a course through a vast desert, where the sands constantly shift beneath your feet. Just when you think you have a clear path, the rules change, new challenges emerge, and what seemed like solid ground is no longer stable. It’s not a static, predictable environment; it’s a landscape in flux, where flexibility and adaptability are key. Much like walking across an ever-changing desert, where the dunes may shift in response to wind or storm, the packaging industry has to pivot quickly to stay on course – whether aligning with new laws, incorporating recycled materials, or embracing new technologies like chemical recycling.

Forward-thinking organizations, like Taghleef Industries, and Monica Battistella, sustainability manager, are leading the charge through these shifting sands. They understand that each step forward might feel like progress, but the terrain constantly evolves, pushing the industry to innovate and adapt faster than ever. At Taghleef, the focus is on keeping up with, anticipating, and shaping the future of packaging sustainability. As the packaging world faces these challenges, these proactive, agile companies will continue to find their footing and pave the way for a more sustainable, circular future.

“A lot is happening not only in Europe and the UK,” Battistella says. “Of course, the UK is not currently subject to the mandatory content of the PPWR, but because we are all in Europe and dealing with transactions and interactions between countries, we need some form of alignment. The content and the rules must create a foundation for all stakeholders to be appropriately informed and knowledgeable about the ‘rules of the game,’ so to speak.

“EPR is an important aspect of the PPWR, not because EPR is specifically part of the Sustainability Requirements set out in the PPWR, but because it is the tool that facilitates some of the major changes and sustainability requirements that are part of the PPWR. For instance, two key areas include recyclability and the use of recycled content. The EPR system can help enable, support, and trigger these aspects by introducing an eco-modulation system.

“This system rewards stakeholders who engage with and create recyclable packaging, working on designing packaging that is recyclable before bringing it to market. The second element, which is also part of the eco-modulation fee, is that if your packaging contains recycled content, you will pay less. This shows your commitment in different ways, particularly within the circular economy concept.

“To truly make this work, we need to put recyclable packaging on the market, as well as make use of recycled content. This helps create the conditions for materials and their value to be returned to the economy as precious secondary material. These are two linked concepts.”

An often overlooked yet critical issue is the role of recycled content, particularly in food contact applications. The complexities of current regulations, especially around the use of mechanically recycled materials, highlight a gap that needs addressing. For example, while PET bottles can be recycled back into food-grade products, most other materials are still not permitted for use in food contact due to compliance restrictions. This is where chemically recycled content could offer a viable solution, but it raises important questions about certification, traceability, and the criteria that ensure these materials meet safety standards and define conditions that are easily understood by the final consumer.

“Another important aspect of the discussion is the recognition of mechanically recycled content, due to the limitations of food contact compliance rules,” she adds. “EFSA has made it clear that, to date, it is not possible to use mechanically recycled content in food contact applications, except for PET bottles. These can be mechanically recycled and returned to the economy as bottles or other applications, such as the food-safe PET tray, for example. In the UK, HDPE milk bottles can also be recycled back into milk bottles. However, outside of these two exceptions, we do not see other materials allowed to return to food contact applications in Europe.”

As the industry evolves, Battistella emphasizes the importance of not only understanding but also clearly defining the frameworks that support the use of chemically recycled content.

“It’s crucial to clarify the acceptance of chemically recycled content, as well as the mass balance system and its underlying criteria. Additionally, we must ensure that valid, globally recognized certifications are understood and implemented. Stakeholders should fully grasp the concept of custody of change and the requirements for using mass-balance recycled content. Even those not currently required to be certified should still be encouraged to obtain the appropriate license, as the mass balance system and its solidity relies on full traceability across the value chain.

“This is a complex issue, but ensuring everything is traceable through proper documentation is essential to maintaining credibility in what we tell our customers and how we engage with them.”

The road to recyclability
The flexible packaging industry, focused on increasing recycled content, is turning to chemical recycling as a solution. There is growing anticipation for clear guidelines and investments to ensure these solutions align with 2030 and 2040 goals under the Packaging and Packaging Waste Regulation (PPWR).

Recyclability remains a significant challenge for flexible packaging compared to rigid plastics like PET bottles, which benefit from established collection and deposit return systems. These systems are efficient, making sorting and recycling less challenging and more valuable for processors.

“Flexible packaging, on the other hand, requires even higher level of efforts, when it comes to the sorting and recycling phases,” she continues. “Flexible packaging is lighter and smaller, which, of course, makes these processes even more challenging and the lightness, though one of the main positive properties of flexible packaging, may influence the final result when it comes to yields. Financially, this can make a huge difference. So, we need to make recyclability of flexible packaging economically viable for the whole system and all the stakeholders in the value chain.

“One way to achieve this is by collaborating with recyclers to ensure that investments are directed toward the right technologies, such as the ability to delaminate materials and remove inks, both steps which would guarantee better value for the materials being collected.

“Some countries are leading the way with exceptional efforts and can prove to have outstanding returns. Countries like Belgium, for instance, have shown impressive data regarding the achievements they have made in recycling, including for flexible packaging.

“However, there are others that are lagging behind, not only in the recycling phase but also in collection. For certain packaging types, such as PET bottles, we can implement deposit return systems, but for flexible packaging, we need proper investment in collection systems and infrastructure to ensure that what we collect can be sorted and then recycled.”

The recyclability targets set for 2035 present a significant challenge, particularly for flexible packaging. To meet recyclability at scale, the recycling rate must reach 55% for each product category, at EU level and on annual basis. A target that impacts every stakeholder across the value chain and requires more efforts on single country level, involving PROs and municipalities, as well. For stakeholders like ourselves, the challenge is to make sure that any solutions developed must not only help customers recyclable and valuable but also ensure essential characteristics are maintained. This includes ensuring performance during printing and on the packaging machinery, so that any novelty will need to meet or exceed current standards.

Despite the complexity of these challenges, the industry appears ready to confront them. Any event dedicated to the packaging industry brings together stakeholders who are proudly showing their active engagement in this process. So if the question is: Is the industry prepared to meet both current and future legislative requirements in their daily operations? The answer is “yes” the industry is ready to rise to the challenge. But we need to do it together, collectively.

“This is a good sign, showing that the industry is prepared for what’s ahead,” she says. “However, we need the support of everyone – from MEPs in the European Parliament to national governments, and all stakeholders in this industry. And we need to monitor carefully what’s happening outside EU, as well. Discussions are also ongoing in the UK regarding chemical recycling content acknowledgment – especially with reference to the Plastic Tax rules and the implementation of the EPR system. It’s crucial that the right decisions are made.

“I heard that the symbol and labelling for recycling in the UK has been put on hold while waiting for the alignment with the PPWR. I think this is a positive step. It shows the willingness of Europe as a market, as a region, to align and deliver a clear message on the market. I’m very pleased to hear this and feel optimistic about the direction we’re headed.”

Beyond closed-loop models
Circularity in packaging is often described as a closed-loop system, where materials are recycled back into the same product, like for PET bottles being recycled into new bottles. However, this isn’t always the case. Not for plastics and not even for other materials like recycled paper and aluminum, which can result in different products than the waste that originated it. This may be due to regulations and material constraints.

“What I’d like to underline is that there is a kind of expectation around circularity, particularly with plastics, which can sometimes be misleading,” she adds. “Circularity is a broad concept, and it can refer to closed-loop systems but this is not always the case. And if this concept applies for other materials, like paper or aluminum, the same should be for plastics.

“From this perspective, I think the challenge for flexible packaging is, first of all, to stop the expectation that it must be a closed-loop system. We need to accept that it can be used in other applications. For example, in the case of mechanical recycling, as of today, recycled resin can be used in flexible packaging but only for non-food applications.”

On the topic of recyclability, “We must also consider the broader picture. As of today, the functionality and lightness of flexible packaging, which also translates into reduced emissions and CO2 impact, is hard to beat. So, what are the implications if we stop investing in the recycling of flexible packaging because we focus on the hard to achieve closed-loop approach only? We should consider various ‘what if’ scenarios instead. What if we invest more in technology? What if we rethink our approach and look at our applications differently?”

As the packaging industry faces growing pressure to adapt to sustainability demands and regulatory shifts, many players are realizing that the status quo is no longer enough. The need to rethink traditional practices and embrace innovative solutions has never been more urgent. Major industry stakeholders are dedicating significant resources to preparing for future targets, but the reality is that not all players are equally equipped to navigate these changes.

“When I say stakeholders in the industry are ready to take the challenge, what I mean is that they are ready to think outside the box,” said Battistella. “It’s no longer business as usual. If you have been doing things in a certain way for the past 20, 30, or 40 years, the new situation forces you to explore new solutions, alternative materials, and different ways of approaching your pool and processes. It’s not just about the materials we use; we are being called to be more responsible in general, especially when it comes to our emissions.

“We see big names – such as the large brands and the major printing companies – along with the largest associations, are aware of what is happening. They are dedicating their time and efforts to studying, understanding, and preparing for the 2030 targets and beyond. The level of commitment required is real.

“However, the packaging market is not only made up of the big players, and smaller companies don’t have the possibility to dedicate resources or teams so that they are fully aligned and up to date with what is happening. We expect that the real wave of change will come as a shock to many of them,” she concludes.