The packaging landscape is changing, not gradually but in sharp regulatory leaps that are catching even seasoned players off guard. Across Europe, the rollout of Extended Producer Responsibility (EPR) rules is transforming everything from the design of packaging to the calculation of its costs. With stricter eco-modulation fees, mandatory recyclability thresholds, and mounting pressure for transparency, the cost of packaging is no longer just a materials issue. It is a data issue.

For producers and brand owners, this shift can feel like a minefield. But it is also a moment of rare opportunity. Alongside these challenges, digitalization offers an equally powerful path forward – a way not just to comply but to lead.

From data graveyards to strategic goldmines

At its core, EPR is about internalizing the environmental costs of packaging. To do that well, businesses need visibility and accurate, structured, shareable data. That means moving beyond PDFs in shared folders or specs buried in emails. It means knowing what is in your packaging, where it is used, how it performs, and what happens to it after use. It also means using that knowledge strategically to make better choices, unlock eco-modulation bonuses, and avoid spiraling costs.

Arno Melchior, retired Global Packaging Director at Reckitt, knows this challenge intimately. After more than three decades leading global packaging efforts at one of the world’s best-known FMCG groups, he has seen the data gap firsthand and the damage it can do.

“What I would like people to take back is really this,” Melchior begins. “While I was working, I got involved in many trade associations in the UK, Germany, and Brussels. You must always consider the large companies, such as P&G, Unilever and Reckitt, as well as other multinationals are data-driven. They have a lot of data.”

“But then you see the small and medium-sized companies,” Arno continues, “and often they don’t have proper specification systems. They get a PDF from their supplier and put it somewhere, maybe a printout in a folder or a digital folder. That’s where the specification lives.”

This lack of digitalization becomes critical under evolving regulations. “Then things come up, like now in the UK with EPR. Suddenly they think, ‘Oops, how do I get this data? Now I need to report something. How do I do this?’ And nothing is really digitized. I say it sits in the data graveyard. That’s something I want people to understand, especially smaller businesses.”

He believes that one of the most important steps any business can take is to assign a clear owner to packaging data. “It’s very important to have a person who deals with packaging. Whether full-time or part-time, maybe someone who covers quality and packaging, but they need to manage packaging data properly.”

That is especially true in the context of eco-modulation, the incentive structure that rewards recyclability with lower EPR fees and penalizes non-recyclable formats with higher ones. “That becomes more and more important, especially now with RAM, where you get a bonus with eco-modulation. You get your bonus when you have recyclable packaging and pay higher fees when your packaging isn’t recyclable. That will have a big impact on finances,” says Melchior.

The complexity is increasing fast. “We need more and more data,” remarks Melchior. “It’s not enough anymore to know a bottle is made of PET or HDPE. We need to know what makes up the HDPE or PET, what’s in the masterbatch, and what substances it contains. Soon, we’ll need a substance breakdown of our packaging, and that’s where suppliers and their suppliers come in. The whole value chain needs to work together, otherwise we don’t get the data.”

Educating the industry, empowering the consumer

But even the most sustainable packaging can’t make an impact if consumers don’t understand it, or worse, ignore it. “There is still a lot of greenwashing,” Melchior admits. “And retailers are becoming better at spotting it. But consumers? I don’t really believe they look at the sustainable aspect. When I talk to friends and family, I’m not sure they really take care of it. They look at the price, yes. However, they often don’t even know what it means. What does bio-based mean to them? What does 30% recycled content really mean?”

Education remains a critical, and often overlooked, part of the picture. “I try to educate my wife,” he adds, “but she says, ‘I can’t be bothered. I want to use the product.’ And with all the labels and icons on packaging, even specialists get confused. What is the difference between all the different recycling labels? I think the industry has confused consumers in the past.”

The latest EU Packaging and Packaging Waste Regulation (PPWR) aims to address some of that confusion with tighter guidelines around recyclability labelling. But as Melchior points out, implementation isn’t always straightforward. “There are lots of discussions, should labeling have text or not? Should it be colored or uncolored? The EU says the minimum size of a recycling label should be one by one centimeter. That’s fine for a 750 ml bottle but impossible for something small like a lipstick. For small, one-color printed packs, how do you put a colored label? We need clear, common signs to inform consumers about whether and how they can recycle something. That’s essential for improving recycling.”

These insights are not theoretical. Melchior speaks from deep, hands-on experience. “I’ve been to many MRFs (Materials Recycling Facilities), the first in 1992. Soon afterwards I visited for the first time a glass recycler. I learned that labels on glass don’t just burn off – the adhesive area is waste and gets thrown out with the glass. That was eye-opening.”

Such learnings continue to inform new initiatives. “We’re looking now at how to make glass bottles, like Gaviscon, more recyclable. It helps a lot if the whole industry, the whole value chain, comes together.”

It is also a reminder that EPR is a global concern and digitalization must scale accordingly. “If someone collects data just for the UK, I say, ‘Forget it.’ That might help a small UK-only company, but for us, even Europe is too small. Ideally, you cover all countries where EPR applies. And not only EPR, with initiatives like the Ellen MacArthur Foundation, you need global data. Wherever you have a factory, even without EPR, you need to know your materials and tonnage.”

From compliance to competitive edge

Tools like Recyda are stepping into that space, empowering producers with software that maps out EPR fees, recyclability scores, and environmental data across markets. “Tools like Recyda, which show the fees in different countries, allow you to calculate costs for different packaging variants. The cost of EPR is now so high you can’t ignore it anymore. It’s a considerable part of your turnover. You need to consider ways to reduce this cost. The cheapest way is to consider it early in new projects and rule out expensive options with the right predictive tools.”

For Melchior, part of the solution lies in rediscovering the value of in-person learning and industry collaboration. “Events like London Packaging Week are important opportunities to discuss issues and discover innovations. When I was a young engineer, I planned visits to fairs based on who was exhibiting, but you miss a lot that way. Now I walk aisle by aisle, meeting people, asking questions, and finding new ideas. That’s why I’ve always enjoyed going to fairs.”