How the PPWR defines reduction

The PPWR implements reduction on several levels:

a) On primary packaging – Article 10
Article 10 states that packaging weight and volume must be limited to the minimum necessary. Can the bottle be thinner? The jar smaller? The tray narrower? Then we have to make that change. Every unnecessary gram counts.

b) On secondary and tertiary packaging – Article 24
Especially in e-commerce and transport, Article 24 sets strict limits: a maximum of 50% empty space in shipping packaging. So, no shoebox for a lipstick; air freight yes, but no freight full of air.

c) By banning specific packaging types – Annex V
Annex V explicitly lists packaging formats that will no longer be allowed as of 2030. For example, double packaging, unnecessary sleeves, or non-functional miniatures.

And don’t forget the paperwork

Article 38

We’d also like to draw your attention to a part of the PPWR that hasn’t received much focus yet: the documentation of your packaging sustainability efforts. Because whatever you do—or choose not to do—you will need to record it.

According to Article 38, producers must be able to demonstrate through an internal production control that their packaging complies with Articles 5 through 12. This includes:

• Documenting the considerations made,
• Archiving test results (such as drop tests for thinner bottles),
• Substantiating conclusions and ensuring they are traceable.
  Specifically, Article 10 even has its own annex (Annex IV) detailing the assessment method for minimising packaging.

It is expected that this information may eventually be subject to audits. A solid packaging administration won’t be a luxury—it’ll be a necessity. After all, how unfortunate would it be to put sincere effort into reducing packaging, but fail to present the process during an audit? That would put you at risk of non-compliance with Article 38 and its associated Annex VII. And let’s be clear: this administration isn’t meant to be a burden. If used well, it can actually work in your favour. You’ll see that with the other strategies too.

“This all sounds like a lot of hassle…”

Yes, it’s complex. But it doesn’t have to be difficult.

Take laundry detergent. We've known it in concentrated form for years now. We even find it convenient, powerful, and space-saving.

But with deodorant? Suddenly not. In our May blog, we discussed this phenomenon: we skipped the small bottle of concentrated deodorant because we thought the big, non-concentrated one offered more value for money. Same principle, same user—but the smaller can felt like “less product.” So we left it on the shelf. Strange, isn’t it?

Or look at Lavazza’s latest innovation: the Tablì. A coffee tablet with no primary packaging. No capsule, no sachet, no foil. Just coffee. REDUCE to the bone.
Hans van Bochove (Head of EU Affairs at Heineken) recently said it well at a Dutch Ministry of Infrastructure and Water Management event:
“A lot of the PPWR can be figured out with just common sense.”
Let’s not forget that. Sure, it’s a lot of work. And sure, not everything is crystal clear yet. But a lot of it is just common sense—and that means you can get started today.

Less is better. And we all understand that. The examples are there.