Under the provisions of the PPWR Regulation, the role of manufacturer is not always fulfilled by the entity that physically produced the packaging in question. In some cases, the manufacturer of the packaging may be the brand owner, an importer or a distributor. Find out how the PPWR Regulation defines a manufacturer and learn about the obligations that this entity must fulfil.

Who is a manufacturer under the PPWR Regulation?

In accordance with Article 3(1)(13) of the PPWR Regulation, a packaging producer is any natural or legal person who:

• produces (i.e. physically produces) the packaging or the product inside the packaging, or
• draws up specifications, commissions the design or manufacture of the packaging or the product inside the packaging under its own name or trade mark. In this case, it is irrelevant whether another party’s trade mark appears on the packaging or the product. What is decisive is who determines the design and specifications of the packaging and markets it under their own brand.

Exception: If the business commissioning the production of packaging is a micro-enterprise and the packaging supplier is established in the same Member State, the packaging supplier, rather than the brand owner, is deemed to be the producer.

Throughout the EU, each package may have only one manufacturer within the meaning of the PPWR Regulation.

See also: Who is a producer within the meaning of the PPWR regulations?

‘Producer’ as defined in the PPWR – practical examples

Manufacturer retail or bulk packaging is usually the entity that fills is the manufacturer of the product and places it on the market in the EU. In practice, this is usually the owner of the product’s brand. This rule does not apply to service packaging (e.g. drink cups, takeaway food boxes).

Example 1: A cosmetics manufacturer orders empty cream jars, then fills them, seals them, packs them into the cardboard boxes supplied to it, and sends them to a wholesaler. The cosmetics manufacturer is the producer of both the cream jar and the cardboard box, even though both items of packaging were physically manufactured by other businesses.

Example 2: A mobile café sells drinks prepared on the premises in multi-material cups without a logo. The café owner does not manufacture these cups.

The manufacturer of transport packaging, service packaging and packaging for primary production is the actual manufacturer of these packaging items. However, if such packaging bears the logo, trademark or brand name of another entity, then its manufacturer, within the meaning of the PPWR, is the owner of a trade mark or logo.

Example 3: The franchisee sells hot dogs in paper wrappers bearing the franchise chain’s logo. These wrappers are manufactured by the owner of the franchise chain, not by the business owner running the outlet.

Under the PPWR, the importer or distributor of packaging may also be regarded as its producer. This is the case if:

• an importer or distributor places packaging on the market under their own name or trade mark,
• an importer or distributor modifies packaging placed on the market in a way that affects the compliance of that packaging with the requirements of the PPWR Regulation.

Example: Company X imports porcelain mugs from China, packed individually in cardboard boxes. Company X then affixes plastic labels to each of these packages, containing washing and care instructions for the mugs (on the back of the package) and its own logo and the mug’s brand name (on the front of the package). Company X incorporates an element made of a different material into the original packaging, which is relevant to assessing the packaging’s compliance with the requirements of the PPWR; it therefore becomes the manufacturer of that packaging.

The obligations of packaging manufacturers under the PPWR Regulation

Packaging manufacturers must fulfil a number of obligations in relation to the packaging they place on the market. For this reason, operators involved in the packaging supply and distribution chain within the EU must ensure that they correctly identify both their role and the list of their legal obligations.

The main responsibilities of packaging manufacturers include, in particular:

• carrying out the conformity assessment procedure packaging (either independently or in collaboration with relevant organisations, such as testing laboratories),
• drawing up and updating the EU declaration of conformity confirming compliance with the PPWR requirements,
• preparation and storage technical documentation and the EU declaration of conformity for the period required by law (5 or 10 years, depending on the type of packaging and its intended use) and making them available upon request by the competent authorities,
• ensuring compliance and identification packaging manufactured in accordance with the requirements of the PPWR Regulation,
• to be displayed on every package a number that enables it to be uniquely identified (e.g. serial number, production batch number),
• to include on the packaging or in a QR code their name, registered trade name or trade mark, postal address and electronic contact details (where available). All information must be provided in a clear and legible manner and positioned so as not to obscure other mandatory information and markings on the packaging,
• notifying the relevant authorities of suspected non-compliance its packaging with the requirements of the PPWR Regulation and the corrective measures taken to remedy this non-compliance.

The full list of a manufacturer’s obligations within the meaning of the PPWR is set out in Article 15 of the Regulation.

The PPWR Regulation not only amends the requirements regarding the design and labelling of packaging, but also the method for determining the entity responsible for fulfilling the obligations arising from extended producer responsibility (EPR). Find out who is considered a producer under the PPWR and learn how to correctly determine your company’s role in various EU markets.

Who is considered a manufacturer under the PPWR Regulation?

The PPWR Regulation defines a producer as a manufacturer, importer or distributor who – depending on the type of packaging, place of business and method of distribution – places the packaging or the product in its packaging on the market of a given Member State for the first time or unpacks the product from its packaging without being the end user. The packaging or the product within the packaging may be made available through traditional sales channels or any form of distance selling, including online sales and telephone sales.

The aim of this regulation is to identify an entity which is located at the start of the supply chain in the Member State in question, and, consequently, should be held liable for packaging or packaged products placed on the market in that country for the first time.

In practice, a ‘manufacturer’ within the meaning of the PPWR regulations may be:

• manufacturer the packaging or the product inside the packaging,
• importer the packaging or the product inside the packaging,
• distributor the packaging or the product inside the packaging,
• an online retailer, who makes the packaging or the product in its packaging available directly to end users in another EU Member State,
• a trader who unpacks or repacks goods prior to their further distribution (only if the above points do not apply).

The PPWR Regulation introduces the principle „one manufacturer for each packaging unit”. This means that, in a given Member State, for every packaging unit, there is always one entity responsible for fulfilling the obligations of the ROP (. EPR) – regardless of how complex the supply chain is.

Are you a manufacturer of packaging or packaged products? Check your EPR obligations in various EU markets >>

‘Producer’ and ‘manufacturer’ in the PPWR Regulation

One of the most common mistakes made by companies operating within the supply chain is to equate a producer with a manufacturer. A manufacturer may also be a producer, but not in every case – The PPWR Regulation distinguishes between these two entities and assigns different responsibilities to each of them.

Manufacturer an entity that manufactures the packaging or the product in the packaging itself, or an entity that commissions the packaging and determines its specifications. Every package placed on the EU market has only one manufacturer, who is primarily responsible for ensuring that this packaging complies with the requirements of the PPWR Regulation regarding design, sustainability and labelling.

Example: Company X orders boxes for sports shoes from Company Y – specifying their exact shape, dimensions and colours, and requesting that its logo be printed on the lid of each box. In this situation, Company X is the manufacturer of the boxes.

Who is the packaging manufacturer? Check the definition and exceptions (article coming soon)

Manufacturer whereas they place the packaging or the packaged product on the market of a given EU Member State for the first time. They are responsible for fulfilling the obligations arising from extended producer responsibility in that Member State.

Example: Company Z operates a chain of supermarket stores in Poland, where it sells packaged products under its own brand. Company Z is the packager of these products (across the whole of the EU) and, at the same time, their manufacturer (within Poland).

When is an importer or distributor considered a manufacturer?

If the packaging manufacturer does not meet the definition of a producer within the meaning of the PPWR (i.e. does not place the packaging or the product in packaging on the market in a given Member State), then the importer or distributor of the packaging or the product in packaging, who meets the conditions set out in the definition of a producer, may be deemed to be the producer of the packaging or the product in packaging within the meaning of the PPWR Regulation, and makes them available for the first time within the territory of a given EU Member State.

If a natural or legal person purchases packaging (empty or containing a product) from another Member State or from outside the EU, and is then the first to place it on the market in one or more EU countries, that person may become the producer of the packaging or the product contained therein and will be required to fulfil the EPR producer’s obligations in each of those countries.

Example: A Polish company imports wholesale quantities of packaged cosmetics from Italy and begins selling them on the domestic market. Although it has not manufactured either the cosmetics or their packaging, it is regarded as the manufacturer in Poland because it was the first to make the packaged products available on the Polish market.

The owner of an online shop as a manufacturer of packaging and packaged products

If a business or an individual sells packaging or packaged products directly to end users in another Member State, rather than the country in which it is established, may be regarded as a producer within the meaning of the PPWR in that country and will be required to fulfil the obligations arising from the local EPR scheme. This means that any entity selling online to individual end-users located in a dozen or so EU countries is simultaneously a producer in all those countries and is subject to local EPR obligations in each of them. This mainly applies to businesses operating online shops, teleshopping and other distance selling channels.

Importantly, the PPWR Regulation explicitly states that in the case of distance selling simply offering the packaging or product to the end user (e.g. via an online shop or an e-commerce platform) is regarded as placing it on the market.

Example: This Polish jewellery manufacturer handcrafts its products and packages them in decorative boxes. It offers all its products via its online shop to end customers – private individuals throughout the EU. The manufacturer is therefore both the producer and the packager of the products in each EU Member State.

Unpacking and repackaging of products in accordance with the PPWR Regulation

A manufacturer, importer or distributor may also meet the definition of a producer where they unpack products from their packaging prior to their further distribution. This applies, amongst others, to logistics companies that are not end-users, which they repackage the goods into smaller packs, and then pass them on to other entities for sale.

How can you determine whether your company is a manufacturer within the meaning of the PPWR?

Assessing whether a given entity is a manufacturer within the meaning of the PPWR requires an analysis not only of the company’s activities themselves, but above all of its role within a specific supply chain.

Although the levels of separate collection of plastic waste are rising year on year, Poland is still failing to realise the potential of the raw material it collects. A report published in May 2026 by Plastics Europe shows that most plastic waste does not end up being recycled, but is sent to incinerators. The low circularity rate for plastics is not merely an environmental issue – at a time when Europe is increasingly committed to the circular economy and is mandating the use of recycled materials, this situation could lead to serious problems with the availability of recycled raw materials and a decline in the competitiveness of Polish companies.

We’re harvesting more and more, but we’re still not processing enough

The latest report from Plastics Europe The Circular Economy for Plastics – A European Analysis 2026 provides further worrying information that highlights the problems facing the Polish and EU plastic recycling sectors. According to the data presented in the report, 2.089 million tonnes of post-consumer plastic waste were collected in Poland in 2024. Only 436,000 tonnes, or 21% of the total stream, were sent for recycling. This means that only around one-fifth of the plastic was returned to the material cycle. The remainder of the waste was managed using other, less sustainable methods – as much as 865,000 tonnes, or 41.4%, of plastic waste was sent to incinerators, whilst 788,000 tonnes (37.7%) was disposed of in landfill. However, from a circular economy perspective, incineration should be a last resort, used only when recycling is not economically viable or impossible due to a lack of suitable technology.

Low levels of plastic recycling have a negative impact on manufacturers of raw materials and plastic products. The limited supply of recycled plastic, combined with price competition between virgin and recycled plastic, means that Only the 30% plastic production process currently relies on recycled materials – both post-consumer (19.6%) and pre-consumer (10%). The remaining 70% of plastics are still produced from virgin raw materials derived from fossil fuels.

Poland is no exception. Europe is also grappling with this problem

Excessive landfilling and insufficient recycling are not merely local problems – similar trends are observed across Europe. A report by Plastics Europe shows that of the 32.7 million tonnes of plastic waste collected in the EU27+3 countries, only 29.6% was recycled. At the same time, as much as 48.9% of waste was sent to incineration plants, and a further 21.5% to landfill sites. This means that over 70% of plastic waste is still not being returned to the material cycle.

Of all plastic waste Packaging waste comes closest to being circular – In Poland, 30% of plastic packaging is recycled, whilst the average for the EU+3 is 40.5%. Plastic waste from agriculture and horticulture ranks second (20% in Poland and 32.5% in the EU27+3). Between 2022 and 2024, both of these waste streams recorded an increase in their recycling rates. The opposite trend is evident in the category of plastic waste from the automotive sector – currently, 9% of this waste is recycled in Poland (compared with an EU average of 17.7%), and between 2022 and 2024, the EU recycling rate for this waste stream fell by as much as one-third.

Data from the automotive sector is particularly interesting in view of the approaching Vehicle ROP – The new regulations are set to require manufacturers to use at least 20% of recycled material in the production of new vehicles.

The authors of the report point out that, despite the increase in collection and sorting rates, Europe still lacks sufficient recycling capacity, and some of the sorted waste is exported outside the region for further processing. To prevent the loss of raw materials caused by exports and to protect third countries from excessive environmental burdens, the EU has amended the rules on cross-border shipments of waste, introducing, amongst other measures, a ban on the export of plastic waste.

Find out about the new regulations on the cross-border shipment of waste >>

Separate waste collection is still important

The Plastics Europe publication focuses not only on systemic issues, but also highlights the importance of individual efforts and actions. One such effort is the separate collection of plastic waste, which enables a significant amount of raw material to be returned to the cycle. The current recycling rate for separately collected plastic stands at 46.5%, whereas for waste entering the mixed waste stream, this figure is only 2.3%.

Countries that invest in technologies for sorting residual waste stand out significantly above the EU average. Thanks to improved sorting processes in Germany, Poland and Spain, it has become possible to recover a greater quantity of plastics from mixed waste, and the recycling rate for plastics from this stream has risen from 3.8% to 5.6%. However, separate collection remains the main source of waste sent for material recycling. Experience in these countries shows that even the most advanced sorting technologies are unable to completely replace source-separated collection. Mixed waste is significantly more contaminated, which limits its potential for reuse and increases the likelihood of it being sent for thermal treatment at a waste-to-energy plant.

Sources:

1. A dramatic slowdown in Europe’s transition to a circular plastics system, https://plasticseurope.org/media/circular-economy-report-2026-dramatic-slowdown-in-plastics-circularity/
2. Plastics Europe, The Circular Economy for Plastics: A European Analysis, https://plasticseurope.org/wp-content/uploads/2026/05/Circular-Economy-Report-2026-full-report.pdf
3. Poland is drowning in plastic. Only 21 per cent is recycled, https://www.bankier.pl/wiadomosc/Polska-tonie-w-plastiku-Tylko-21-proc-trafia-do-recyklingu-9135839.html
4. Plastics Europe, The Circular Economy for Plastics: A European Analysis – Executive Summary, https://plasticseurope.org/wp-content/uploads/2026/05/CER26-SINGLEPAGE-Executive-Summary.pdf

On 30 April 2026, the annual „Clean Odra” campaign came to an end, during which volunteers collected litter from the riverbanks and the water for the fifth time. One stage of the campaign involved not only a major clean-up, but also an analysis of the composition of the waste, which served as a test of the effectiveness of Poland’s waste management policy and the new measures implemented over the past 12 months.

Waste composition from the 5th edition of the ‘Clean Odra’ campaign

Thanks to the commitment of the Waste Free Oceans (WFO) Foundation, Dominik Dobrowolski, the West Pomeranian Province Landscape Parks Team and the Regional Water Management Authority in Szczecin (Wody Polskie), On 22 April 2026, an analysis was carried out of the composition of the waste collected during the clean-up campaign in Międzyodrze in the Lower Oder Landscape Park. This was the first study of its kind covering the period following the introduction of a deposit scheme for PET bottles and cans in Poland. It therefore had the potential to provide answers to questions regarding the rationale behind the implementation and the effectiveness of the Polish deposit scheme model.

During this one-day event, the following was collected:

• 240 kg of glass,
• 77 kg of plastic,
• 6 kg of aluminium cans not subject to a deposit,
• bulky waste (including tyres, garden furniture and other items).

We discuss the Odra clean-up campaign and other nature conservation initiatives in more detail on the ‘Eko bez kantów’ podcast: A clean Oder, a clean Vistula – is that possible? An interview with Dominik Dobrowolski

The deposit scheme is working – just two returnable bottles in Międzyodrze

As expected, the analysis of the composition of the waste collected during the clean-up of Międzyodrze has yielded some interesting findings regarding the recently launched deposit-refund scheme. During the all-day clean-up operation the volunteers found just two returnable bottles. Importantly, the result from Międzyodrze was no fluke – the organisers of the „Clean Oder” campaign noted that This year’s campaign collected far fewer plastic bottles and cans than in previous years. Although these figures do not yet conclusively prove the effectiveness of the deposit scheme, they clearly show a trend that is likely to continue in the coming months – packaging with economic value rarely ends up in the environment.

For environmental experts, this is a sign that a well-designed scheme based on a financial incentive to return packaging can reduce the amount of litter in the countryside.

Is single-use glass the new plastic?

The introduction of a deposit-return scheme and a significant reduction in the amount of discarded plastic packaging have led to a noticeable change in the composition of the waste collected during clean-up operations along the River Oder. In previous editions of the campaign, PET bottles and aluminium cans made up the bulk of the contents of the volunteers’ bags, but in 2026 these were replaced by single-use glass bottles. A morphological analysis showed that as much as 60% of the total mass of collected recyclable waste consisted of glass. Next on the list was waste that has been lying in the environment for years and is not regularly removed by local authorities. This mainly refers to old PET bottles and aluminium cans, which volunteers mostly found in hard-to-reach places.

The event organisers emphasise that glass waste is not merely an aesthetic problem – although it does not break down in the environment and does not emit harmful substances, it can pose a fire risk, and, when broken, it poses a danger to people and animals.

The results of the analysis and a detailed report on the Odra clean-up campaign have contributed to the ongoing debate on the possibility of introducing a deposit scheme for single-use glass bottles, particularly the so-called „małpki”. Small alcohol bottles are one of the most common types of litter found in the natural environment and in urban areas. Including them in the deposit-return scheme could have a measurable environmental impact comparable to that currently seen with PET bottles – instead of ending up in the natural environment, the glass would go into a bottle return machine and then be recycled. The Ministry of Climate and Environment is currently working on such a solution. The outcome of this work and the final decision on the future of single-use glass bottles will likely be announced after the summer holidays.

Read also: New rules for returning glass bottles under the deposit scheme >>

From 19 July 2026, large fashion companies will no longer be allowed to destroy unsold textiles – the ban will come into force on that date, although there will be certain exceptions. The new rules form part of the EU’s ESPR Regulation (Regulation on Ecodesign for Sustainable Products), which promotes sustainable production and supports the circular economy.

Who will be affected by the ban on the destruction of unsold textiles? Scope in terms of entities and subject matter

The European Union is introducing further legislation aimed at accelerating the transition to a circular economy. It will come into force as early as 19 July 2026 a ban on the destruction of unsold textiles – clothing, footwear and fashion accessories. It will cover not only products that have not been purchased by consumers – in accordance with the ESPR Regulation, „”unsold products’ also include products that were never put on sale (e.g. prototypes, post-show models or those from photo shoots) and products from returns made by consumers under their right to withdraw from a contract.

The last three operations listed in the waste management hierarchy – recycling, other recovery and disposal – will be classified as destruction. However, preparation for reuse, refurbishment and reconditioning will not be classified as destruction.

The ban on destroying unsold clothes and footwear will be introduced gradually – From 19 July 2026, new obligations will be imposed on large companies employing more than 250 staff. On 19 July 2030, i.e. four years later, the scope of the provisions will be extended to include medium-sized enterprises employing between 50 and 250 staff. To avoid excessive administrative burdens, micro-enterprises and small enterprises have been exempted from the ban on the destruction of textiles.

The EU legislator has also provided for a mechanism designed to prevent abuse and eliminate unfair practices by the largest market players. Article 25(2) of the ESPR Regulation provides for a mechanism designed to protect the smallest economic operators – small and micro-enterprises, which have been exempted from the scope of the new rules – must not destroy unsold consumer products that were supplied to them solely for the purpose of circumventing the ban.

Clothing and footwear covered by the ban on destruction

The products covered by the ban on destruction included unsold clothing, clothing accessories and footwear classified under the following CN codes:

• 4203 Articles of clothing and clothing accessories, of tanned leather or reconstituted leather
• 61 Knitted garments and clothing accessories
• 62 Non-knitted articles of clothing and clothing accessories
• 6504 Hats and other headgear, plaited or made by weaving strips of any material, whether or not lined or trimmed
• 6505 Hats and other headgear, knitted or crocheted, or made of lace, felt or other textile materials, in the piece (but not in strips), whether or not lined or trimmed; hairnets of any material, whether or not lined or decorated
• 6401 Waterproof footwear with soles and uppers of rubber or plastics, where the uppers are not attached to the sole or joined to it by stitching, riveting, nailing, screwing, pinning or similar means
• 6402 Other footwear with soles and uppers of rubber or plastics
• 6403 Footwear with soles of rubber, plastics, tanned leather or reconstituted leather, and uppers of tanned leather
• 6404 Footwear with soles of rubber, plastics, tanned leather or reconstituted leather, and uppers of textile materials
• 6405 Other footwear.

Exceptions to the ban on the destruction of unsold clothing and footwear

As stated in the explanatory memorandum to the ESPR Regulation, The destruction of unsold textile products is a common occurrence – it affects as many as 4-9 % for all products available on the EU market. The overproduction of textiles and their short lifespan have a negative impact on the environment and lead to the loss of valuable economic resources; they must therefore be resolutely combated.

Preventing damage to clothing and footwear must not be pursued at any cost; therefore, in the Commission Delegated Regulation of 9 February 2026,. A number of derogations have been established, relating mainly to safety, public health and intellectual property rights. In any case However, the manufacturer must provide evidence justifying the destruction of the products, and then retain the documentation collected for a period of 5 years and make it available upon request by the supervisory authority.

Read also: There will be a ROP for textiles >>

Mandatory disclosure of information on unsold consumer products

Pursuant to the ESPR Regulation Manufacturers who destroy unsold textile products will be required to disclose information o:

• the annual number and weight of products destroyed, broken down by type and category,
• the reasons for product damage,
• the method of managing textile waste and the percentage of products that have been prepared for reuse (including refurbishment and regeneration), recycling and other forms of recovery (including energy recovery),
• measures taken and planned to prevent the destruction of products in the future.

All this information must be included on the website the manufacturer and worded in a clear and legible manner. This is intended to discourage manufacturers from disposing of unsold consumer products, whilst at the same time providing information on the scale of this phenomenon.

On 21 May 2026, Regulation (EU) 2024/1157 of the European Parliament and of the Council (EU) 2024/1157 of 11 April 2024, introducing the most significant reform of the rules on transboundary movements of waste (TPO) within the Community in over a decade. The new regulations are intended to strengthen controls over the international transport of waste, limit its export outside the EU and contribute to the development of the circular economy.

The DIWASS system – mandatory digitisation of cross-border waste shipments

From 21 May 2026. All EU entities participating in the TPO are required to use the DIWASS system (English. Digital Waste Shipment System), which is used for the electronic transmission of all transport-related documentation. It is intended to streamline administrative procedures, increase the transparency of the waste shipment process and facilitate the work of the supervisory authorities, which will gain full access to the documentation.

The following must be submitted via the DIWASS system: documents submitted as part of the notification procedure (i.e. prior written notification and consent), as well as those relating to information procedures. The only part not yet covered by the digital system is Annex VII, which relates to the shipment of waste on the so-called ‘green list’. As reported by GIOŚ, Between 21 May and 31 December 2026, Annex VII may be submitted in paper form, whilst the creation of an electronic version of the document will remain optional. From 1 January 2027, all documentation relating to the transboundary shipment of waste will be maintained exclusively in electronic form.

New regulations enable the completion of proceedings initiated under Regulation (EC) No 1013/2006. Permits issued in accordance with the previous regulations remain valid for the period specified therein, provided that the final recovery of the waste is completed:

• until 20 May 2027, if the customer’s installation is not covered by a preliminary authorisation,
• until 20 May 2029, provided that the customer’s installation is covered by a preliminary authorisation.

Przemysław Kurowicki, an expert on transboundary waste shipments, provided a detailed explanation of the new rules on waste shipments and the operation of the DIWASS system during a free Interzero webinar:

Who is required to use the DIWASS system?

The obligation to register with and use DIWASS rests with all entities involved in TPO, namely:

• the party submitting the TPO,
• organiser of the movement,
• carrier,
• recipients,
• waste producers,
• the operator of a waste treatment plant.

Before submitting the first documents Entities subject to the obligation must register with the DIWASS system. During registration, they must provide their main identification number – the EORI number, or, if this is not available, their NIP – as well as the required registration numbers, in particular the REGON number and the BDO number. Registration requires approval by the Chief Inspector of Environmental Protection (GIOŚ).

It will be possible to submit data and documentation via the DIWASS system once the registration has been approved by GIOŚ.

The DIWASS system will also be used by authorities responsible for handling notifications and supervising TPO. Currently, in Poland, these powers are held by the Department for the Transboundary Movement of Waste at the Chief Inspectorate for Environmental Protection (GIOŚ). Access to all electronic documentation will also be granted to supervisory bodies, e.g. provincial environmental protection inspectorates, the Road Transport Inspectorate, the Border Guard, the National Revenue Administration and the Police – to the extent necessary to carry out the inspection.

What other changes does Regulation 2024/1157 introduce?

Regulation 2024/1157 not only strengthens controls on the movement of waste, but also introduces new restrictions on its export to third countries, including:

• a ban on the export of waste intended for disposal to third countries, with the exception of the EFTA countries,
• ban on the shipment of hazardous waste intended for recovery or disposal from EU Member States, OECD countries and Liechtenstein to third countries (the so-called ‘Basel ban’ amendment),
• export ban non-hazardous waste, including plastic waste to countries not covered by the OECD decision. An exception will be made for countries which have demonstrated their ability to manage such waste safely and have been included in the list maintained by the European Commission.

Read also: The EU is introducing duties on parcels from China. The new charges will apply from 1 July 2026. >>

Sources:

1. Regulation (EU) 2024/1157 of the European Parliament and of the Council of 11 April 2024 on the shipment of waste, amending Regulations (EU) No 1257/2013 and (EU) 2020/1056, and repealing Regulation (EC) No 1013/2006 (Text with EEA relevance)
2. Commission Implementing Regulation (EU) 2025/1290 of 2 July 2025 laying down rules for the application of Regulation (EU) 2024/1157 of the European Parliament and of the Council (EU) 2024/1157 as regards the requirements necessary to ensure interoperability between the central system enabling the electronic transmission and exchange of information and documents relating to the shipment of waste and other systems or software, as well as other technical and organisational requirements necessary for the practical implementation of such electronic transmission and exchange of information and documents

The latest consumer survey shows that purchasing decisions are increasingly being made at the packaging level. Consumers are no longer driven solely by price, product quality or brand sentiment - what the product is packaged in is becoming just as important, if not more important. If the packaging is not eco-friendly and does not meet their environmental expectations, they are ready to reach for an alternative without hesitation.

Recycling above all

The European Association of Carton and Cardboard Packaging Manufacturers Pro Carton conducted a study The Power of Packaging. What Makes European Consumers Trust, Stay, or Switch?, which provides an understanding of how European consumers perceive the environmental aspects of packaging and packaging materials. It shows that in 2026, the most important packaging features for consumers are:

• ease of recycling (64%),
• made from renewable raw materials (40%),
• resealable (39%),
• convenience of opening (35%).

This means that messages about recycling and the origin of raw materials on packaging cease to be a marketing add-on and start to determine consumers' everyday choices and have a real impact on brand image. However, this impact can be twofold, and its nature depends mainly on the reliability of the producer. Truly sustainable packaging builds trust in the product and increases customer loyalty (as declared by 66% respondents). Packaging greenwashing, on the other hand, can alienate consumers not only from the product itself, but also from the brand as a whole. Gen-Z is definitely at the forefront of this issue. one in three 17-29 year olds abandons a purchase if they suspect greenwashing[i].

Packaging more important than the product? The new reality in the B2C sector

As it turns out, many consumers judge an entire product by its packaging. However, this is not about aesthetics or design, but about ecology and sustainability. When reaching for a packaged product, as many as 85% of the 5,000 respondents think about its impact on the climate, and 15% say they do so at every opportunity. Consideration is also followed by action -. 37% respondents admitted that they had swapped the product they were currently buying for a competing brand precisely because of concerns about its packaging. Again, Gen-Z representatives were the most radical on this issue, with as many as 54% of them abandoning their purchase because of the packaging. The most common allegations were:

• packaging not recyclable (53%),
• excessive packaging (39%),
• use of plastic (33%).

Unrecyclable, excessive or plastic packaging can therefore directly reduce sales, and this even if the product itself meets all consumers' quality expectations.

Consumers and legislation are beginning to speak with one voice

The conclusions of Pro Carton's study clearly coincide with the direction of legislative changes introduced in recent years in the European Union -. packaging is to be minimised, easily recycled and made of sustainable materials. Thus, manufacturers are under increasing pressure and need to make green changes not only because of potential penalties for non-compliant packaging, but also because of the real risk of a loss of competitiveness and revenue.

In some cases, consumer expectations are ahead of legislation. A good example of this is the design of packaging with a view to later recycling - according to the PPWR, businesses only have to eco-design packaging from 1 January 2030, but according to consumers, they should be doing this now.

Beats plastic head-on and wins the hearts of end-users - 84% consumers choose paper

The data is clear - 84% of respondents prefer to buy a product wrapped in paper rather than the same product in plastic. This percentage increases with the age of the respondents, and is as high as 92% among seniors.

The popularity of paper is supported not only by its real environmental potential, but also by good PR. Significant This is because the majority of consumers (86-87%) believe that paper, cardboard and corrugated board packaging will indeed be recycled at the end of its life cycle. Respondents put less faith in glass (82%), paper cups (75%), metal (62%), rigid plastics (60%), plastic beverage cups (54%) and flexible plastics (53%).

Ecological packaging as a to be or not to be for the producer and his brand

In light of this data, eco-design of packaging is becoming a natural response to both market expectations and upcoming legislative requirements. Entrepreneurs are therefore faced with the challenge of reconciling multiple, sometimes conflicting functions in a single optimised package. In practice, this means switching to simpler material structures (and preferably monomaterials), reducing the use of additives and elements that make it difficult to recycle, and reducing the weight and volume of packaging to the minimum necessary for product protection. And all this while maintaining the distinguishing features of a manufacturer's packaging on the shop shelf, which seems difficult to achieve. Why?

PPWR Regulation may result in the standardisation and unification of packaging for products in the same category in terms of shape, colour, type of closure and type of label, among others. The minimisation of packaging alone will reduce the space previously devoted to the marketing function. At the same time, it is worth bearing in mind that space will shrink even further with the introduction of new mandatory segregation labels and digital product passports. Manufacturers who want to maintain sales levels in the future and remain competitive should therefore start work on eco-design as soon as possible - as long as long vacatio legis gives them plenty of time to implement new, more environmentally friendly packaging, consumers expect and even demand it today. If they do not receive them, they will unsentimentally switch to competitors' products.

Find out about our packaging eco-design service >>.

Check that your packaging is PPWR compliant >>

Sources:

1. Greenwashing? Not for Gen Z. Young consumers bet on transparency [SURVEY]., https://omnichannelnews.pl/2025/11/04/greenwashing-nie-dla-gen-z-mlodzi-konsumenci-stawiaja-na-transparentnosc-badanie/
2. Pro Carton, The Power of Packaging What Makes European Consumers Trust, Stay, or Switch?, https://www.procarton.com/wp-content/uploads/2026/03/Pro-Carton-Consumer-Study-2026-Final-Edit-1.pdf

The deposit system in Poland has raised many questions and controversies from the outset, especially among industries that found themselves in it „by the way”, so to speak. One of these was pharmacies and the HoReCa sector, which - although not typical beverage outlets - were covered by the obligations under the legislation. However, the draft amendment to the Packaging Act shows that the legislator is beginning to recognise the specificity of these entities and respond to their demands.

Pharmacies excluded from deposit scheme - latest change in bill

The appeals of the Supreme Pharmaceutical Chamber and representatives of the pharmaceutical industry have finally had an effect - it seems that the soon large pharmacies will no longer have to collect empty drinks containers. On 20 March 2026, the following was published on the website of the Government Legislation Centre an updated version of the draft amendment to the Packaging and Packaging Waste Act (UC100), which meets the expectations of pharmacists. In fact, Article 133(8) states excluding pharmacies, pharmacy outlets and pharmaceutical wholesalers from the obligation to participate in the deposit scheme in terms of:

• collection of packaging and packaging waste,
• return of deposits,
• to conclude contracts with any representative entity that wishes to do so.

If the aforementioned provision of the law is passed unchanged, all pharmacies will be officially excluded from the deposit scheme, including those with a sales area of more than 200 m². Pharmacies will, however, retain the right to participate voluntarily in the system and to run collection points.

Read also: A deposit system will increase the carbon footprint of PET bottles >>

How did pharmacies get into the bail system and how will they leave it?

With the launch of the deposit system in Poland, all pharmacies with a retail area of more than 200 m² have automatically become collection points for deposit packaging. Why? The assortment of each of them contained products recognised by the Act as packaged beverages, i.e. liquid food for special medical purposes, liquid dietary supplements or mineral water, thus making large pharmacies and pharmaceutical wholesalers meet the statutory definition of a retail and wholesale unit.

The original version of the bail law did not provide exemptions for pharmacies - As the Ministry of the Environment argued, the obligation to run a collection point covered a small number (maximum 20) of outlets across Poland. In addition, most of them were located in shopping centres, so, according to the ministry, pharmacists did not have to collect the bottles directly - they could use, for example, bottle machines. However, these explanations did not satisfy the pharmaceutical community. Industry representatives stressed that a pharmacy is a public health facility, not a shop. Furthermore, pharmacies contribute to the environment anyway by collecting unwanted and out-of-date medicines.

The Ministry of Climate and Environment remained adamant, justifying its position with the need to keep the bail-in system watertight. This only changed with the publication of the draft amendment, which responded not only to the needs of the pharmaceutical industry, but also of HoReCa.

HoReCa outside the bail system, but under certain conditions

The amendment to the bail law is also expected to simplify bail settlement operations in the HoReCa sector. Hoteliers, restaurateurs and catering owners selling beverages in containers covered by the deposit system will be able to waive the collection of security deposits, if they fulfil all of the following conditions:

• packaging will be opened on the premises,
• the drink will be consumed on the premises,
• empty packaging or packaging waste will be returned to the premises.

Ministerial the bill is currently in the early stages of legislative work - has already been submitted to the Joint Committee of the Government and Local Self-Government for its opinion, and will then go to the Committee of the Council of Ministers for Digitalisation. The course of the legislative process can be followed on the website of the Government Legislation Centre.

Read also: Glass bottles, however, outside the deposit system >>

The amount of waste generated worldwide is growing much faster than expected. The latest World Bank report highlights the scale of the problem and warns that without rapid investment in infrastructure and systemic change, we face not only an environmental crisis, but also an economic one.

Forecasts from a few years ago are no longer valid - there is more waste than predicted

The world is drowning in rubbish - this is the worrying conclusion that emerges from the World Bank's latest report, 'The world is drowning in rubbish'. What a Waste 3.0: Global Snapshot of Solid Waste Management toward Circularity until 2050. As its authors point out, projections produced in 2018 indicated that we would globally generate around 2.59 billion tonnes of municipal waste in 2030. Meanwhile, we reached this level... just four years later. Already in 2022, 2.56 billion tonnes of municipal waste were generated globally, forcing experts to revise their assumptions.

Current projections for the scenario business as usual indicate that 2.95 billion tonnes of waste will be generated worldwide in 2030, rising to 3.85 billion tonnes in 2050. This represents an increase of around 50 per cent in less than three decades. It should be stressed that these figures relate only to municipal waste, which accounts for only a fraction of the total waste generated (in Poland in 2024 it was 12 per cent.[i]).

In the period from 2022 to 2050. the highest 128% increase in municipal waste mass is expected to occur in low-income countries. Lower middle-income countries will almost double the amount of waste generated (97 per cent increase). The lowest increases will be seen in high-income (18 per cent) and higher middle-income countries (38 per cent). None of the scenarios, even the most optimistic, assumes a reduction in the mass of municipal waste.

The ever-increasing mass of waste is not just due to the continued growth of the global population. It is primarily the result of changing lifestyles - greater consumption, urbanisation and rising incomes. The richer a society is, the more waste it produces.

Municipal waste as a measure of social inequality

Figures for municipal waste generation and management vary according to region, country and wealth of the population.

• Highly developed countries (16 per cent of the global population) account for 29 per cent of waste generated and achieve the highest waste generation rates per capita.
• The East Asia and Pacific region accounts for the largest share of global municipal waste mass (33 per cent) and the Middle East and North Africa the smallest (6 per cent).
• Countries in Europe and Central Asia achieve the highest collection rates (96 per cent on average and even 100 per cent in some countries), while in the sub-Saharan African region, as much as 69 per cent of waste is not collected at all and 24 per cent ends up in wild landfills.
• In low-income countries, bio-waste (i.e. food and green waste) makes up the majority of the municipal waste stream (52 per cent). In contrast, in higher-income countries, recyclables, textiles and waste electrical and electronic equipment (WEEE) dominate, making up about 50 per cent of the municipal waste mass.
• In highly developed countries, almost 100 per cent of municipal waste is treated in professional facilities. In low-income countries, only 3 per cent of rubbish goes to such installations.

What about the remaining waste? Surveys and desk studies conducted in 49 countries show that the most common methods of managing unclaimed waste in low- and middle-income countries are self-incineration and environmental dumping. Residents of affluent countries mostly report open burning and recycling or composting. Other methods used by the surveyed population included burying waste and abandoning it in watercourses.

Read also: New EU food waste reduction target >>

Plastic waste one of the biggest challenges of the global waste system

The World Bank report devotes considerable attention to plastic waste, which accounts for about 12.5 per cent of the mass of global municipal waste (ranging from 8.1 per cent in low-income countries to 13.1 per cent in middle-income countries), equivalent to about 324 million tonnes. As much as 65 per cent of this mass is single-use products.

The problem of plastic pollution is currently one of the biggest environmental challenges. To date, 88 countries around the world have implemented specific policies aimed at reducing plastic consumption and proper management of the waste generated from them. Depending on the country and region, these take the form of additional fees, taxes and bans imposed on the most common plastic products. One of the most complex policies is the Extended Producer Responsibility system, which is currently implemented mainly in high-income countries.

Despite global efforts, still more than 29 per cent of plastic waste (93 million tonnes) is not adequately treated and managed, 13 per cent are recycled incorrectly or dumped in wild landfills and 16 per cent do not enter the collection system at all. The largest generators of untreated plastic waste are: Sub-Saharan Africa (15 million tonnes), South Asia (14 million tonnes) and East Asia and the Pacific (12 million tonnes).

From the perspective of a circular economy, this is not only a huge environmental problem, but also a loss of valuable, non-renewable raw materials that (under other market conditions) could go back into circulation.

Read also: Fiasco of global plastic pollution treaty negotiations >>

Too high, yet still too low costs of global waste management

As calculated by the authors of the report, the cost of global municipal waste management already exceeds the USD 250 billion per year, and in the scenario business-as-usual by 2050. may even rise to the level of 426 billion dollars. Like other waste management issues, the unit cost of waste management also varies considerably in different regions of the world. Processing a tonne of municipal waste in low-income countries with simple waste management systems can cost around $40-45 per tonne, and up to over $120 per tonne in highly developed countries using advanced, automated recycling systems. This is a heavy burden on local governments, which spend on average about 6 per cent of their budgets, and even more in poorer regions.

Read also: Municipalities will pay for insufficient recycling. Waste collection fees could rise by several tens of percent

Despite significant financial resources, many cities and municipalities struggle to finance waste management. Only in high-income countries are the fees paid by residents and producers (if the country has a ROP system) sufficient to cover all the necessary costs. In other countries it is necessary to subsidise the waste system from the state budget, which often turns out to be impossible. The scarcity of resources leads to chronic underinvestment and growing problems in the waste management system.

About the report What a Waste

Report What a Waste 3.0: Global Snapshot of Solid Waste Management toward Circularity until 2050 This is the third (after the 2012 and 2018 publications) edition of the report series What a Waste developed by World Bank experts. The report was authored by Ed Cook, Kremena Ionkova, Perinaz Bhada-Tata, Sonakshi Yadav and Frank van Woerden, who collected and analysed publicly available data from 217 countries and economies and 262 cities.

What a Waste 3.0 consolidates data on municipal waste generation, morphology, collection, treatment and disposal, and presents trends by geographical region and income group. It updates and extends previous studies to provide a global reference set of information on municipal waste management in the context of the GOZ transition.

[i] CSO, Environmental protection 2025, https://stat.gov.pl/obszary-tematyczne/srodowisko-energia/srodowisko/ochrona-srodowiska-2025,1,26.html

The Ministry of Climate and Environment does not rule out extending the deposit system to further fractions, including multi-material packaging. The issue is currently under discussion between the ministry and the bottling industry. Possible changes can be expected no earlier than 2027.

MEP asks, MEP answers - discussion on multi-material packaging in the deposit system

The issue of including multi-material cartons in the deposit system was raised by MEP Grzegorz Matusiak in an interpellation addressed to the Minister for Climate and Environment. He pointed out that there is a current trend in the market to „escape” from the bail system - large beverage producers are switching from the mono-material packaging previously included in the system to alternative packaging that does not belong to the system. According to reports from the trade press the most common choice for producers in this situation is the difficult-to-recycle multi-material cardboard packaging, for which no deposit is charged.

In its response, the climate ministry confirmed that it recognises the phenomenon, but that it is, as indicated, of marginal scale, so does not require immediate action. However, the Ministry of the Environment is constantly analysing the industry's demands, including those regarding the inclusion of so-called tetraps in the deposit system, and still plans to decide on a possible legislative initiative in 2026.

Multi-material packaging is not a priority - take care of the fractions listed in the law first

The answer to the interpellation by the Undersecretary of State at the Ministry of Climate and Environment, Anita Sowinska, shows that at the moment the ministry is focusing on the development of infrastructure and reverse logistics those types of beverage packaging that have been part of the deposit system since its inception. Sowinska also pointed out that the imposition of a deposit on another fraction would result in a an additional burden on retail outlets and a reduction in the already greatly reduced waste stream going into the municipal system. In addition, it would require significant changes to the return infrastructure that has just been set up. One element of this is the bottle dispensers installed at collection points, which have not been adapted to collect waste from multi-material packaging.

Do exemptions to the bail system restrict competition?

In his interpellation, Grzegorz Matusiak also raised the problem of entire packaging segments being excluded from the deposit system. At first it was milk and dairy products, and after the launch of the system - beer and other beverages in reusable glass bottles. While the possibility to exclude beer packaging is only temporary (until the end of 2028) and the use of it has been made conditional by the Ministry of the Environment on the operation of an alternative collection system, for milk and dairy products there is no other collection system in place, nor is there a timetable set for their future inclusion in the central system. In the Member's view, such aim at restricting competition between marketers of packaged beverages, and the validity of their use should be reviewed by the IOC.

Read also: Glass bottles, however, outside the deposit system >>

As a restriction of competition in the market, the Member also points to the phenomenon of PET bottles and aluminium cans being replaced by multi-material cardboard packaging, which, due to the absence of a deposit and the need to return them, is a cheaper and more convenient alternative for consumers.

The Ministry did not directly address the issue of a potential restriction of competition. However, Minister Sowińska stressed that the purpose of the deposit system was not to promote the use of multi-material cardboard packaging, but to meet the high EU targets for separate collection levels of packaging waste. She added that the effectiveness of the system and its impact on the environment and the competitiveness of bottlers would only be able to be reliably assessed after an analysis of the reports for the first full year of operation of the deposit system.

Read also: Will there be an umbrella institution in the bail system?

Sources:

1. Interrogatory No. 16100 to the Minister for Climate and Environment on the deposit system and the types of beverage packaging covered, https://www.sejm.gov.pl/sejm10.nsf/InterpelacjaTresc.xsp?key=DSHE6Y
2. Reply to MEP Grzegorz Matusiak's interpellation on the deposit system and the types of beverage packaging covered, K10INT16100, https://sejm.gov.pl/INT10.nsf/klucz/ATTDSWJ5B/%24FILE/i16100-o1.pdf