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EU Packaging & Packaging Waste Regulation: How can healthcare prepare?

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In last week’s blog, we outlined the key PPWR requirements and deadlines facing the healthcare industry—highlighting specific challenges for this highly regulated area. Today, we provide some actionable recommendations to start your PPWR compliance journey and prepare for the future. 

1

Conduct a comprehensive audit:

Start by assessing your current packaging portfolio. Identify non-recyclable materials, excessive packaging, and any substances of concern. Establishing this baseline will be crucial for identifying clear areas for improvement.  
2

Verify exemptions carefully:

PPWR provides certain exemptions for recyclability and the use of post-consumer reyclate (PCR), specifically for “contact sensitive packaging”. Article 3 defines what contact sensitive means. Don’t assume exemptions automatically apply, always cross-reference with relevant legislation to ensure compliance. 
3

Move towards PFAS free:

Whilst the obligation is for food contact packaging, PFAS free alternatives are available. Consider if PFAS is in your supply chain and proactively start to eliminate usage where feasible.  
4

Redesign for minimisation:

Identify any packaging that could be lightweighted, downsized or even eliminated. For example, could a rigid tray and lid move to a lighter card and pouch system?  Reducing packaging volume not only aligns with the legislation, but could also lead to lower material costs, EPR fees, and emissions. 
5

Prepare for EPR fees:

Budget appropriately for higher EPR fees, harder to recycle packaging will have higher costs. Ensure your systems can track material and weight by country. This might mean updating ERP systems or supplier data collection so that by 2026 you know exactly how much of each packaging material you are putting on each EU market. 
6

Evaluate the use of designed for recycling materials:

Although the timeline for recyclability is extended for contact sensitive packaging, the direction of travel is clear. Healthcare packaging requires long and extensive validation, to assess safety and stability. Therefore, the earlier you can start material testing the better. Also, there could still be a financial benefit in doing so, as eco modulated EPR fees are implemented, easier to recycle materials will have lower cost.  
7

Remember transport and logistics packaging:

It’s important to maintain a broad view of packaging beyond just the primary pack. Transport packaging must comply with the reuse and minimisation requirements of the PPWR. 
8

Focus on quick wins:

Primary packaging is the hardest to change, prioritise the less sensitive components of the supply chain, that could more readily move to recyclable materials or even incorporate PCR content.  
9

Engage with suppliers:

We are in this together. Clear, open communication, and aligned goals across the supply chain can help accelerate meeting PPWR requirements.  

As the EU Packaging and Packaging Waste Regulation takes shape, it’s clear we are still only at the beginning of an evolving journey—one that poses significant challenges to the healthcare industry. Yet, even in this risk adverse and traditionally slow to change environment, opportunities can present themselves. Forward thinking, early movers can embrace sustainable practices as a competitive advantage, driving innovation and building trust. Ultimately, this shift isn’t just about adhering to regulations; its about fulfilling our promise of packaging that is Designed to protect, the planet, patients and the future of healthcare for generations to come.  
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