With the EU’s Packaging and Packaging Waste Regulation (PPWR) set to take force on 12 August 2026 and the UK’s Extended Producer Responsibility (EPR) initiative entering its most consequential phase, packaging businesses across Europe are wading through what may be the most complex regulatory landscape the industry has ever faced.  

The European Commission published its first official PPWR implementation guidance on 30 March 2026, offering long-awaited clarification on producer definitions, recyclability requirements, and restrictions on PFAS in food-contact packaging. Yet industry association Europen noted that the guidance still falls short of the legal certainty and operational clarity businesses urgently need. Several delegated and implementing acts, covering recyclability grading, recycled content thresholds, and EPR registration formats, remain in active preparation, with final details still to be confirmed. 

Meanwhile in the UK, the Recyclability Assessment Methodology (RAM) is now underpinning real financial consequences. Green, amber and red ratings are translating directly into modulated EPR fees, with red-rated plastic packaging attracting up to double the base rate by 2028. Producers are navigating two distinct compliance regimes simultaneously, one that restricts market access, one that increases cost, each with its own data requirements, timelines, and commercial implications. 

Joanna Stephenson, Managing Director at Think B2B Marketing, shares her perspective: “What we’re seeing right now is a perfect storm, and I mean that in the most practical, operational sense. Packaging businesses are being asked to comply with two substantial regulatory frameworks at once, one of which still doesn’t have all of its rules written. That is genuinely objectively difficult, even for the most experienced and well-resourced in-house sustainability teams. What’s striking for those of us with many packaging industry years under our belt is how many businesses are treating this purely as a compliance and operations challenge, when in reality it has enormous implications for how they communicate internally, to customers, to the market, and on pack. 

“If we break down what’s actually happening now, the RAM green/amber/red classification is now a financial instrument. It directly affects what you pay under UK EPR. Meanwhile, the EU PPWR recyclability grades A to C will affect market access. And yet, every single one of those classifications touches communications. What claims can you make about your packaging? How do you substantiate those? What do your sales teams tell customers who ask about compliance status? What does your website say about recyclability? These aren’t sustainability team questions anymore, they’re marketing questions, and they need marketing-calibre answers. 

“We’ve been in this space long enough to recognise the pattern and working alongside some of the world’s most prominent packaging businesses, genuine titans in their respective fields, means our team at Think B2B Marketing gets a front-row seat to how this is playing out in real time. What those businesses are telling us, consistently, is that the pace of regulatory change has outstripped their internal capacity to communicate it. Not to comply with it, as many of them are well ahead on the operational side, but to communicate it. To customers, to procurement teams, to brand owners, to the trade press, and increasingly to consumers. The gap between what they’re doing and what they’re being seen to do is widening, and that gap has a commercial cost. 

“One of the things that strikes us when we talk to senior leaders in the industry is that sustainability communication has become one of the most legally sensitive areas of their marketing. Under PPWR, making a recyclability claim that doesn’t meet the regulation’s own definitions is a major compliance risk. With penalties under the EU Green Claims Directive potentially reaching up to 10% of annual turnover, the businesses getting this right are the ones treating their communications with the same laser-sharp rigour they apply to their technical and operational compliance. The ones that aren’t are, frankly, exposed. 

“The flip side of this, and it’s genuinely exciting from where we sit, is the differentiation opportunity. When compliance complexity reaches this level, the businesses that communicate with clarity, confidence and precision will stand out very clearly from those that don’t. The most exciting companies we partner with aren’t just doing the compliance work; they’re building it into their brand narrative. Regulatory readiness, material innovation, and recycled content investment are powerful proof points, but only if they’re communicated effectively to the right audiences.

“My advice to any packaging business right now is this: make sure your communications strategy is keeping pace with your compliance strategy. They’re not separate workstreams anymore; they should be the same conversation.”