EU Packaging and Packaging Waste Regulation and ESC Requirement

Modified on Thu, 23 Oct at 3:30 PM


Introduction 

This article provides a comparative analysis of the EU's new Packaging and Packaging Waste Regulation 2025/40 (PPWR) and the B Lab Standards (V2.1) Environmental Stewardship & Circularity (ESC) Impact Topic. While both frameworks share the goal of promoting a circular economy and reducing environmental harm, they are distinct in their purpose, scope, and application.


Main takeaways

Both the EU PPWR and the B Lab ESC Impact Topic are fundamentally aligned in their commitment to the principles of a circular economy. They both seek to:

  • Minimize Waste: Drastically reduce the amount of packaging waste generated, especially through waste prevention and the increase of recycled content.

  • Promote Reuse and Recyclability: Encourage the use of reusable packaging and ensure that all packaging is recyclable.

  • Encourage Sustainable Design: Influence packaging design to be more environmentally friendly from the outset, moving away from single-use and hard-to-recycle materials.

  • Shift Responsibility: Place greater responsibility on producers for the end-of-life of their packaging.

The B Lab Standards complement the EU PPWR by:

  1. Requiring the consideration of the hierarchy of actions.

  2. Focusing both on product and packaging.

  3. Mandating for the reduction of virgin non-renewable packaging materials, and not only the increase of recycled content.

  4. Extending the producer’s responsibility to take concrete action to improve the infrastructure where there’s a barrier (globally where the company operates).


Some of the requirements of the EU PPWR are addressed through different Impact Topics directly or indirectly. These include, for instance:

  • Labeling: EU PPWR sets specific labeling rules for the packaging (where to bin it, and how to return it for reuse). This is indirectly addressed under PSG4 Responsible Marketing Policy.

  • Product safety: EU PPWR bans harmful and cancer-causing “forever” chemicals (PFAS) in packaging from August 2026. Both the ESC and the Human Rights Impact Topic ask for a materiality assessment. If substances of concern are a material environmental or salient human rights issue the company must address this.


Comparative analysis


Scope

Feature

EU PPWR

B Lab ESC Impact Topic

Type of Framework

Mandatory Legal Regulation: A binding law that applies to all businesses placing packaged goods on the EU market, regardless of their size or sector. Non-compliance results in legal penalties.

Voluntary Standard: A set of requirements that companies voluntarily commit to in order to achieve or maintain B Corp Certification. It is a tool for self-assessment and continuous improvement.

Geographic Reach

EU-centric: Applies only to packaging and packaged goods placed on the market within the European Union.

Global: Designed to be applicable to companies of all sizes and sectors, in any country. The standards are tailored based on the company's context, e.g. size and sector.

Focus

Specific: Narrowly focused on packaging and packaging waste, including design for recycling, minimum recycled content, reuse systems, and bans on unnecessary packaging.

Holistic: Companies not only need to consider circularity with regards to their packaging but also regarding the product itself. In addition companies need to address a broad range of environmental impacts across the entire value chain.



Issue Coverage & Requirement

Topic

EU PPWR

B Lab ESC Impact Topic

Alignment

Recyclable packaging

All Packaging must be recyclable by 2030.

The company’s product development must incorporate circularity principles considering the hierarchy of actions. Recyclable packaging is at the lowest rung of the hierarchy.

There is conceptual alignment. While the EU PPWR sets a target the ESC Impact Topic (due to its global nature) leaves it to the company with continuous improvement required. With time the company considers other circularity principles higher in the rungs of hierarchy. In addition, the ESC Impact Topic covers both the packaging and the product itself.

Less packaging waste

Plastic packaging must be made in part from recycled content, with increasing targets for 2030 and 2040.  

In each 3-year cycle the company must reduce its total use of virgin non-renewable materials and increase the use of renewable materials from sustainable sources, or reused or recycled input materials in its products and 

packaging.

There is conceptual alignment. The ESC Impact topic does not set a target date, but focuses on continuous improvement. It requires companies to eventually reduce the virgin non-renewable input materials to an absolute minimum.

Re-use, refill & collection

Those who make reusable packaging available must ensure that a system is in place for the re-use of that packaging in that market.

Some single-use plastics will be banned. 

Companies must make reuse or refill options available whenever possible, with no extra charge.

Phased targets for transport packaging to be reusable. 

In each 3-year cycle the company must demonstrate that its product design follows the priority order established in the waste hierarchy with avoiding and reducing single-use packaging being at the top of the hierarchy. The second to top option is that the company designs its products for long-term use (including the product or packaging designed for durability, repairability and reusability).

There is conceptual alignment. Both promote reuse options and discourage single-use plastic. The ESC Impact Topic does not set a target date for the latter and goes beyond plastics. 

Extended producer responsibility

Companies are required to fund the full cost of managing their packaging waste. 

Larger companies are required to understand the recovery infrastructure available where they sell their products (ESC3.4) and take steps to increase the recovery of their products and packaging after their end-of-life (ESC3.5).

 Company contributions towards Extended Producer Responsibility (EPR) schemes can be considered actions to improve the available infrastructure for recovery, as long as they are: a) linked to the company’s material products and packaging; b) contributed in countries with recovery infrastructure barriers.

There is conceptual alignment. Both EU PPWR and the ESC Impact Topic intend to put more responsibility on the producer to ensure they contribute to the improvement of infrastructure for waste collection. The ESC Impact Topic asks companies to focus on markets with recovery infrastructure barriers to shift the attention where it is needed (which may be the Global South).


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