Packaging regulations in flux: what do SUP and PPWR mean for organizations?

European packaging regulations no longer only affect organizations at an operational level, but increasingly also influence strategic decision-making. Cost structures, investment choices, contracts with suppliers, and administrative responsibility are directly affected by new EU obligations. Against this backdrop, the Single Use Plastics Directive (SUP) and the Packaging and Packaging Waste Regulation (PPWR) mark a structural shift in how organizations must deal with packaging.

Regulations are in a state of flux. Whereas in recent years the focus has been mainly on reducing specific disposable plastic products through the SUP Directive, the PPWR adds a new and much broader framework. Together, these rules aim to reduce waste, increase reuse, and increase responsibility for producers and chain partners.

1. SUP en PPWR: two regimes, one direction

SUP and PPWR coexist, but differ in scope and approach.

SUP Directive (2019/904)	PPWR Regulation (2025/40)
EU directive, implemented nationally	EU regulation, directly binding
Focused on specific single-use plastic products	Applies to all packaging; does not affect SUP-specific bans and obligations
Focus on litter and behavioral change	Focus on design, circularity, and chain
Limited product scope	Integrated life cycle approach

The SUP rules remain applicable within their own scope. The PPWR forms the broader and structural framework for the coming years.

Because the PPWR is an EU regulation, the rules apply directly and uniformly in all member states. This limits national policy space and requires organizations to make central, organization-wide preparations. Packaging is therefore no longer exclusively an operational issue, but affects strategic decision-making on product design, investments, contracts, and chain cooperation.

The SUP, on the other hand, is an EU directive that is implemented nationally by member states. As a result, there are differences in interpretation, exceptions, and enforcement between countries. Under SUP, packaging has also become a strategic choice—for example, due to cost structure, reusable alternatives, and UPV obligations—but these choices have different legal and practical implications in each member state. This is particularly relevant for organizations that operate in multiple member states.

2. What does the SUP Directive regulate?

The SUP Directive focuses on single-use plastic products that often end up as litter. The regulation distinguishes between products that are completely banned and products that remain permitted under specific conditions.

2.1 Prohibited products

Since July 2021, the following plastic products, among others, may no longer be placed on the market:

• cutlery, plates, straws, and stirrers;

• drinking cups and food packaging made of expanded polystyrene (EPS/XPS);

• balloon sticks and oxo-degradable plastics.

A complete sales ban applies to these product categories.

2.2 Products with requirements (no ban)

Other products are not subject to a ban, but are subject to additional obligations, such as:

• consumption reduction, particularly for cups and containers for on-the-go use;

• design requirements, such as fixed caps and a minimum percentage of recycled material in PET bottles;

• separate collection targets for beverage packaging.

  
  

In addition, the following apply in general:

• labeling requirements for certain product categories, to inform consumers about plastic use and proper waste disposal;

• extended producer responsibility (EPR), whereby producers contribute financially and organizationally to collection, processing, litter cleanup, and monitoring.

  
  

These obligations have been elaborated in the Netherlands through the Single-Use Plastic Products Decree, the Single-Use Plastic Products Regulation, and the SUP Assessment Framework. Other Member States may place different emphases within the directive. For internationally operating organizations, it is therefore essential to distinguish between directly applicable EU obligations and national additions.

2.3 Tightening of SUP as of January 1, 2026 (Netherlands)

In the Netherlands, the SUP rules will be further tightened as of January 1, 2026. The current variable surcharge for single-use cups and meal packaging containing plastic will be replaced by a fixed surcharge of €0.25 for consumption on the go. In addition, exceptions for paper and cardboard packaging with a plastic coating will be limited, making reusable packaging the norm for consumption on site, with the exception of closed events and a few specific situations.

These changes do not alter the nature of the SUP Directive, but make the rules clearer and easier to enforce.

3. What will change with the PPWR?

The PPWR shifts the focus from specific products to the packaging system as a whole. The regulation applies to all packaging, regardless of material or sector.

Important elements are:

• recyclability of packaging;

• use of recycled material;

• reusability in, among other things, hospitality, retail, and logistics;

• reduction of harmful substances;

• uniform labeling and chain documentation.

  
  

At the management level, this means that packaging will become part of broader decision-making on risk management, investment planning, and supplier strategy. Choices regarding materials, reusability, and logistics systems have direct consequences for costs throughout the entire life cycle and for contractual agreements within the chain.

The first obligations will apply from 2026, with further tightening towards 2030 and beyond.

4. Timeline at a glance

Year	SUP	PPWR
2021	Prohibited SUP products (including cutlery, EPS packaging)	—
2023–2024	Consumption reduction & reusable alternatives	—
2025	Bottle collection targets (77%)	Entry into force of PPWR
2026	Stricter NL-SUP rules	First PPWR obligations
2030	—	Recyclability and reuse targets
2038	—	Tightening of recyclability standards

5. What does this mean for organizations?

For organizations, this development means that packaging is increasingly becoming a strategic compliance issue:

• under the SUP rules, the emphasis is on product choices, reusable alternatives, price and cost structure, and demonstrable consumption reduction;

• under the PPWR, the focus shifts to structural choices in design, material use, reusability, and chain cooperation.

Organizations that already have insight into their packaging flows, suppliers, and materials used are better prepared for the tightening of regulations towards 2030. In many cases, this requires coordination between purchasing, product development, compliance, and sustainability.

6. In conclusion

SUP and PPWR are not separate rules, but successive steps in the same direction: less waste, more reuse, and transparency in the chain. Where SUP directly targets specific products and behavior, PPWR lays the foundation for a structurally circular packaging system.

It is essential for organizations to view both regimes in conjunction with each other and to make timely choices that are also sustainable in the longer term. DuFinco supports organizations in translating these developments into clear decision-making, practical implementation, and robust governance.

Questions?

Would you like to ask any questions about the application of the SUP Directive or the upcoming obligations under the PPWR? Would you like to gain insight into what these regulations mean for your organisation?

If so, email us at info@dufinco.nl or miranda.haak@dufinco.nl.

Call us on +31 6 512 47 217.