Among many factors influencing the technology and processes of waste sorting, legal conditions and implemented waste policy play a significant role. They shape the framework — the foundations, goals, directions, and limitations of waste management. In the near future, important changes, regarding legal conditions and the waste policy, are going to be made in Poland. They won’t fundamentally affect current goals (recycling levels, limiting landfilling) or principles (e.g., waste hierarchy, “the polluter pays”). However, they will affect the profitability and costs of waste sorting. This is due to the implementation of a deposit-refund system from October 1, 2025. They will also have an impact on the shape of the waste management system because of the planned full implementation of the Extended Producer Responsibility (EPR) system over the next few years, based on the draft law on packaging and packaging waste from August 7, 2025. Over the next few years, the legal changes will also affect the structure and composition of waste streams directed to sorting processes. This will happen as a result of the entry into force of Regulation (EU) 2025/40 of the European Parliament and of the Council of December 19, 2024, on packaging and packaging waste, which amends Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repeals Directive 94/62/EC. This act is widely known by its acronym PPWR (Packaging and Packaging Waste Regulation). It will replace Directive 94/62/EC, which will lose its force in August 2026.
This article is an analysis of the PPWR regulation in the context of its impact on waste sorting technology, as well as the effectiveness and efficiency of these processes. This raises fundamental questions: What will be the practical consequences of implementing PPWR for packaging waste sorting in Poland? How will the anticipated changes affect the technology and efficiency of sorting processes? Will the solutions provided in PPWR compensate Polish municipal waste sorting facilities for the effects of the deposit-refund system’s implementation starting in October 2025 and the lack of an Extended Producer Responsibility (EPR) system? What significance will PPWR have for waste management in Poland?
What is the goal of introducing PPWR?
The goal of implementing PPWR is to reduce the amount of packaging waste and increase the reuse and recycling of packaging. It aims to support the transition to
a circular economy. The introduction of PPWR comes from the fact that 40% of plastics and 50% of paper in the European Union are used for packaging production, which is a process that consumes a significant amount of primary raw materials. Additionally, packaging makes up 36% of the mass of municipal waste, as stated in point 2 of the PPWR preamble.
What determines the efficiency of waste sorting processes?
Investors interested in building or modernizing municipal waste sorting plants pay close attention to the efficiency of the sorting processes. This is the corelation between the achieved results and the investment costs incurred. However, this efficiency is not just economic. It also has, and perhaps primarily, an environmental dimension – in the form of achieving goals related to preparing waste for recycling. Such efficiency also has a social dimension, referring to, for example, meeting the real needs associated with waste management, and much more. Therefore, efficiency relates to the purpose and meaning behind the operations of economic entities.
However, what conditions and effectively motivates waste sorting facilities is the economic stability and profitability of operational activities. Therefore, the ability to achieve waste sorting efficiency depends first and foremost on the system that establishes the rules of the market and determines economic motivation. The second fundamental factor influencing efficiency (including achieving environmental goals) is the technological effectiveness of the sorting processes. This is dependent on the composition of the waste directed for processing and the quality of the technology used for the sorting processes.
It is the technology that unlocks the potential in waste
The composition of waste determines its raw material and economic potential. Technology allows this potential to be recovered and then recycled. However, for this to happen, a profitability mechanism is essential – it serves as the “driving force” for the entire waste management system. This mechanism, in the form of economic solutions, can be created within a properly structured and effective Extended Producer Responsibility (EPR) system. Such a system links the goods production and consumption industries with the twin industry of waste management. The EPR system in a given country is an expression of the state’s strategy in this field. Issues related to this were presented in more detail in the article titled: “EPR system. Will Poland use the opportunity to create a driving force for its waste management economy?”
In contrast to the EPR system, which can shape the entire waste management system, the Packaging and Packaging Waste Regulation (PPWR) relates to a small part of the issues – concerning only packaging and packaging waste. From the perspective of waste sorting technology, it’s crucial to know what changes in waste composition the introduction of the PPWR might cause. Although the PPWR won’t be the only determining factor, it will undoubtedly influence the quality and composition, that is, the potential, of waste. Consequently, we may ask: what requirements and solutions does the PPWR consists of and how will they shape the composition of packaging waste? What is the significance of the PPWR for sorting technology and its effectiveness?
The PPWR doesn’t change packaging waste recycling targets
Firstly, it’s important to note that the Packaging and Packaging Waste Regulation (PPWR) does not change the recycling targets for packaging waste (as per Article 6 of Directive 94/62/EC and Article 52 of the PPWR). These targets require that at least 65% (by the end of 2025) and at least 70% (by the end of 2030) by weight of all generated packaging waste must be recycled. Recycling targets have also been set for specific materials: plastics – 50% (by the end of 2025) and 55% (by the end of 2030); wood – 25% and 30%; ferrous metals – 70% and 80%; aluminum – 50% and 60%, glass – 70% and 75%; paper and cardboard – 75% and 85%.
To meet these targets, sorting processes for packaging waste from households are essential, especially for selectively collected plastics. The sorting of mixed waste will also be significant. Although the proportion of packaging in the mixed waste stream is relatively small, the total volume of this waste overall makes its sorting crucial.
The PPWR focuses on separate collection and sorting capacity
The Packaging and Packaging Waste Regulation (PPWR) (Preamble, points 30 and 46) pays attention to the issue of separate waste collection and the need to achieve the necessary sorting capacity. This is essential to ensure that collected packaging waste undergoes preliminary processing and high-quality recycling. The regulation specifies that separate collection of packaging waste is crucial for obtaining high-quality collected materials (resources) and high-quality recyclates. The standardization of labeling and symbols on packaging and waste bins (Articles 12 and 13) is intended to help achieve better quality waste segregation at the source. The regulation emphasizes that “sorting is an essential step to ensure greater circularity of packaging.” Therefore, “the improvement of sorting capacities, in particular through technological innovations, should be encouraged in order to enable more effective sorting, and thus better quality feedstock for recycling.” (Preamble, point 65).
Recycling targets increase requirements for sorting effectiveness
The basic technological setup for sorting selectively collected plastic waste includes devices such as: a bag opener, a pre-sorting cabin, a screening system (most often a trommel screen), optical sorters for separating plastics from other materials and then sorting specific types of plastics or other materials (like paper), a ballistic separator (to assist with plastic sorting), ferrous and non-ferrous metal separators, sorting cabins (for quality control and cleaning of the material fractions), and a baling press. This is the standard, widely-used technological system that allows for a recovery effectiveness of 40-80% of the raw material fractions contained in the input stream, depending on the specific technology used and the sorting processes performed.
However, this level may be insufficient given the high demands for packaging waste recycling. Thus, to increase the effectiveness of sorting processes, it may be necessary to focus on the potential of the fine fraction (which makes up over a dozen percent of the selectively collected waste stream) that is often screened out and left unprocessed. It’s also vital to improve the recovery effectiveness of raw material fractions from the medium and oversized fractions. Tapping into the raw material potential found in these streams and in technological losses may be necessary to achieve higher and higher recycling targets. This will also be justified under the right economic conditions.
The PPWR outlines three key directions for packaging
The regulation points out three main directions that are intended to help reduce the amount of packaging waste and achieve recycling targets. These directions will also have a significant impact on sorting processes. They are:
- eco-design of packaging,
- use of recycled content in new packaging,
- reducing the quantity of packaging waste generated.
Eco-design of Packaging and its impact on waste composition
The Packaging and Packaging Waste Regulation (PPWR) establishes the principle that all packaging placed on the market must be recyclable (Article 6). This condition will be met when packaging is designed for material recycling, allowing the resulting secondary raw materials to be of sufficient quality to replace primary raw materials. What is more, PPWR states that when packaging becomes waste, it can be separately collected, sorted for specific waste streams, and recycled on a large scale (PPWR, Preamble, point 28 and Article 6).
The recyclability of packaging will be expressed in recycling performance classes: A, B, or C, as described in Table 3 of Annex II to the regulation. These are: class A – packaging with a recyclability of at least 95%; class B- at least 80%; class C – at least 70%. If a package’s recyclability is below 70%, the PPWR considers it non-recyclable, and placing it on the market will be banned from 2030. Furthermore, the PPWR plans to ban the market entry of Class C packaging from 2038.
From the perspective of municipal waste sorting facilities, this regulation should lead to an increased share of recyclable waste (materials). This means a greater proportion of mono-materials (PE, PP, PET) and fewer composite and multi-material packages. Physical characteristics of packaging, such as color, should also improve, and the amount of problematic and difficult-to-recycle waste should decrease. Consequently, the potential of waste directed to the sorting process will increase. With a given sorting process, this should result in a higher level of waste recovery and better preparation for recycling. At the same time, the share of residual waste remaining after sorting—which is used as high-calorific fraction for producing refuse-derived fuel (RDF)—should decrease. Thanks to more homogeneous materials, the waste stream should become more predictable, and the sorting effectiveness within a given technology should be higher. Due to the growing importance of the recycling sector, there may be additional requirements for sorting processes, such as: higher quality standards for the raw material supplied to recyclers (greater purity and material uniformity), the need to recognize low-quality recycled materials, which may differ from primary materials, the need to sort additional raw material fractions separately (a higher level of material separation).
In this scenario of changes to packaging and their impact on waste composition, increasing the effectiveness of sorting technology and processes will become even more significant. The automation and digitalization of sorting processes, as well as the ability to increase the efficiency and effectiveness of sorting and the purity of output streams, will also gain greater importance.
Using recycled content in packaging
The second key direction outlined in the PPWR is the use of recycled content in plastic packaging. According to the regulation, every part of a plastic package placed on the market must contain a specific minimum share of material from post-consumer waste. Depending on the type of packaging, the minimum recycled content is set at 10-35% by 2030 and will increase to 25-65% by the end of 2040 (Article 7).
This regulation should boost demand for recycled materials. For waste sorting facilities, this means increased demand for the separated raw material fractions. In turn, assuming other factors remain constant, this should translate into higher prices for sorted materials.
Reducing the amount of packaging waste generated
The third direction outlined in the PPWR that could impact sorting processes is the reduction of packaging waste generated. The regulation requires each EU member state to reduce the amount of packaging waste per capita by at least: 5% by 2030, 10% by 2035, 15% by 2040. These targets are compared to the amount of waste generated in 2018 (Article 43, Preamble, point 120). These goals have been set because of increasing amounts of packaging waste in the economy (Preamble, point 114). Currently, it’s hard to imagine that this trend will change or that these goals are realistic. Achieving them would require a drastic shift in consumption trends and models. And that is unlikely to happen on its own.
Additionally, the PPWR introduces restrictions on packaging mass and volume: “by 1 January 2030, the manufacturer or importer shall ensure that the packaging placed on the market is designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality, taking account of the shape and material from which the packaging is made.” (Article 10). It also highlights the need to reduce the empty space ratio, which should not be more than 50% (Preamble, point 84), and the need to reduce the consumption of lightweight plastic shopping bags (Article 34).
Reducing packaging size and the consumption of plastic shopping bags may lead to an increase in waste density and a higher proportion of smaller material fractions. This could potentially increase the efficiency of processing lines but also increase the share of fine fractions and create more difficult sorting conditions – especially with manual sorting technologies.
Controversies and discussions concerning the PPWR
However, the regulation also sparks controversy and will lead to further discussions. As EU law, the regulation is obligatory for all member countries and does not account for the specific conditions of individual nations. Its detailed solutions, and those to be set by subsequent legal acts implementing it, will negatively affect many market participants. An example of this is the lawsuit filed in March 2025 by five Czech waste organizations and companies to the Court of Justice of the European Union against the European Commission. The lawsuit seeks to declare Article 50 of the PPWR invalid. The first set of claims concerns the deposit-refund system, pointing to the discriminatory nature of the PPWR in this area and the danger of financial harm. According to the plaintiffs, the new regulations favor producers and producer-responsibility organizations by granting them exclusive access to valuable secondary raw materials, particularly PET, aluminum, and metals. This, in the plaintiffs’ view, distorts competition and devalues previous investments made by the recycling sector. The obligatory deposit system concentrates control over recyclable materials in the hands of a small group of entities. The plaintiffs argue that as a result of these solutions, they will lose a source of revenue and a return on investments made under previous rules, which in turn violates the principles of free competition and equal opportunities in the EU internal market1.
The Czech entities’ complaint results from the fact that the Czech Republic has its own independent strategy for achieving targets based on earlier directives. The plaintiffs argue that the European Commission is wrongly delegating the decision on technical measures for achieving obligatory deposit targets to the EU level, even though member states could achieve results independently. The introduction of an arbitrary regulation prevents the continued independent implementation of national-level goals and methods. This also applies to the second set of claims, which involve ignoring the recycling exemptions for aluminum that the Czech Republic had previously negotiated. In this area, too, the Czechs have their own individually agreed-upon path with the EU for achieving the target. The PPWR arbitrarily ignores the negotiated exemption, violating the principle of legal certainty, trust in the EU negotiation process, and creating legal chaos1.
Are the ambitious targets and standards of the PPWR achievable?
The aim of this article was not a detailed analysis of the PPWR or a comprehensive assessment of its impact on the waste management industry. This document is very extensive, and besides outlining fundamental directions, it also touches on many detailed and debatable issues that will cause controversy.
The ambitious targets, the arbitrarily imposed methods for their implementation, and the detailed criteria that still need to be developed and implemented—for things like packaging design, compliance with recycling performance classes, methods for assessing this performance, methodologies for calculating target achievement indicators, and other implementing regulations—will all put additional pressure on the waste industry. This raises questions about the general and technological capability of achieving such high-set goals and standards, implementing and controlling these extensive systems, and the associated costs and their funding sources.
PPWR – opportunities and challenges in the context of of Poland’s lack of an EPR system
The PPWR (Packaging and Packaging Waste Regulation) requires the use of solutions that will be implemented over a long-term perspective, aligning with the goals and indicators set for the years 2030–2040. However, it does not include solutions that will compensate waste sorting facilities for the costs they will incur due to the introduction of a deposit-refund system in Poland, starting in October 2025.
The regulation can create specific opportunities for waste sorting facilities by increasing the potential of the waste stream and improving market conditions (leading to higher prices for sorted secondary raw materials). At the same time, it is also generates new challenges related to adapting technological systems, modernizing sorting plants, and the necessity to increase sorting effectiveness. These challenges must be viewed in the context of a national deficit in technological infrastructure and the inadequacy of existing systems to meet current needs. The administrative and legal barriers that exist do not help in the efficient preparation and execution of investments. Waste sorting facilities, which are meant to play a vital role in waste recycling, will be economically weakened by the introduction of the deposit-refund system. The market and economics are unstable for operational activities and investment planning. An EPR (Extended Producer Responsibility) system is not in place – a system that could, and should, stabilize economic conditions and serve as a motivational force for building or developing the technological infrastructure for waste sorting and recycling. Such a system would enable the achievement of higher targets in this area. As a consequence, waste management fees for residents are rising and will likely continue to rise.
Achieving waste management objectives requires a coherent system
Achieving waste management goals requires a smoothly functioning system, from the design and production of goods and their packaging to the collection, sorting, and recycling of waste. This all depends on cooperation between these sectors. For this to happen, a mechanism to finance and motivate individual entities – the various parts of this system – is essential. The PPWR also points to this, repeatedly emphasizing the need for incentives, or solutions that encourage specific behaviors. These include: modulating fees based on the type of packaging introduced to the market (Preamble, point 28), increasing the recycled content in packaging (point 42), using reusable packaging (point 63), improving sorting capacity (point 65).
Implementing a proper EPR system remains a priority for Poland’s waste management
The PPWR (Packaging and Packaging Waste Regulation) will not replace the EPR (Extended Producer Responsibility) system. EPR is a system for financing waste management and economically motivating various entities -such as producers who introduce packaging to the market, municipalities (responsible for waste collection), facilities that ensure effective sorting, and recyclers – to make appropriate decisions and take action. The regulation is a collection of solutions that assume the existence of such a system, one tailored to a country’s specific needs and conditions. Polish facilities will have to wait several more years for the full implementation of EPR, which is a negative situation. Municipal facilities will be under particular pressure. On one hand, to meet rising targets and implement the solutions outlined in the PPWR, better – and more expensive – collection systems and new sorting and recycling technologies will be necessary. On the other hand, the financial resources to fund these are limited. Furthermore, there is currently no guaranteed financial support to provide economic stability and operational profitability for these facilities.
The key to success will be to economically link the production and consumption of goods with the waste management sector. (Explained in detail in the article: “EPR system. Will Poland use the opportunity to create a driving force for its waste management economy?”)
The source:
- Česká žaloba na PPWR: kritika povinného zálohování i dopadů na systém třídění, www.obaly21.cz, as of: 14.08.2025.
