DPPs for the Food Packaging Industry

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Food Packaging and the Push for Circular Packaging Systems

Food packaging represents one of the most visible and contested areas of the sustainability debate. Packaging is essential for food safety, shelf life extension, and waste prevention, yet it generates enormous quantities of waste, the EU produces approximately 84 million tonnes of packaging waste annually, of which food packaging constitutes a significant proportion. The challenge is not to eliminate packaging but to transform it into a truly circular system where materials are recovered, recycled, and reused at the highest possible quality.

The Ecodesign for Sustainable Products Regulation (ESPR) and the revised Packaging and Packaging Waste Regulation (PPWR) together establish the framework for this transformation. Digital Product Passports for packaging will provide the standardised data infrastructure that enables material identification, recyclability assessment, and recycled content verification at scale. For the food packaging industry specifically, these requirements intersect with food contact material safety regulations, creating a uniquely complex compliance landscape.

This guide examines the specific DPP requirements for food packaging, the data that will need to be captured, and the practical steps that packaging manufacturers, converters, and brand owners should take to prepare for compliance.

Regulatory Landscape: ESPR and the Packaging Regulation

Food packaging DPP requirements will be shaped by two primary EU regulations. The ESPR establishes the general framework for DPPs and the ecodesign requirements that apply to all product categories, while the revised PPWR introduces packaging-specific rules on recyclability, recycled content, minimisation, and reuse. The two regulations are designed to complement each other, with the DPP serving as the common data carrier for packaging sustainability information.

The PPWR introduces several provisions that directly affect DPP requirements for food packaging. From 2030, all packaging placed on the EU market must be recyclable, and from 2035, it must be recycled at scale. Mandatory recycled content targets are established for plastic packaging, with targets increasing over time. The regulation also introduces restrictions on certain packaging formats and requires clear consumer-facing labelling of packaging materials and collection instructions.

For food packaging specifically, these requirements must be balanced against food contact material safety regulations. Any material that comes into contact with food must comply with Regulation (EC) 1935/2004 and relevant specific measures such as the plastics regulation. This creates a particular challenge for recycled content requirements, as recycled materials used in food contact applications must meet stringent purity standards. DPPs will need to document both the sustainability credentials and the food safety compliance of packaging materials.

Key Data Fields for Food Packaging DPPs

Food packaging DPPs will need to capture data across multiple dimensions, material composition, recyclability, recycled content, food safety compliance, and environmental footprint. The specific requirements will be detailed in the ESPR delegated acts and PPWR implementing measures, but the following data fields are expected based on the regulatory text and preparatory work.

• Complete material composition of the packaging, including all layers in multilayer structures
• Material identification codes aligned with European standards for sorting and recycling
• Recyclability classification based on design-for-recycling criteria and compatibility with existing collection and sorting infrastructure
• Recycled content percentage for each material, with specific tracking for post-consumer recycled content
• Food contact compliance declarations and migration testing results where applicable
• Substances of concern present in packaging materials, including printing inks, adhesives, and coatings
• Weight and material efficiency data demonstrating compliance with packaging minimisation requirements
• Compostability certification where relevant, including whether the packaging is certified for industrial or home composting
• Reuse system information for packaging that is part of a reuse scheme
• Carbon footprint data for the packaging lifecycle

The level of detail required for multilayer packaging structures is particularly noteworthy. A typical food packaging laminate might combine polyethylene, aluminium, polyester, and printed layers, each with different properties and recycling implications. The DPP must document this structure in sufficient detail to support accurate recyclability assessment and inform waste sorting decisions.

Recyclability Classification and Design for Recycling

Recyclability is arguably the most important DPP data point for food packaging. The PPWR establishes a classification system that grades packaging recyclability from A to E, based on design-for-recycling criteria and the availability of collection, sorting, and recycling infrastructure at scale. From 2030 packaging graded D or E can no longer be placed on the market, and from 2038 only grades A and B remain, creating a strong incentive for packaging redesign.

For food packaging, achieving high recyclability classifications requires careful attention to material selection, structure design, and auxiliary components. Common barriers to recyclability in food packaging include opaque or coloured PET that interferes with sorting, multilayer structures that cannot be separated by existing recycling processes, non-detachable components such as sleeves or labels made from incompatible materials, and small format packaging that falls through sorting screens.

DPPs will need to document the recyclability assessment for each packaging format, including the specific design-for-recycling criteria that have been applied and any limitations on recyclability. This information serves multiple purposes: it enables brand owners to make informed packaging choices, provides transparency to consumers about the recyclability of their packaging, and supports waste management operators in optimising sorting and recycling operations. For a broader understanding of how DPPs drive material transparency, see our guide on supply chain transparency with DPPs.

Recycled Content Mandates for Plastic Packaging

The PPWR establishes mandatory recycled content targets for plastic packaging that will be phased in over the coming years. From 2030, contact-sensitive plastic packaging (including food packaging) must contain a minimum percentage of post-consumer recycled content, with higher targets applying from 2040. These targets vary by plastic type and packaging application, reflecting the different technical challenges associated with recycling different polymers to food-grade quality.

For food packaging, the recycled content requirements present particular technical challenges. Food-grade recycled PET is relatively well established, with EFSA-approved recycling processes and growing supply. However, food-grade recycled polyethylene and polypropylene are less mature, and the availability of certified recycled material for food contact applications remains limited. The DPP must document not only the recycled content percentage but also the source and certification of the recycled material, providing verifiable evidence of compliance.

Mass balance and chain of custody certification approaches are being developed to support recycled content verification in packaging supply chains. DPPs will need to accommodate these methodologies, clearly indicating whether recycled content claims are based on physical segregation, mass balance, or other approaches. This transparency is essential for maintaining credibility and avoiding greenwashing concerns.

Substances of Concern in Food Packaging

Food packaging presents a unique dimension of the substances of concern challenge. Materials in direct contact with food must comply with strict migration limits to ensure that chemicals do not transfer into food at levels that could pose health risks. The ESPR's substances of concern requirements add a further layer of transparency, requiring disclosure of certain substances present in packaging regardless of whether they are regulated under food contact legislation.

Printing inks, adhesives, and coatings are areas of particular attention for food packaging. While these materials may not be in direct food contact, they can migrate through packaging layers, particularly under heat or prolonged storage. The transition from mineral oil-based printing inks to alternatives with lower migration potential is already underway in the industry, driven by both regulatory pressure and consumer expectations.

PFAS chemicals, which have been widely used in food packaging for their grease and water resistance properties, are another critical area. The proposed EU-wide restriction on PFAS will significantly impact food packaging, and DPPs will need to document PFAS-free status or, where PFAS are still present, disclose their use and concentrations. The food packaging industry should be actively transitioning away from PFAS-based treatments in anticipation of both the PFAS restriction and the DPP transparency requirements.

Timeline and Preparation for Food Packaging Businesses

The timeline for food packaging DPP requirements is shaped by both the ESPR and the PPWR. The PPWR's recyclability classification requirements are expected to apply from 2030, with the more stringent recyclability thresholds taking effect from 2035. Recycled content mandates will be phased in from 2030, with higher targets from 2040. ESPR-specific DPP requirements will be determined by the relevant delegated acts, which are expected to be developed in alignment with the PPWR timeline.

For food packaging businesses, the key preparation steps include assessing current packaging portfolios against design-for-recycling criteria, establishing recycled content sourcing strategies, and building the data management infrastructure needed for DPP compliance. The complexity of food packaging supply chains, involving raw material suppliers, converter, brand owners, and co-packers, means that data-sharing agreements across the value chain will be essential.

We recommend beginning with a portfolio review that maps each packaging format against expected recyclability and recycled content requirements, identifies gaps, and prioritises redesign efforts. For practical guidance on getting started with DPPs, our guide to creating your first Digital Product Passport provides a step-by-step approach that can be adapted for food packaging applications.

The Future of Transparent Food Packaging

Digital Product Passports for food packaging represent a step change in transparency for an industry that has traditionally been characterised by complex supply chains and limited material traceability. By creating standardised, digital records of packaging composition, recyclability, and environmental performance, DPPs enable a more circular packaging system where materials are valued, recovered, and reused effectively.

The food packaging industry is already in the midst of a significant transformation, driven by consumer expectations, retailer commitments, and regulatory pressure. The Plastics Pact network, the Ellen MacArthur Foundation's work on packaging, and national EPR schemes are all pushing in the same direction. DPPs provide the data infrastructure that connects these initiatives, enabling evidence-based decision-making and verifiable progress towards packaging circularity.

For forward-thinking packaging businesses, DPPs offer an opportunity to differentiate through genuine transparency, to build deeper relationships with brand customers who are themselves facing sustainability reporting obligations, and to contribute to the systemic change needed to solve the packaging waste challenge. The businesses that invest in DPP capability now will be best positioned to lead the food packaging sector into its circular future.