Your monthly source for circular economy insights - redesign systems, reduce risks, drive real impact.
π Are you ready for PPWR?
Published 21 days agoΒ β’Β 3 min readΒ β’Β Policy
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Hey Reader π
Welcome to the 23rd edition of Circular Digest!
Hello from Central Asia π I have just got back from a 10-day tour of Kyrgyzstan. It's a stunning country with beautiful, diverse nature, from canyons and beaches, to mountains and valleys. One thing that really stood out to me was the symbiosis between traditional Kyrgyz lifestyles and nature. People grow up milking cows, riding horses and hunting their food. A far cry from city life.
I must apologise for missing June but I've been working on something very exciting! The Packaging and Packaging Waste Regulation (PPWR) comes into force in August of this year. From many conversations I've had, significant numbers of SMEs do not know their exposure under PPWR... and most importantly, what needs to be done to be compliant.
So I've built something to help you! More on this below β¬οΈ
Circular Roundup
Finance: The International Finance Corporation released a Circular Economy Investment Tracker.Since 2018, $198bn has been privately invested to increase the circularity of electronics, appliances, packaging & textiles. Regionally, US is leading the way, closely followed by Europe. The majority of these deals relate to value recovery at End-of-Life, showing more needs to be done to invest in circularity further upstream, in the design and use phase.
Source: Circular Economy Investment Tracker (International Finance Corporation)
Kayleigh's Thought Leadership: Andy Burnham has just become PM, and there have been a lot of calls urging him to drill what little we have left of the North Sea Oil, for short-term economic gain. What strikes me in these conversations, is the multi-billion economic cost of global warming is never mentioned. From reduced productivity, increased mortality and damage to farming and infrastructure. More thoughts here.
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Action This π‘
Pull your top 5 SKUs by shipment volume this week and check one number: empty space ratio. An approx. methodology (packaging volume vs product volume) is fine at this stage.
If you find a format that's mostly air, that's your starting point for a supplier conversation. Since redesigns can take 12β24 months to execute, understanding this now for the 2030 deadline is crucial.
Are you ready for PPWR?
The Packaging and Packaging Waste Regulation (PPWR) is an update from the Packaging and Packaging Waste Directive. This is a Regulation meaning the obligations and rules are harmonised across all 27 EU Member States.
PPWR has no company-size or revenue threshold. If you sell packaged goods or packaging into the EU, you almost certainly have obligations, even as an SME with no compliance team. The narrow exception is micro-enterprises (<10 employees, <β¬2m turnover and/or balance sheet per year) sourcing from a domestic EU supplier, where some obligations shift upstream.
From my many discussions over the last few months, two things are catching SMEs out right now:
If a product has your branding, you carry full manufacturer obligations, even when a third party physically produces the packaging. Most brand owners don't realise this.
For the first time in EU history, food-contact packaging must be PFAS-tested, with legal limits now in force from 12 August 2026.
Generic checklists will tell you what PPWR says... but that's already public.
What they can't tell you is where your business actually stands, because that depends on your specific role, structure, and documentation.
Today I am launching a completely free5-minute diagnostic - from role determination and EPR registration to governance and PFAS documentation - that flags your actual exposure areas.
PPWR Guidance Document - The European Commission published its final PPWR Guidance document and accompanying FAQ on 30 March 2026, formally adopted in the Official Journal on 10 June 2026. It's dense, but it resolves most of the interpretive grey areas that have been rife for speculation. If you read one primary source on PPWR this year, this is the one.
What did you think of this edition of Circular Digest? If you have any thoughts, questions, or ideas for future content, reply to this email. π
β See you next month!
Kayleigh
How can I help you? πͺ
Here's how I can help you, whenever you are ready:
π¦ Book a PPWR Gap Analysis here: Score yourself, then book a fixed-fee, fixed-scope gap analysis that turns your score into an actionable set of priorities: your role, your most pressing obligations and your exposure before the deadline.
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