Kayleigh's Thought Leadership: China just released it's Five-Year Circular Economy Development Plan with targets covering resource productivity, recycling and prioritising key materials such as steel, plastics, textiles and renewable energy equipment. The plan links circular economy development to resource security, supply chain resilience, industrial upgrading and green transformation. This isn't simply a waste management strategy. China has positioned circularity as industrial, resource and economic policy, making the direction of travel unmistakable. Read more here.
Finance: UNEP FI has launched new guidance, Circular Solutions to Achieve Nature Targets, to help commercial banks mitigate nature loss and financial risks by embedding circular economy solutions into their strategies. This report provides a framework spanning marine, freshwater, and terrestrial ecosystems - such as resource efficiency, circular water management and regenerative land use - detailing how banks can integrate circularity into governance, risk management, portfolio screening, and client transition plans. By linking financial decision-making directly to biodiversity goals, the report helps institutions align with the Kunming-Montreal Global Biodiversity Framework and the Principles for Responsible Banking.
Policy: The EU has launched a consultation on VAT, as part of the Circular Economy Act update, to support the transition to a low-carbon, circular economy. This could include VAT reduction for businesses buying second-hand or refurbished goods, removal of VAT entirely for businesses buying low-emission cars and restructuring of the current VAT deduction for unsold goods which may favour destruction over reuse. The public consultation is open until 4 November 2026 and you can have your say here.
Action This π‘
Speaking to your leadership as to why PPWR compliance is a business opportunity - not just a compliance exercise - can create the buy-in needed.
- Certain PPWR obligations, such as packaging minimisation, literally specify less material. Less material = cost savings.
- Meeting PPWR obligations before the deadline, requiring your supply chain to be more sustainable. This all builds positive brand reputation that your business can shout about.
- Redesigning your packaging early lets businesses lock in competitive long-term procurement contracts for high-quality recycled materials, before demand spikes.
The top PPWR challenges
This year I have been helping companies get ready for PPWR - from pharmaceuticals and HVAC to industrials and retail.
PPWR has no company size or revenue threshold. This means if you sell packaged goods or packaging into the EU, you almost certainly have obligations.
Many companies are facing the same challenges getting PPWR-compliant. Below are the top challenges I am seeing over and over again, and my recommendations on how to mitigate them.
PPWR is ultimately a data consolidation exercise. Many companies have fragmented data. SKU tonnages held in different countries. Material composition held in one department that doesn't talk to others. Packaging ratios held by suppliers.
Whenever I start working with a company on PPWR, I always recommend consolidating and cleaning the data, and assigning ownership, as a first step. By doing this, you will be able to spot data gaps, assess whether remediating one obligation meets or conflicts with another, and be able to quickly access the data for supplier or enforcement requests.
PPWR puts obligations on every stakeholder in the packaging value chain. If you are not responsible for the Declaration of Conformity as a Manufacturer, as an Importer or Distributor you still have a responsibility to have the data on file to demonstrate compliance.
PPWR requires a ton of data. My top recommendation for supplier data requests is to ensure comprehensiveness from the start, in a single document, to save time-consuming back and forth. For example, any information on existing tests - third-party or internal - necessary to meet the PPWR obligations. Or, if compliance assessments have been done for other regulations, (like REACH in the case of hazardous substances). It is crucial you also ask for evidence attached, as a supplier declaration without evidence is not enough to meet PPWR compliance!
- Thinking 2030 is far away
PPWR has obligations coming into force in 2026, 2028 and 2030. Many businesses I've been working with naturally focus on the most pressing 2026 obligations, which is understandable. However, 2030 is only 4 years away. 2030 obligations cover aspects such as recycled content, reusability, recyclability and packaging minimisation. To meet these obligations packaging redesign may be necessary, which can have lengthy lead times, especially for multinational corporations with complex supply chains.
This is why I recommend businesses to start thinking about these obligations in parallel. If you're in the process of consolidating your packaging data, ensure it covers data for all obligations. Start thinking about whether you anticipate packaging redesign for future obligations - you can at least get company buy-in to prevent roadblocks down the line, even if you don't enact it yet.
If you relate to any of these challenges, I got you! I've launched a completely free 5-minute diagnostic that flags your actual exposure areas under PPWR.
Smart Picks π§
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 resolves most of the interpretive grey areas. Keep this guidance document handy as a primary source on PPWR.
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
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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 to avoid financial penalties.
π© Any other collaboration: Whether it's partnerships, projects or something else, just reply to this email, and let's chat!
Kayleigh Lee-Simion
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