- 1Packaging accounts for a minority of a product's impact, unless it lets the product deteriorate.
- 2Reused glass may perform better or worse, depending on rotations and washing distance.
- 3Avoided extended producer responsibility (EPR) fees form part of the business case for packaging redesign.
- 4Bpifrance Diag Éco-conception: 60 to 70% funded, with a remaining cost from €5,400 excl. VAT.
Almost all the requirements converge on 1 January 2030 under the European packaging regulation, the Packaging and Packaging Waste Regulation (PPWR). Recyclability of all packaging, minimum recycled plastic content, banned formats in Annex V, an empty space ratio capped at 50% and the first reuse targets: these obligations share a target date, which is the earliest possible date for recyclability, recycled content and the empty space ratio.
Packaging redesign moves at the pace of supplier contracts. You need to qualify an alternative, validate its ability to protect the product, use up stocks already ordered and sometimes modify a packaging line. Each step takes months, extending the overall lead time.
1Redesign lead times depend on supplier qualification
A portfolio inventory takes three to four months, because packaging data is scattered across procurement, quality and production, often in files that are not linked. Assessing the key packaging types takes another four months, and qualification with the supplier six to twelve months.
That means 18 to 24 months before the first packaging type changes specification. Starting in 2026 leaves a comfortable margin and allows you to work through the portfolio in stages. Starting in 2028 leaves little room for manoeuvre: decisions then lack a basis for comparison, and the choice falls to whichever supplier is available.
Two years between the decision and the first modified reference
Three workstreams that follow one another, and a fixed deadline of 1 January 2030. Durations depend on supplier contracts and qualification cycles.
References, materials, weights, volumes, tonnages.
The impact contributors and the quantified gains of a redesign.
Specification, performance tests, industrial validation.
Between the decision and the placing on the market of the first modified reference.
Retailers are also bringing the timetable forward. They adjust their specifications ahead of the regulation, to avoid being left with packaging types they cannot sell. Several retailers already require a recyclability data sheet when listing a product, bringing the practical deadline forward to 2028 for companies selling through major retailers.
2Packaging protection shapes the overall environmental impact
For a food product, a life cycle assessment (LCA) (in French) shows that packaging accounts for a minority of the total impact. The contents dominate, sometimes by a wide margin, and this balance determines the choices that follow.
Even with that minority share, packaging can increase or reduce the overall impact. Inadequate packaging lets the product deteriorate, and the lost product carries its entire production impact with it. ADEME (the French Agency for Ecological Transition) makes this point: for some products, a little more packaging may be the option with the lowest impact, provided it prevents the contents from being lost.
Reducing material without monitoring breakage may therefore worsen the overall result. Reducing the weight of packaging that provided adequate protection by 15%, while the breakage rate rises from 0.5% to 2%, is enough to cancel out the gain once the packaged product's impact exceeds roughly ten times that of its packaging.
The four main sources of impact
- Raw material production, almost always the largest source of impact for single-use packaging, and the one most affected by recycled content.
- The weight transported, which depends much more on density and the number of units per pallet than on distance travelled.
- Empty space, long overlooked in assessments and now regulated: it means extra lorries and more void-fill material.
- End of life, whose effect depends less on the material specified than on the waste management system available where the product is sold.
Their ranking changes with the product. For a beverage bottle, material and weight outweigh everything else. For an e-commerce parcel, empty space comes first: an oversized box increases both void fill and transported volume. A first product LCA (in French) starts by establishing this ranking.
The four impact contributors, and why their order changes
The same four contributors appear everywhere, but their hierarchy depends on the product being packaged. Switch profile to see the ranking reorder.
The largest contributor on almost any single-use packaging, and the one that recycled content shifts the most.
Determined by density and the number of units per pallet, much more than by the distance travelled.
Depends less on the stated material than on the end-of-life route that actually exists where the product is sold.
Long invisible in footprint assessments, now regulated, it is paid for in lorries and in void-fill material.
Qualitative orders of magnitude. The actual ranking for a given piece of packaging is determined by an LCA on its own data.
Reusable glass and single-use packaging
ADEME examined this question through fourteen scenarios in its environmental assessment of deposit return for reuse in France. Its findings depend on specific conditions: return rate, packaging weight and distance between the collection point and the washing facility. Reuse becomes favourable when it completes many rotations and is washed nearby, and its advantage diminishes as the logistics loop lengthens. The framework for reuse targets sets a direction, but does not remove the need to assess your own loop.
Compostable packaging is not necessarily recyclable
The word "compostable" describes the ability to break down under controlled conditions. ADEME points out that compostable plastics are not a miracle solution: this packaging rarely reaches a composting facility, as operators remove it upstream because they cannot distinguish it from other plastics. Composting is not recycling, as most of the material becomes CO2. Compostable packaging retains a role in targeted uses, typically packaging soiled by biowaste.
Mono-material packaging and barrier performance
Mono-material packaging meets the 2030 recyclability criteria most readily, while multilayer composites face the highest penalties under eco-modulation. The barrier preserves the product for its intended shelf life: substituting material without requalification shifts the impact from packaging waste to product waste. Mono-materials with enhanced barriers are available today for several dry product categories. The obstacle often lies elsewhere: the existing packaging type has already been qualified, it works and nobody has a mandate to revisit it.
For the same product, a change in washing distance or return rate can reverse the ranking of two packaging options.
3An inventory establishes the scope and cost of assessment
The inventory comes before the LCA. Few companies fully understand their packaging portfolio before consolidating the data, and assessment is meaningless when the scope is uncertain. Our 7-step eco-design process (in French) sets out the general approach; what follows applies it specifically to packaging.
The most underestimated cost is still internal staff time. Finding the exact weight of a packaging type sometimes means weighing it, calling a supplier again or reopening a technical data sheet from 2019. Allow three to six full-time-equivalent months, spread across the project and shared between procurement and quality teams.
What the engagement covers and costs
- Consolidated packaging inventory, around 3 months: packaging types, materials, weights, volumes and declared tonnages. €15,000 to €30,000.
- Packaging LCA for 3 to 5 key packaging types, around 4 months: those responsible for the tonnage, rather than those prompting internal debate. €20,000 to €50,000.
- Eco-design plan and supplier specifications: quantified scenarios, target weight, recycled content rate and an enforceable recyclability criterion.
These ranges cover assessment and the eco-design plan, which is the work we carry out. Performance trials, supplier qualification and conformity testing remain with your teams and suppliers, with their own lead times. Our article on the cost of a product LCA (in French) examines the budget in more detail.
Avoided EPR fees contribute to the business case
Eco-modulation adjusts the EPR fee (éco-contribution) paid to the producer responsibility organisation (PRO, éco-organisme in French) according to the packaging's characteristics: bonuses for reduction, incentives for incorporating recycled material and penalties for recycling disruptors. In France, Citeo describes a progressive fee schedule that may rise from 10% to 100% of the fee over several years.
This cost applies to recurring annual tonnages, making it a factor in profitability that is rarely quantified in decision papers. For future planning, Citeo expects the harmonised European recyclability score to supersede part of the national fee schedules by 2028-2030. Decisions are therefore better based on physical parameters, weight, materials and recyclability, which will remain valid after harmonisation.
Funding and further uses for the assessment
In France, Bpifrance (the French public investment bank) offers the Diag Éco-conception (eco-design diagnostic), funded by ADEME, covering 60 to 70% of an engagement budgeted at €18,000 excl. VAT: scoping, product LCA and an eco-design plan. The remaining cost is €5,400 excl. VAT for fewer than 50 employees, or €7,200 excl. VAT for fewer than 250, for small and medium-sized enterprises (SMEs) under the European definition, including micro-enterprises, in all sectors. Projet Celsius is approved under this scheme and handles the application with you. Other grants may be combined with it (in French).
The database created for this work has further uses: it supports the Digital Product Passport (in French) and eco-design requirements under the Ecodesign for Sustainable Products Regulation (ESPR) (in French), whose timetable largely overlaps (in French) with that for packaging. This is the approach we use in our work on textile eco-design (in French), where a single database supports four obligations.
The output of this work must be enforceable against a supplier. A report limited to general recommendations leaves packaging types unchanged. Specifications setting a target weight, a recycled content rate and a verifiable recyclability criterion give the supply chain binding requirements.
4Key takeaways
- 5 obligations target 1 January 2030: banned formats and the first reuse targets on that date, with recyclability, recycled content and the empty space ratio applying from that date at the earliest (full timetable).
- 18 to 24 months separate the decision from the first specification change, allowing time for the inventory, assessment and supplier qualification.
- Packaging accounts for a minority of a product's impact, but poorly judged weight reduction causes the contents to be lost, as ADEME has documented.
- Reusable glass, compostable packaging and mono-materials: every comparison depends on measurable conditions, rather than the material alone.
- Diag Éco-conception funds 60 to 70% of an engagement budgeted at €18,000 excl. VAT, with a remaining cost from €5,400 excl. VAT. Projet Celsius is approved under this scheme.
