Page 74 - FoodFocusThailand No.242 June 2026

STRENGTHEN THE PACKAGING

Multilayer Packaging: such as recycling criteria and minimum recycled content, will
Challenges from Regulatory Uncertainty be enforced only once the implementing and delegated acts
The primary concern among stakeholders centers on multilayer are adopted, with further details developed through standard
packaging, a technology that extends shelf life, reduces regulatory procedures in subsequent phases.
contamination, and improves logistical efficiency. The PPWR
may introduce new limitations or conditions that could constrain Key Measures and PPWR Enforcement Timeline
its future use. The PPWR outlines a phased transition from 2026 to 2040,
The core issue is not a direct “prohibition,” but rather covering measures from the control of hazardous substances
uncertainty over which materials will be permitted under the new to targeted outcomes within the circular economy. (Table 1)
rules, compounded by the lack of clear guidelines, FAQs, and
implementing or delegated acts that typically provide detailed Strategic Advice for Thai Manufacturers
technical specifications, thereby limiting industries’ ability to Thai manufacturers, especially in the food and beverage
accurately assess and evaluate potential impacts. sector, should view the PPWR as a catalyst for structural
These uncertainties directly affect manufacturers’ investment transformation rather than merely a set of regulations. Waiting
planning, as packaging reformulation requires not only material for full clarity may result in missed opportunities for adaptation
changes but also adjustments to machinery, product design, and increased long-term costs.
and the broader supply chain, all of which demand additional Operationally, the transition should begin with a risk
time and cost to ensure effective transitions. assessment of current packaging materials, particularly
multilayer structures. This should be followed by pilot transition
EU’s Directions: tests, such as switching to mono-material packaging for
A Gradual Transition via Implementing selected products, and the gradual, proportionate integration
and Delegated Acts of recycled materials into manufacturing processes, to ensure
According to the EU, as the PPWR remains in a detail-defining operational flexibility in response to evolving EU regulations.
phase, its clarity is expected to improve once implementing and As a mid-term strategy, manufacturers should design
delegated acts, covering technical aspects such as recyclability packaging that meets multiple market requirements,
criteria and mandatory recycled content, are adopted. Rather particularly EU-ready standards, and closely monitor updates
than immediate enforcement, the regulation will be introduced to the PPWR’s implementing and delegated acts. Detailed
through a gradual transition to facilitate industrial adjustment. criteria on recyclability and technical specifications will
The criteria for multilayer films are still being developed in directly determine market access requirements.
collaboration with the European Committee for Standardization Finally, the ability to prepare and adapt in advance
(CEN). There is no indication of an immediate ban, as these will not only mitigate regulatory compliance risks but also
materials are also widely used by European industries. strengthen competitive advantages in European markets,
Accordingly, the transition will focus not on outright prohibition where packaging standards are continuously evolving under
but on refining existing criteria and improving material efficiency the PPWR framework.
to align with circular economy objectives.
According to the EU, implementation details will be clarified
through the committee guidelines, FAQs, the DG Environment
website, and the Access2Markets platform, all of which
are readily accessible to stakeholders. Key requirements, More Information Service Info C012
74 FOOD FOCUS THAILAND JUN 2026

22/5/2569 BE 17:28
70-74_Strengthenb Pack_NFI.indd 74 22/5/2569 BE 17:28
70-74_Strengthenb Pack_NFI.indd 74