recyclability criteria. This review process isn’t quick or cheap, and many companies are facing it with an urgency they didn’t have twelve months ago. In design, the biggest transformation is cultural rather than technical. For decades, packaging was designed with the point of sale and product protection in mind. End-of-life was, at best, a secondary consideration. That order of priorities is changing, and altering such a deeply ingrained design criterion requires more than just updating a brief: it requires retraining teams, reviewing approval processes, and, in many cases, renegotiating with suppliers. In the supply chain, the pressure is shifting upwards. Converters are receiving new specifications from their customers, which in turn reflect the demands of their own customers or the Extended Producer Responsibility (EPR) systems in which they operate. Material traceability, verifiable recycled content, recyclability documentation: all of this is now part of the daily business dialogue in a sector where it was barely mentioned five years ago. At Formaspack, our response has been to work from the material’s origin: we recover what the conventional system would treat as waste, we valorize it to restore its technical properties, and we return it to the production cycle in the same application, closing the loop without losing value. The mistake many companies are making There’s a trap that organizations facing regulatory changes of this magnitude frequently fall into: treating them as compliance projects. A compliance project has a start date, an end date, and a person responsible. It closes when the minimum required threshold is reached. But the transition to circularity doesn’t work that way. The 2030 requirements are a first threshold, not a destination. Those that will come after will be more strict, and companies that have treated this adaptation as a one-off project will find themselves back in the same position in three years. The second mistake is confusing theoretical recyclability with actual recyclability. There are currently certified recyclable containers on the market that, in practice, are not being recycled because collection systems are not prepared, because the volumes are insufficient for recyclers to process them, or because the combination of materials makes separation difficult. The new regulations aim precisely to close this gap, and companies that have built their sustainability arguments on this theoretical recyclability will have to revise them. The third mistake, perhaps the most costly, is waiting. Adapting materials, redesigning product references, searching for alternative suppliers, and validating new structures take time. With the full implementation of the PPWR on August 12, 2026, companies that have not yet begun this process have made decisions under pressure and with very little room for maneuver. Circularity as a competitive advantage Having said all of the above, it’s worth concluding with a strategic point. Companies that are integrating circularity as an operational criterion—not as a reactive response to regulation—are building a differentiated position that goes beyond mere compliance. Their customers are increasingly auditing the supply chain. Large consumer goods groups have their own sustainability commitments that they need to pass on to their suppliers. A converter or packaging manufacturer that can demonstrate verifiable recycled materials, design for recycling, and processes that close the loop not only complies but also makes it easier for their customers to comply. This has real commercial value, and in a market where technical differentiation between competitors is increasingly limited, it is significant. European packaging regulations are not easy. They require investment, process review, and, in many cases, difficult conversations with customers and suppliers. But they are also accelerating a transformation that the sector needed, and in this transformation, as in almost all others, some companies arrive sooner and others later. By August 12, that decision has already been made in most cases, depending on whether the process started on time or not. What remains open is the next stage, the 2030 thresholds, which are more demanding and still offer some leeway to decide which of the two groups a country wants to belong to. 38TEMA CENTRAL I MAIN TOPIC Circular o fuera del mercado Circular or out of the market ANA SASTRE, CEO Formaspack UpcyclinG Group
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