The EU produced 4.2% more packaging waste per person in 2024 than in 2018, so the PPWR's "5% less by 2030" is a cut of almost 9% from where Europe stands, and of 20% or more in eight Member States

What Article 43 says, paragraph by paragraph

SPI tracks the prevention targets as PR-EU-011 in the regulation tracker. SPI read Article 43 in the German text as reproduced by LX Gesetze, an unofficial reproduction, and translated it. Exhibit 2 sets out the nine paragraphs.

The target is national and per person. Paragraph 1 contains no company duty and no material split. The Commission’s guidance says so directly in its section on national exemptions from the reuse targets, where it ties those exemptions to the Article 43 result (Commission Notice C/2026/3084, section 24). A Member State can meet its target with any mix of materials, which is why the same 5% will mean heavier fee pressure on some formats in one country and on others elsewhere.

The baseline is the reported 2018 figure. Article 43(1) refers to the figure each Member State reported for 2018. SPI uses the current Eurostat env_waspac series, which holds those reports as Eurostat now publishes them; if a state’s 2018 figure has been revised since, the baseline the Commission uses may differ from the one in Exhibit 1. SPI has not yet confirmed whether any Member State asked for a different base year under Article 43(8) by the 31 December 2025 deadline.

Plastic gets an effort duty, not a number. Paragraph 4 is worded as an endeavour, unlike the fixed percentages of paragraph 1. Plastic was 35.9 kg of the 181.0 kg per person in 2024, Eurostat says, and SPI’s Eurostat news piece covers the plastic recycling side of that release; this piece does not repeat it.

National measures carry the brand impact. Paragraph 5 lists economic instruments and other incentives that apply the waste hierarchy, EPR incentives, and obligations on producers or producer responsibility organisations to adopt waste prevention plans. Paragraph 7 limits them: proportionate, non-discriminatory, no trade barriers, and no push from heavier to lighter packaging materials. Recital 121 repeats that last warning and asks Member States to prioritise measures that minimise the risk (EUR-Lex, recitals).

How Europe got further from 2018

The EU series has not moved in a straight line. Exhibit 3 shows it from 2014, so the 2018 baseline can be read against the years around it.

Three things stand out. First, 2018 was a slightly lower year than 2017, at 173.64 kg against 174.21 kg, so the baseline is not inflated. Second, the 2021 peak of 190.28 kg sat 9.6% above the baseline, by SPI’s calculation, and the fall to 2023 took most of that back. Third, the 2024 rise of 3.2 kg per person, which Eurostat reported, ended the fall: 2024 is 4.2% above 2018 and 16.03 kg per person above the 164.96 kg line for 2030, so the cut needed from 2024 is 8.9% of the 2024 figure.

Eurostat’s method note matters for brands reading these numbers. The figures cover packaging waste generated by the whole economy, households, businesses and government, and per capita figures divide national totals by the average resident population of the year (Eurostat news item, 22 October 2026). Commercial and industrial packaging is therefore inside the number. Recital 120 says per capita targets cannot apply as such to commercial and industrial packaging waste, because its generation is not related to household consumption, and Article 43(3) lets states with separate systems keep them (EUR-Lex, recital 120).

Why 5% per person is bigger than it sounds

The legislature itself sized the targets in absolute terms. Recital 120 compares each step with a baseline scenario in which nothing changes, and Exhibit 4 sets the two measures side by side.

Recital 120 says that meeting the 5% target by 2030 should entail an overall absolute reduction of about 19% on average across the Union, compared with the 2030 baseline scenario. The gap between the two numbers is growth: the baseline scenario assumes packaging keeps rising with consumption and population, so holding per capita waste 5% below 2018 removes far more tonnage than 5%.

Every Member State's 2030, 2035 and 2040 level

Exhibit 5 converts Article 43 into kilograms per person for each Member State, using the 2018 figure in Eurostat’s current series, and shows how far each must cut from its latest reported level.

SPI calculation. Each level is the 2018 figure times 0.95, 0.90 or 0.85. The cut needed is one minus the 2030 level divided by the latest figure. For Spain: 161.27 x 0.95 = 153.21 kg; 1 minus 153.21 / 194.43 = 21.2%. For the EU: 173.64 x 0.95 = 164.96 kg; 1 minus 164.96 / 180.99 = 8.9%.

The ranking by kilograms and the ranking by effort are different lists. Germany generated 214.72 kg per person in 2024, the fourth highest figure in the table after Italy, Ireland and Luxembourg, and yet it was 0.6% inside its 2030 level. Croatia generated 82.10 kg, among the lowest, and needs a 19.6% cut. Article 43 rewards movement from a state’s own 2018 figure, not a low level of waste, so a brand cannot read national pressure from the kilograms alone.

Two cautions apply. First, Article 43(2) asks the Commission to set a tourism correction factor by 12 February 2027, based on packaging waste per tourist and changes in tourist numbers since 2018 (Article 43, German text as reproduced). SPI has not yet confirmed which states the factor will change, or by how much, so the levels in Exhibit 5 are before any correction. Second, several series carry Eurostat flags, and three states have no value for 2024.

A framework: four groups by distance to target

SPI’s organising device for this piece sorts the 27 Member States by one number: the change in packaging waste per person from 2018 to the latest year. Exhibit 6 sets out the four groups that result and what each means for a brand selling there.

Group A, already below. Germany, Sweden, Estonia and France reached their 2030 line on Eurostat’s latest figures. Germany is only 0.6% inside it and needs a further 4.6% for 2035; France, at 7.3% inside, has room until 2035 and needs 4.0% for 2040. Brands should not read this as a free pass, because national laws in these markets already carry their own reduction aims, such as France’s single-use plastic decree.

Group B, within reach. Six states need cuts of 1.6% to 9.1%. Italy, with the highest per capita figure in the EU at 221.22 kg, sits here because its 2018 figure was also high.

Group C, stretch. Nine states need 10.0% to 20.2%. Denmark is the outlier by level: 197.09 kg per person in 2024, the highest figure outside Italy, Ireland, Luxembourg and Germany, and 13.9% above its 2018 figure.

Group D, far off. Eight states need more than a fifth. They include the two markets this piece looks at in detail below, Spain and Poland, and several others where the tourism correction factor may change the level.

Scenarios: three paths to 2030

The per capita figure for 2030 depends on what happens to packaging per person between now and then. Exhibit 7 tests three paths for the EU, Spain and Poland.

SPI calculation, base case. Held flat at 180.99 kg, the EU figure would be 16.03 kg above the 164.96 kg line in 2030. To reach it from 2024, packaging waste per person must fall by 1.53% a year for six years. Spain would need 3.89% a year, from 194.43 kg to 153.21 kg, and Poland 4.51% a year, from 180.43 kg to 136.78 kg.

The low case is the useful one. The EU fell by 1.65% a year from 2021 to 2024, from 190.28 kg to 180.99 kg, a fall that took in the 2023 drop and the 2024 rebound. If that pace held to 2030, the EU total would just clear its line, at 163.75 kg. The same pace would leave Spain 22.70 kg and Poland 26.46 kg short, because they start from further above their baselines.

What the national cut means per pack

A national per capita figure becomes a brand question once it is turned into grams per unit. SPI priced one illustrative food brand that sells 100 million units a year in Spain, each with 40 grams of packaging across primary, grouped and transport layers, so it places 4,000 tonnes of packaging on the Spanish market a year.

SPI calculation, illustrative brand. If the brand’s unit sales stay flat and it matches the national cut of 21.2% from 2024 to 2030, its packaging per unit falls from 40.0 grams to 31.5 grams, and its tonnage from 4,000 tonnes to 3,152 tonnes, a reduction of 848 tonnes. Matching the 10% step for 2035 from the same start, a 25.3% cut, takes it to 29.9 grams per unit. If instead unit sales grow by 2% a year while grams per unit stay at 40.0, tonnage reaches 4,505 tonnes in 2030, 505 tonnes more than in 2024. These figures are SPI assumptions, kept in tonnes and grams, and are not a forecast for any company.

The example shows why prevention is a portfolio question rather than a pack question. A brand can meet the national pace through lighter primary packs, fewer grouped layers, reusable transport packaging, refill formats or a change in sales mix, and each of those moves sits under a different PPWR article. Recital 119 lists the same levers: removing excess packaging and certain formats, longer packaging life, redesigned products and sales models including bulk, and a shift from single-use to reusable packaging (EUR-Lex, recitals; PR-EU-011).

Spain: a national target on top of the EU one

Spain is the one market in this piece with a prevention target already in national law. Article 6 of Royal Decree 1055/2022 sets a reduction in the weight of packaging waste produced of 13% in 2025 and 15% in 2030, against 2010 (BOE; PR-ES-002). Exhibit 8 sets the two Spanish targets side by side.

SPI calculation. 7,389,590 x 0.87 = 6,428,943 tonnes for 2025 and 7,389,590 x 0.85 = 6,281,152 tonnes for 2030. Against 9,502,487 tonnes in 2024, that is 32.3% and 33.9% less. The per capita figure rose from 179.20 kg in 2023 to 194.43 kg in 2024, up 8.5%; SPI’s Eurostat news piece notes a break in Spain’s plastic series in 2024, and SPI has not yet confirmed whether the total series is affected in the same way.

The two targets measure different things. The decree counts tonnes from 2010 and the PPWR counts kilograms per person from 2018. Spain’s population growth means the tonnage target is the harder of the two: tonnage rose 26.0% from 2018 to 2024 while kilograms per person rose 20.6%, by SPI’s calculation. MITECO’s clarifying note of 19 May 2026 says the decree now governs only the matters the regulation does not cover or does not contradict, with a successor decree in preparation (MITECO; SPI’s Spain note). SPI has not yet confirmed whether the successor will keep the 2010 tonnage target.

The decree also names the measures. Article 7 requires food shops of 400 m2 or more to give at least 20% of their sales area to products sold without primary packaging, including bulk and reusable containers, requires whole fresh fruit and vegetables to be offered loose with exceptions, and requires event promoters to replace single-use cups from 1 July 2023 (BOE, article 7). The Spain cost stack piece covers the fee and tax side of the decree; this piece does not repeat it.

Poland: the steepest climb from the lowest baseline

Poland’s path to 2030 starts from a 2018 figure that sits below the years around it. Exhibit 9 shows the series.

SPI calculation. The 2018 figure was 6.5% below 2017 and 2019 was 15.7% above 2018. In tonnes, Eurostat shows 5.85 million in 2017, 5.47 million in 2018 and 6.32 million in 2019. The 2030 level of 136.78 kg is lower than any Polish figure since 2015.

That shape is the case Article 43(8) was written for: a Member State could ask the Commission, by 31 December 2025, to use another base year if it showed a significant rise caused only by changes in reporting methods and not by consumption (Article 43, German text as reproduced). SPI has not yet confirmed what caused the 2018 dip in Poland’s series, or whether Poland made such a request.

Poland also has no national prevention target in its packaging law, to SPI’s knowledge. Its deposit system began on 1 October 2025, and the ministry reports about 5 billion containers returned on operator data for October 2025 to September 2026 (SPI’s Poland note). The government’s packaging bill, UC100 on the legislative list, is meant to implement the PPWR and adapt EPR; the ministry’s reply of 18 February 2026, signed by an undersecretary of state, sets out a reform model focused on EPR financing and recycling levels and gives no date for the bill (Ministry of Climate and Environment, reply to interpellation 14977). That reply does not mention Article 43. SPI’s Poland piece covers the deposit and EPR detail.

Where national measures land on a brand

Article 43(5) gives Member States a menu, and other PPWR articles add tools that count towards the same target. Exhibit 10 maps each lever to the part of a brand’s business it reaches.

Fees. EPR incentives are the most direct lever, because they price packaging by weight. SPI’s fee per tonne piece compares scheme rates; under Article 43(5) the per tonne rate itself becomes a prevention tool.

Reuse quotas. A state may set reuse targets above the EU ones only under Article 51. The Commission’s guidance lists cumulative conditions: the new targets must be necessary for the state to reach its waste reduction targets, must not distort the internal market and must be notified through the TRIS procedure; it adds that higher national prevention targets cannot justify raising the EU reuse targets (Commission Notice, section 27). SPI’s reuse targets piece covers the EU reuse levels.

Design rules. The Commission’s guidance says packaging minimisation requirements help Member States reach their packaging waste reduction targets in a harmonised manner (Commission Notice, section 10). The 2030 format bans and empty space limit therefore count towards Article 43 without any national law.