Regulatory consulting in the packaging industry
It isn’t always immediately apparent what a specific packaging material, flowpacker or cartoner can actually deliver in terms of sustainability. And sometimes there is a lack of awareness and knowledge to manage these issues in depth. The PCC – or Packaging Competence Centre – was set in motion by Schubert and Berndt+Partner six months ago to provide clients with qualified answers and solutions. This interview with Michael Graf, Head of PCC at Gerhard Schubert GmbH, and Matthias Giebel, COO at Berndt+Partner Consultants GmbH, outlines the insight gained over the past six months.
Mr Giebel, Mr Graf, how has the PCC been received so far?
Michael Graf: We launched the PCC on 1 January 2025 after surveying 15 leading brand manufacturers from various industries on the regulatory impact of the EU’s Packaging and Packaging Waste Regulation (PPWR). Our market analysis confirmed that a very clear need for consulting exists, as well as for subsequent technical implementation. An ideal backdrop for getting the PCC off the ground. After the first six months, we are seeing that awareness of the PPWR specifics still varies greatly. And some companies mistakenly believe that the PPWR regulation is no longer an issue. We still have a lot of educational work to do to help manufacturers navigate the regulations and avoid very unpleasant surprises.
Matthias Giebel: Developments with the confectionery sector, with whom we have carried out our first cases, are especially exciting. One challenge that we are facing is that many clients would ideally like to take advantage of our consulting services free of charge – even though a PPWR check, line modifications or new purchases naturally generate costs. Our approach is that Berndt+Partner Consultants carry out PPWR impact checks – including inventories of existing packaging and materials used – and define the necessary actions, while Schubert designs, tests and implements the required technical changes to the lines. It is important to understand that we are two independent companies working in collaboration. We offer our services separately. We also work with the Berndt+Partner Creality agency that designs new, PPWR-compliant packaging.
What potential does the PCC offer clients in the medium term?
Michael Graf: At the PCC, we assess the entire packaging portfolio and evaluate possible solutions for PPWR compliance. The collaboration between Schubert and Berndt+Partner Consultants offers our clients an enormous advantage in sustainable production. Ultimately, we want to ensure that the products packaged by the participating companies are still marketable in 2030 and can be sold in the EU.
In your opinion, how well prepared are companies today for PPWR implementation?
Matthias Giebel: As indicated, while some are actively gearing up to the upcoming changes, others are relatively complacent. This has a lot to do with the specific circumstances individual sectors are facing. The confectionery industry has a lot of work to do because it has long relied on non-recyclable films for primary packaging. Oversized, sometimes decorative packaging – especially for gift products – is also part of the packaging mix of many manufacturers…
Michael Graf: …and even today, plastic multipacks are the norm in many sectors. The issue is that these examples clearly fall under the anticipated PPWR bans – no more plastic outer packaging, no oversized packaging and no packaging materials that cannot be recycled. There is a lot at stake for large companies, which is why many of them are already taking action and showing real commitment. We also see a lot of plastic in baked goods, for example in clamshell packaging for products such as muffins. The logical consequence and fundamental requirement of the PPWR is the use of more recycled material from 2030 onwards. However, because there is no current demand for this from consumers and recycled material is still relatively expensive, the PPWR isn’t exerting too much pressure for now – even though bakery manufacturers will also need to comply and should be taking action in good time. As the PPWR progresses, it will become clear where each industry stands. In all cases, the PCC will be providing the most current, relevant information and support.
From your perspective, what are the real strengths of Schubert and Berndt+Partner?
Matthias Giebel: The PCC provides an important interface to two players who are well established in the packaging world and who offer guidance. This creates confidence and trust. Here’s an example: A confectionery manufacturer is switching to paper multipacks with the PPWR in mind. To achieve this, the company needs to select the right paper and adapt its machines accordingly. As consultants, we show the company how to proceed. For example, we suggest suitable paper manufacturers and check with Schubert whether qualified materials are available on the market. Schubert then reviews the options in its material database and can make recommendations for initial trials.
Michael Graf: To this end, we created the ‘Comfort Pack’ – a collection of some 600 films, ranging from mono-PP film to grass fibre-based options. If the client is keen on maintaining their machine performance despite using new materials, we adapt the tools as necessary. Paper, for example, calls for different forming shoulders than composite films. The far-reaching experience we have gained over many years is the decisive advantage we can offer. Together with the client’s core technical data and industry guidelines, this paves the way for more sustainable packaging concepts.
How exactly?
Michael Graf: For instance, the PPWR also clearly specifies which coatings and labels are acceptable. Based on design-for-recycling guidelines, we can say what colours and materials are suitable. Schubert discussed the limitations of these solutions with suppliers and supports them in mastering the balancing act between guidelines and machine compatibility. If required, some clients may also have to change material suppliers.
It seems that there is no shortage of strategies. What do you believe needs to happen to achieve the ambitious PPWR targets by 2030?
Michael Graf: Recyclers and material manufacturers will have to adapt in the medium term to manage the increasing material flow. As of today, recycling capacities are far from sufficient. This gap is leading to food retailers here in Germany, for example, becoming more creative. Some players are relying on their own networks to return materials to the value stream. The first converters are also showing initiative, but don’t necessarily have the means to do so.
Matthias Giebel: True circular recycling is contingent on a comprehensive collection, sorting and recycling infrastructure. Because plastic manufacturers are currently investing too little in recycling, more and more food manufacturers are testing paper – quite simply because there is a functioning recycling infrastructure for it. In terms of risk management, we always advise our clients to test several materials – if only because different companies have different requirements. Fortunately, there is a great deal of innovation in the industry. Specifically, I’m referring to novel approaches to barrier papers, tamper evidence or glue-free cardboard box solutions. There are impressive developments in the pipeline that allow us to look to the future with optimism.
