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EHPM Calls for Pragmatic EU Packaging Waste Rules for Supplement Industry

The European Health Product Manufacturers (EHPM) advocates for a science-based, proportionate approach to the EU's Packaging and Packaging Waste Regulation (PPWR), citing unique challenges for food supplement packaging that could impact supply chain and cost structures if not addressed.

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Brussels, Belgium — 25 August 2026

The European Health Product Manufacturers (EHPM) has released a definitive position paper on the impending EU Packaging and Packaging Waste Regulation (PPWR), outlining critical considerations for the food supplement sector. While EHPM explicitly supports the regulation's overarching goals of waste reduction, circularity, and sustainable packaging, it stresses the imperative for a proportionate, science-based, and operationally viable implementation. The current draft, if enacted without sector-specific adjustments, threatens to impose significant commercial and technical burdens on manufacturers and brand owners.

The food supplement industry's packaging requirements are distinct, driven by product stability, consumer safety, and regulatory compliance, particularly concerning shelf-life, barrier protection against moisture and oxygen, and tamper-evidence. These specific needs mean that general packaging mandates, such as blanket bans on certain formats or aggressive recycled content targets, may conflict with fundamental product integrity and efficacy. EHPM's submission highlights the necessity for exemptions or tailored provisions that recognise these technical constraints, preventing unintended consequences like increased product spoilage or compromised safety.

Key concerns raised include the feasibility of achieving stringent recycled content targets for primary packaging materials that are in direct contact with sensitive ingredients, where food-grade recycled plastics are scarce or not yet technologically advanced. Furthermore, the push for widespread reusability and refill systems, while commendable, presents considerable logistical and hygiene challenges for products requiring precise dosing and sealed environments to maintain potency and prevent contamination. Brand owners anticipate substantial operational overhauls, impacting everything from manufacturing lines to distribution networks, should these requirements be universally applied without sector-specific impact assessments.

The EHPM advocates for a collaborative approach between regulators and industry to refine the PPWR's technical details. They argue that successful implementation hinges on a deep understanding of the supplement sector's supply chain realities, investment cycles, and existing quality assurance protocols. Without this, the regulation risks undermining product safety, increasing costs for consumers, and hindering innovation within a vital health sector.

What this means for United Kingdom

While the UK is no longer an EU member, the PPWR's influence on packaging material suppliers and cross-border trade is substantial. UK manufacturers supplying the EU market must comply with PPWR standards, demanding significant investment in packaging redesign and material sourcing aligned with EU rules, irrespective of domestic regulations. This could lead to a two-tier packaging strategy, increasing MOQs and procurement complexity. The UK's Plastic Packaging Tax (PPT) at £217.85 per tonne already incentivises recycled content; the PPWR's more prescriptive nature could push UK suppliers to prioritise EU-compliant materials, potentially impacting availability and cost for UK-only brands. Procurement leads must track EU developments closely to avoid future supply chain disruptions and ensure product marketability in key export territories.

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