Designing OTC Packaging for PPWR – and What Comes Next in North America

Recyclability is becoming a design requirement and a financial consideration.

For OTC brand owners, packaging sustainability is moving from a voluntary objective to a measurable business requirement.

The European Union’s Packaging and Packaging Waste Regulation, or PPWR, establishes requirements covering the entire packaging lifecycle. Its objectives include reducing packaging waste, minimizing unnecessary packaging and making packaging placed on the EU market recyclable under defined criteria.

At the same time, Extended Producer Responsibility programs are expanding across North America. Although requirements differ by jurisdiction, these programs generally place more responsibility for packaging waste on producers. Reporting requirements, material classifications and, in some cases, fee structures can create a financial incentive to use less material and select packaging that performs more effectively in established recycling systems.

As a recent Packaging Gateway article explains, recyclability is therefore becoming a larger financial risk for producers – not simply an environmental claim or corporate sustainability metric.

For OTC companies selling across multiple markets, the direction is becoming clear: packaging decisions made today can influence regulatory readiness, EPR costs and material flexibility in the years ahead.

What PPWR Means for OTC Packaging

PPWR should not be viewed only as a plastics regulation. It requires brand owners and packaging suppliers to consider the complete package and how its different components interact during collection, sorting and recycling.

For an OTC product, that package may include:

• A plastic, glass or metal primary container
• A pressure-sensitive, shrink-sleeve or expanded-content label
• A folding carton
• Printed instructions or inserts
• Tamper-evident components
• Adhesives, inks, coatings and barrier layers

A container may be technically recyclable on its own, but its decoration and secondary packaging can influence how effectively the complete package moves through the recycling process. Label material, adhesive behavior, sleeve density, ink coverage and the ability to separate components can all affect the outcome.

This is why design for recyclability must evaluate the complete packaging system – not just an individual label, bottle or carton.

OTC Performance Safeguard

Product protection, tamper evidence, regulatory information, dosage instructions, warnings, accessibility and consumer usability remain essential.

Using Less Material Without Losing Functionality

Packaging minimization is another important part of PPWR readiness. For OTC brands, reducing material does not necessarily mean eliminating important packaging components. It means identifying where materials can be reduced, consolidated or used more efficiently without affecting product quality or regulatory compliance.

Potential opportunities can include:

• Evaluating thinner label facestocks, liners or sleeve gauges
• Right-sizing folding cartons around the product and required contents
• Reducing unnecessary material layers
• Optimizing printed sheets and label webs to generate less converting waste
• Consolidating information into an expanded-content label where appropriate
• Using digital production and improved version control to reduce obsolete packaging
• Reviewing whether separate inserts or components can be integrated into another packaging format

Expanded-content labels can be particularly valuable for OTC products that require substantial Drug Facts, multilingual or instructional content. In the right application, an expanded-content format may consolidate information that would otherwise require a larger carton, separate leaflet or additional packaging component.

The best solution will depend on the product, regulatory copy, consumer-use requirements and recycling pathway. A lifecycle or packaging-system assessment should therefore precede any material-reduction claim.

How CCL Healthcare Can Help

CCL Healthcare approaches sustainable packaging as an engineering and collaboration process. Through its sustainable packaging audit capabilities, CCL Healthcare can evaluate existing product lines and identify potential improvements involving material selection, packaging construction, adhesives, print design and manufacturing efficiency.

1. Review the complete packaging system
   CCL Healthcare can work with the brand owner, primary-container supplier and material partners to examine how the label, container, carton and literature function together. The review can identify potential recycling incompatibilities, unnecessary material combinations and opportunities for component separation.

2. Design for the intended recycling stream
   A label solution should be selected in relation to the primary container and its likely recycling pathway.

• Wash-off adhesive technologies for suitable film and container applications
• Removable adhesives for certain paperboard applications
• Repulpable adhesive and paper combinations
• Label or sleeve materials designed to separate from the container
• Recycling-compatible material combinations
• Responsibly sourced paper and material options
• Reduced-gauge constructions

Important: No single construction is appropriate for every package or market. Proposed solutions should be tested using relevant design-for-recycling guidance and, where necessary, validated with recycling-system specialists.

3. Reducing material and converting waste
   CCL Healthcare can examine both the finished package and the manufacturing process. Opportunities may include optimizing label webs and printed sheets, reducing press setup waste, reviewing the number of colors or printing stations, selecting efficient constructions and evaluating whether digital production is appropriate for lower-volume or frequently changing SKUs.

4. Preserve OTC packaging performance
   Sustainability changes must not create new risks. Proposed materials and constructions should be evaluated for adhesion, resistance, tamper evidence, code readability, functionality, consumer use and application-line performance.

5. Support testing and documentation
   As PPWR and EPR requirements develop, brand owners will need stronger documentation supporting packaging composition, material weights and design decisions. CCL Healthcare can assist with specifications, comparisons, prototypes and test plans.

Preparing for North American Requirements

North America does not currently have one uniform packaging regulation equivalent to PPWR. Instead, requirements are developing through state and provincial EPR programs, recycled-content mandates, recyclability criteria and packaging-reduction initiatives.

This fragmented environment creates a different challenge. A package may encounter different reporting rules, fees or recyclability definitions depending on where it is sold. OTC brand owners can begin preparing by:

• Create an accurate packaging-material and weight baseline.
• Map SKUs to the markets where they are sold.
• Identify formats that may be difficult or costly to recycle.
• Prioritize high-volume packages for redesign.
• Establish internal design-for-recyclability guidelines.
• Test alternative constructions before regulations force a rapid conversion.
• Maintain records supporting material and environmental claims.

Packaging designed with European PPWR principles in mind may also give brands a useful foundation for responding to future North American requirements, although compliance must still be assessed for each jurisdiction.

Start With the Package – Not the Claim

The most effective sustainability strategy begins with a clear understanding of the package, the product and the recycling system.

For OTC brand owners, that means balancing recyclability and material reduction with product protection, regulatory communication, tamper evidence and consumer usability. It also means avoiding assumptions that a package is recyclable simply because one component carries a familiar material designation.

CCL Healthcare can help brands evaluate current packaging, identify practical improvements, develop new constructions and build a phased roadmap toward greater regulatory readiness.

The result is not just packaging that uses fewer resources. It is packaging designed more intentionally – with its manufacturing performance, consumer function and next life considered from the beginning.

Come Talk with CCL Healthcare at PACK EXPO – Booth W-26082

Discuss PPWR readiness, design for recyclability and material-reduction opportunities for your OTC packaging with our team.

PACK EXPO International 2026 | October 18–21, 2026 | McCormick Place, Chicago, IL | Booth W-26082

Bring a current package or project challenge – and let’s start the conversation.