EU Packaging and Packaging Waste Regulation (PPWR): What Businesses Must Do in 2026 and Beyond

Published: 3 November 2026
Category: Environmental Regulations | Circular Economy | Packaging Compliance

The European Union has entered a new phase of packaging regulation. Since 12 August 2026, the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has begun applying across the EU, introducing stricter requirements for packaging design, material composition, environmental performance and waste prevention.

For businesses, this is more than a recycling initiative. The PPWR changes how packaging is designed, purchased, documented and placed on the European market.

Manufacturers, importers, distributors, retailers and packaging suppliers must understand their responsibilities, particularly when products move through multiple countries or supply chains.

With further requirements approaching in 2028 and 2030, businesses need to distinguish between obligations already applicable and those requiring preparation.

Why Has the EU Introduced the PPWR?

Packaging is an essential part of modern commerce, but it also places considerable pressure on natural resources and waste management systems.

According to the European Commission, packaging accounts for approximately 40% of plastics used in the EU. Without additional measures, total packaging waste was projected to increase by 19% by 2030, with plastic packaging waste potentially increasing by 46%.

The PPWR addresses these challenges through a common EU regulatory framework designed to:

• Reduce unnecessary packaging and packaging waste.
• Improve packaging recyclability.
• Increase recycled content in plastic packaging.
• Encourage reusable and refillable packaging systems.
• Restrict harmful substances in packaging.
• Strengthen producer responsibility and traceability.

Unlike the previous Packaging and Packaging Waste Directive, the PPWR is an EU Regulation, meaning it is directly applicable in Member States. Nevertheless, national authorities continue to have important responsibilities for registration, waste management, enforcement and implementing certain provisions.

Key PPWR Compliance Dates

The regulation follows a phased implementation schedule.

DateRequirement or milestone11 February 2025PPWR entered into force.12 August 2026General application began, including restrictions on PFAS in food-contact packaging.2028Harmonised packaging labelling requirements begin, subject to the relevant legal timetable and implementing measures.1 January 2030Packaging minimisation requirements and restrictions on specified single-use packaging formats begin.2030Recyclability performance requirements and recycled-content obligations apply to relevant packaging.2035Additional recyclability-at-scale requirements take effect.2040Further recycled-content and reuse objectives apply.

Not every requirement applies to every business or packaging format. Specific obligations depend on the packaging material, intended use, economic operator and relevant legal provisions.

Seven Important PPWR Requirements for Businesses

1. Packaging Must Become More Recyclable

From 2030, packaging placed on the EU market will need to meet applicable recyclability requirements.

This means that selecting a material described as recyclable will not necessarily be sufficient.

Businesses will need to consider whether their packaging can be collected, sorted and recycled through appropriate processes, taking account of its design and components.

Packaging elements such as adhesives, coatings, labels and mixed materials may affect overall recyclability.

Business action: Review packaging specifications, material composition and supplier evidence to identify formats requiring redesign.

2. Plastic Packaging Must Contain Recycled Material

The PPWR establishes minimum recycled-content requirements for specified plastic packaging categories from 2030, with further targets for 2040.

Requirements vary by packaging type and application. Certain packaging categories may be subject to exceptions or special conditions.

Businesses should begin collecting reliable information on recycled plastic content from suppliers.

Business action: Request material specifications, recycled-content declarations and supporting evidence from packaging manufacturers.

3. Unnecessary Packaging Must Be Reduced

Excessive packaging is a central concern under the new regulation.

Under Article 24, the maximum empty-space ratio for relevant grouped, transport and e-commerce packaging will be 50%, from 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later.

Protective fillers such as bubble wrap, air cushions and loose-fill materials are generally counted as empty space for this calculation.

Separate packaging minimisation rules also apply.

Business action: Review carton dimensions, void fill, protective materials and packaging-to-product ratios, without compromising product safety.

4. Restrictions Apply to PFAS in Food-Contact Packaging

Since 12 August 2026, food-contact packaging exceeding the PPWR’s specified limits for per- and polyfluoroalkyl substances (PFAS) cannot be placed on the EU market.

PFAS have been used in certain packaging applications because of their resistance to grease, water and heat.

Affected packaging may include takeaway containers, wrappers and other food-contact materials.

Business action: Obtain chemical-composition evidence and appropriate compliance declarations from suppliers of food-contact packaging.

5. Packaging Labelling Will Become More Consistent

The PPWR introduces harmonised labelling requirements intended to make it easier for consumers to identify packaging materials and sort waste correctly.

The European Commission is developing additional implementing measures governing labelling formats.

Businesses using multiple packaging types should prepare their artwork, product information and labelling systems for future requirements.

Business action: Establish a central packaging specification register that links material data to packaging labels and product identifiers.

6. Reuse and Refill Will Become Increasingly Important

The regulation establishes reuse obligations for specified packaging categories and operators, with major requirements beginning in 2030.

Relevant packaging may include certain transport and grouped packaging formats.

Reusable packaging must meet applicable design requirements and operate within a suitable reuse system.

Not all businesses face identical reuse targets, and exemptions apply in specified circumstances.

Business action: Evaluate opportunities to replace single-use delivery materials with appropriately managed reusable packaging systems.

7. Extended Producer Responsibility Remains Critical

Extended Producer Responsibility (EPR) places responsibility on relevant producers for the environmental and waste-management costs associated with packaging.

The PPWR introduces a harmonised framework, but businesses must still assess their obligations in the individual EU Member States where packaged products are placed on the market.

A company selling into Germany, France and the Netherlands may therefore face different national registration and reporting arrangements.

Business action: Map the countries where packaging is supplied, establish the relevant producer for each market and verify national registration, reporting and compliance scheme requirements.

Who Is Responsible for PPWR Compliance?

EU PPWR introduces requirements for packaging recyclability, waste reduction, recycled content and sustainable packaging design.

Responsibilities depend on the role performed within the packaging supply chain.

Business roleMain compliance considerationsPackaging manufacturerPackaging design, applicable conformity assessment and technical documentation.ImporterVerification of relevant requirements before placing packaging on the EU market.DistributorApplicable checks and obligations when making packaging available.Brand ownerPackaging specifications and responsibilities arising from its actual legal role.Online retailerPackaging design, supply-chain responsibilities and possible EPR obligations.Logistics providerResponsibilities linked to packaging handled or supplied and its role within the supply chain.

A company can perform more than one role.

For example, a business importing packaged electrical equipment into Germany and subsequently distributing it across Europe may need to assess both importer obligations and national packaging producer responsibilities.

Importantly, the entity responsible for packaging conformity is not necessarily the same entity responsible for EPR reporting.

Are Micro-Enterprises Exempt?

The PPWR includes targeted exemptions and lighter requirements for certain micro-enterprises, but it does not provide a blanket exemption from packaging compliance.

A micro-enterprise cannot assume that all obligations disappear simply because it employs fewer than ten people.

The applicable treatment depends on the specific legal provision, the business role and, where relevant, national implementation arrangements.

Similarly, selling to a micro-enterprise does not automatically remove the supplier’s obligations.

Businesses should assess their own role and the relevant provision rather than relying solely on their customer’s size.

What Does the PPWR Mean for UK Businesses?

The PPWR is particularly relevant for UK businesses supplying packaging or packaged goods to the European Union.

Businesses operating exclusively in England, Scotland or Wales are not automatically subject to the PPWR merely because they operate in the UK.

However, packaging placed on the EU market must comply with applicable EU requirements, including when exported from Great Britain.

Northern Ireland has a distinct position under the Windsor Framework. Many PPWR product requirements apply there, but certain provisions, including the PPWR’s EPR and deposit-return obligations, do not apply under that framework.

UK businesses must therefore distinguish between Great Britain, Northern Ireland and EU Member State requirements.

The UK’s separate packaging EPR framework must also be considered where applicable.

Practical Example: A Manufacturer Supplying Equipment Across Europe

Consider a manufacturer supplying electrical and industrial equipment from the UK to customers in Germany, France and Spain.

Each delivery includes:

• A corrugated cardboard carton.
• Plastic protective wrapping.
• Foam corner protection.
• A wooden pallet.
• Plastic strapping.

Although these materials form part of one shipment, they may need to be assessed individually for material composition, recyclability, reuse and relevant reporting purposes.

A practical packaging record could include:

Packaging componentMaterialInformation requiredOuter cartonCardboardMaterial weight, specification and recyclability evidenceProtective wrapPlasticPolymer type, weight and relevant recycled-content informationCorner protectionFoamMaterial composition, weight and recyclabilityPalletWoodWeight, reusable status and applicable treatmentStrappingPlasticMaterial type, weight and reuse or recycling characteristics

The manufacturer would also need to identify which legal entity places the packaging on each market and determine applicable national EPR obligations.

This example illustrates why packaging compliance cannot be managed reliably through total shipment weight alone.

Building a PPWR Compliance Data Register

One of the most important practical steps is establishing a structured packaging dataset.

A useful register should capture:

1. Packaging component identifier and description.
2. Packaging material and material composition.
3. Packaging weight and relevant dimensions.
4. Supplier and supporting material specifications.
5. Recycled-content information where applicable.
6. Recyclability evidence and any restrictions.
7. Reusable or single-use status.
8. Countries where the packaging is placed on the market.
9. Responsible legal entity and applicable EPR arrangements.
10. Supporting declarations, assessments and compliance records.

Businesses can use this information to identify gaps, evaluate alternative packaging and prepare for future regulatory milestones.

The same underlying records may support wider sustainability reporting, although PPWR compliance, packaging EPR and greenhouse gas emissions accounting remain distinct requirements.

A Practical PPWR Compliance Checklist

Businesses can begin by completing the following actions.

• Map packaging flows: Identify products, packaging components, suppliers, countries and responsible entities.
• Review requirements: Determine which obligations currently apply and which become applicable later.
• Assess materials: Collect composition, weight, recycled-content and recyclability information.
• Verify suppliers: Request relevant declarations, specifications and technical evidence.
• Identify EPR obligations: Review registration and reporting duties for each applicable Member State.
• Plan packaging improvements: Prioritise excessive, difficult-to-recycle or problematic packaging.
• Maintain evidence: Keep records that demonstrate decisions, assessments and compliance actions.
• Monitor regulatory changes: Track EU implementing acts, guidance and national enforcement requirements.

Beyond Compliance: The Business Case for Better Packaging Data

PPWR compliance should not be treated solely as an administrative exercise.

Improved packaging information can support better purchasing decisions, reduce material use and identify opportunities to redesign transport packaging.

For organisations with complex supply chains, the ability to connect packaging information with supplier records, procurement activities and product movements can be especially valuable.

Reliable data also supports internal accountability and helps businesses respond more consistently to customer information requests.

However, claims of cost savings, emissions reductions or improved recyclability should be supported by appropriate evidence rather than assumed.

How Sustainzone Supports Packaging Sustainability

At Sustainzone, we recognise that effective packaging management depends on accurate information, clear responsibilities and measurable environmental performance.

Businesses preparing for PPWR requirements need to understand their packaging materials, supplier information, reporting boundaries and operational impacts.

A structured approach to packaging data can also complement wider environmental activities, including greenhouse gas accounting, supply-chain assessments and sustainability reporting.

The priority is to establish reliable information that can support both regulatory compliance decisions and long-term resource efficiency.

Conclusion

The EU Packaging and Packaging Waste Regulation marks a significant change in how packaging is regulated across Europe.

Since August 2026, businesses have been operating under a new legal framework, with further obligations approaching over the coming years.

Organisations that understand their packaging supply chains, establish reliable material records and prepare for future requirements will be better positioned to manage regulatory risk and adapt to Europe’s transition towards a circular economy.

The immediate priority is straightforward: identify the packaging placed on the market, establish who is responsible and retain the evidence needed to demonstrate compliance.

Frequently Asked Questions

When did the EU PPWR start applying?

The regulation generally began applying on 12 August 2026. Additional obligations are phased in through 2028, 2030 and later years.

Does the PPWR apply to UK businesses?

It is relevant where businesses place packaging or packaged goods on the EU market. Many product requirements also apply in Northern Ireland under the Windsor Framework. It does not automatically govern packaging placed solely on the Great Britain market.

Is the PPWR the same as Extended Producer Responsibility?

No. PPWR establishes a broader regulatory framework covering packaging design, materials, recyclability and waste prevention. EPR is one part of packaging regulation and concerns producer responsibilities for packaging waste management.

Are small businesses exempt from PPWR?

Not generally. Specific exemptions and simplified obligations apply in certain circumstances, but businesses must verify the provisions relevant to their activities.

Does all packaging need to be recyclable by 2030?

The regulation establishes recyclability requirements from 2030, with further requirements concerning recycling at scale from 2035. Specific provisions and exceptions must be considered.

Can businesses continue using plastic packaging?

Yes, where it meets applicable requirements. The PPWR does not impose a general prohibition on all plastic packaging.

Official References

1. Regulation (EU) 2025/40 — Full legal text
2. European Commission — PPWR Implementation Resources
3. European Commission — PPWR Frequently Asked Questions, August 2026
4. European Commission — New EU Packaging Rules Apply from August 2026
5. Northern Ireland DAERA — Packaging and Packaging Waste

Regulatory information reviewed as of 3 November 2026. Businesses should consult the applicable legal provisions and national authority guidance when determining their compliance obligations.