A short guide to EU Packaging and Packaging Waste Regulation (PPWR)

As Governments around the world focus on improving sustainability, legislation supporting this is now a bigger topic than ever before.

In the UK, we’ve seen the introduction of the Plastic Packaging Tax and UK Extended Producer Responsibility (EPR), and from this August the initial phase of the EU’s Packaging and Packaging Waste Regulations (PPWR) will come into force.

In this article, we’ll be exploring PPWR, what it is, its key features and how it will impact businesses and their packaging.

What is EU Packaging and Packaging Waste Regulation (PPWR)?

Packaging is everywhere, and so is packaging waste. The EU generates over 80 million tonnes of it every year, and that figure has been rising for decades.

In essence, the EU has passed a law saying that from August 2026, all packaging sold in Europe must be simpler, smaller, safer and easier to recycle. Plus, you must be able to prove it on paper!

The Packaging and Packaging Waste Regulation will be the biggest shake up of packaging laws in the European Union for over 30 years and it will have a broad impact on businesses putting packaging on to this market. If you sell, manufacture, import or distribute packed goods in the EU, PPWR will affect you!

The regulation will aim to:

• prevent unnecessary packaging and promote reuse, refill and recycling;
• harmonise national measures to avoid trade barriers and competition distortions;
• contribute to the circular economy and climate neutrality by 2050.

How PPWR differs from the old EU Packaging Directive

The PPWR replaced the historic EU Packaging and Packaging Waste Directive 94/62/EEC, known as PPWD, which was originally released in 1994.

The move from directive to regulation aims to ensure that there is greater alignment across EU member states. PPWR will act as a single rulebook versus the directive, which was applied and implemented differently within each EU member country. 

Who does PPWR apply to?

EU Packaging and Packaging Waste Regulation has a broad scope. It covers all packaging and packaging waste, no matter the material or origin. This will include industrial, retail and household packaging. Online marketplaces, fulfilment providers and importers are all going to be in scope. So, this can include EU and non-EU based business, if they’re putting packaging into the EU market.

Unlike UK EPR regulations, the EU PPWR does not make general exemptions for micro or small businesses. The only exceptions are set to be:

• Medical and hazardous product packaging – this type of packaging may be excluded from reuse or recyclability targets if safety legislation requires it.
• Export packaging – for products sold outside exclusively the EU, there may be exemptions from certain labelling and registration requirements.
• Reusable packaging – some exemptions for micro-enterprises and certain packaging formats, like cardboard transit boxes and dangerous goods packaging.

Download our Quick Guide to PPWR for a practical overview of the PPWR and its implications.

The 6 key requirements of PPWR

PPWR focuses on six key aspects that will specifically impact packaging design. These are:   

1. Packaging being fairer and safer – companies using non-recyclable or harmful materials must pay to clean them up. Plus, harmful substances will be banned from packaging.
2. Packaging being easier to recycle & reuse – by 2030, packaging must be graded for recyclability and designed to be recyclable, 40% of transit packaging needs to be reusable and certain single use packaging formats will be banned.
3. Packaging must contain more recycled content – PPWR is expected to set minimum post-consumer waste recycling for all plastic packaging by 2030.
4. Packaging being the right size - small, light packaging with no empty space will be a requirement by law.
5. Packaging being labelled, registered and documented – the new PPWR will mandate EU-wide labelling requirements for packaging, including traceability and digital labels. There will be new laws around greenwashing and eco-friendly packaging claims too. In addition, companies who make packaging will need to complete conformity assessments of packaging and keep records of packaging.
6. Packaging producers having extended responsibility– companies using and producing packaging must consider the full lifecycle of packaging when designing it, including specific rules around compostables and bio-based materials. Plus, they must bear the costs for collecting, processing and repurposing packaging waste.

Key dates and timelines of PPWR

PPWR is evolving. As the European Commission develops the regulatory framework, dates may change. Currently, the below milestones are expected…

Date	Milestone
February 2025	PPWR entered into force
August 2026	PPWR provisions begin to apply from 12 August 2026. The previous Packaging and Packaging Waste Directive is repealed and businesses in scope must meet new obligations, including reporting requirements where applicable. UK businesses placing packaging on the EU market will also need to comply.
August 2026 onwards	The European Commission is expected to adopt implementing acts that provide further detail on areas such as harmonised labelling requirements.
August 2028	Harmonised EU packaging waste sorting labels are expected to apply (subject to implementing act timelines).
2029	Deposit return systems (DRS) requirements apply. Member States must ensure systems meet PPWR requirements, with the 90% separate collection target applying from 1 January 2029 for certain single-use plastic and metal beverage containers.
2030	Key targets begin, including packaging designed for recyclability, recycled content requirements for certain plastic packaging, restrictions on certain single-use packaging formats, and reuse targets.
2035	Packaging recyclability requirements become stricter, with packaging required to be recycled at scale.
2040	Further increases to recycled content targets apply.

What businesses can do now to prepare

As PPWR comes into effect, businesses impacted by the regulation need to understand their obligations and take the necessary steps to meet the new requirements.

There are proactive steps you can start taking now.

• Audit current packaging – compare against the proposed regulations. Do you have any gaps or risks when it comes to recyclability, pack size or voids, recycled content and substances of concern?
• Engaging your packaging suppliers – speak to your packaging suppliers to gather data on your packaging use and materials, including recycled content. Quality packaging partners. 
• Investing time in packaging optimisation – packaging that’s lighter, the right size and easy to recycle will pay dividends, helping you combat producer fees and meet PPWR targets. Working with a supplier that can help you optimise your packaging designs will be time well spent.
• Registering your company on applicable producer registers – whether your company is based in an EU member state or importing into it, your business will need to register with local reporting schemes.
• Planning systems for digital labelling – are your IT systems fit for purpose ahead of digital requirements? Begin reviewing them now, so you have a plan to implement any new software in time for the deadline.
• Monitoring member state implementation – keeping track of how enforcement of PPWR will work in member states your business operates in will be key, as there could be differences in each country.

Your business should also consider assessing the impact of PPWR alongside related EU frameworks like the Digital Product Passport and Green Claims directive, as well as any other packaging legislation relevant in the countries you operate.

FAQs

Here are some common FAQs about PPWR…

Does the PPWR apply to businesses outside the EU? Yes, it can.  If you place packaging on the EU market you fall within scope, no matter where your business is headquartered. So, if you’re importing, manufacturing, distributing or using packaging in the EU, it is likely to apply to you.

Are small businesses exempt from PPWR? No, small businesses aren’t exempt from PPWR. The PPWR does not provide a general exemption for micro or small enterprises. There are some very limited exemptions for microenterprises in specific contexts (e.g. on-premises food service), but the core obligations apply to all.

What happens if I don't comply with PPWR? While the regulation does not prescribe EU-wide penalties, it does require all member states effective enforcement measures. Risks of non-compliance are likely to include fines, restricted access to markets and reputational damage.

Does it apply to B2B packaging? Yes, PPWR will apply to business-to-business (b2b) packaging, which differs from UK EPR. It’s worth noting that under PPWR, B2B packaging is subject to adjusted obligations compared to B2C packaging, particularly regarding reuse and digital labelling.  

What is the difference between the PPWR and the old EU Packaging Directive? The old directive set goals but left implementation to individual member states, creating inconsistency. The PPWR is a regulation. It is written in the EU and applies directly and uniformly across all 27 EU member states.

Can I still make green claims about my packaging?  You can, but any environmental claims in the EU market can only be made if the packaging properties exceed the applicable minimum requirements PPWR. Plus, any claims need to be explicitly clear on what exactly the claim refers to and be backed up by relevant packaging data or evidence. Vague "eco-friendly" or "sustainable" labels risk falling foul of both the PPWR and the separate Green Claims Directive.

Summary and support

In summary, the Packaging and Packaging Waste Regulation (PPWR) is going to change the landscape of how packaging is designed, used, recycled and disposed of in the EU.

The regulation has broad scope and will apply to B2B and B2C packaging, with minimal exemptions. Reviewing your packaging designs, usage and data will help your business manage the requirements of PPWR and minimise potential risks and costs.

For support with packaging optimisation, speak to the Macfarlane team today.