The EU Packaging and Packaging Waste Regulation is now applicable: What businesses need to know

The EU Packaging and Packaging Waste Regulation (the PPWR) became generally applicable on 12 August 2026. Although many requirements will be introduced in phases between 2028 and 2030 and beyond, a number of key obligations are already in force. For this reason, businesses placing packaged products on the EU market should no longer treat PPWR compliance as a future exercise.

The PPWR applies irrespective of where packaging or packaged products are manufactured and can affect manufacturers, importers, distributors, brand owners, and direct sellers, both within and outside the EU. It links packaging design and materials to conformity documentation, labeling, extended producer responsibility (EPR), and corrective action.

Businesses exporting to the EU that have not yet assessed their packaging portfolios, supply chains, and routes to market should do so as a priority. In particular, companies should ensure that they have sufficient technical and supplier information to support compliance, understand how responsibilities are allocated across the supply chain, and confirm that applicable EPR obligations are being addressed in relevant Member States.

Most importantly, packaging now needs to be treated as part of product compliance for goods entering the EU – not simply as a waste issue after sale.

From a national waste regime to an EU product framework

The previous Packaging and Packaging Waste Directive established common EU objectives but relied on implementation through national law, leaving differences in rules and practice between Member States. The PPWR is directly applicable and introduces more detailed sustainability, labeling, conformity, and supply chain requirements across the packaging life cycle.

The Regulation forms part of the EU’s broader product sustainability agenda and is intended to address the continued growth of packaging waste, reduce dependence on virgin materials, improve packaging recyclability and reuse, and reduce regulatory fragmentation within the internal market. As a result, packaging imported from third countries must now meet the same product requirements as packaging made in the EU before it is placed on the EU market.

A phased regime rather than a single deadline

The PPWR entered into force on 11 February 2025 and has applied generally since 12 August 2026, when it repealed the previous directive, subject to transitional provisions.

Although the framework is now operational, many substantive obligations will only become applicable from later dates and, in some cases, depend on the adoption of further delegated and implementing acts by the Commission. Because packaging redesign, validation, and procurement can require long lead times, the PPWR should be treated as an ongoing compliance program rather than a one-off exercise.

Where preparations are incomplete

Companies that have not yet completed their PPWR preparations should identify all packaging formats sold into the EU, including sales, grouped, transport, service, and e-commerce packaging, and trace how it moves through the EU supply chain.

Companies should also determine the relevant roles and responsibilities arising under each route to market; collect composition, specification, and test information from suppliers; and confirm what documentation and registrations are required. Where an EU importer or distributor is expected to perform obligations allocated to them under the PPWR, including importer checks or applicable EPR-related responsibilities, a non-EU manufacturer placing packaged goods on the EU market should obtain confirmation of the steps taken rather than assume that compliance has already been addressed.

Who is responsible: Roles across the supply chain

The PPWR allocates obligations according to the role performed in the supply chain. Depending on the sales model, responsibility may fall on manufacturers, importers, distributors, or producers responsible for EPR obligations in a particular Member State.

Businesses should carefully assess which entity is responsible for compliance, documentation, importer checks, and EPR obligations in each route to market. This analysis may differ depending on how products are supplied and which entities place packaging or packaged products on the EU market.

Restricted substances

The PPWR imposes restrictions on certain hazardous substances in packaging. Packaging must not contain more than 100 mg/kg of lead, cadmium, mercury, and hexavalent chromium combined (subject to applicable derogations).

In addition, food-contact packaging placed on the EU market from 12 August 2026 must comply with new PFAS concentration limits. These restrictions may be particularly relevant for grease-resistant and moisture-resistant paper packaging, and businesses should obtain appropriate supplier certifications, composition information, and, where necessary, testing data.

Conformity assessment and documentation

Before packaging is placed on the EU market, the manufacturer must carry out the applicable conformity assessment, prepare the technical documentation under Annex VII, and issue an EU Declaration of Conformity in the form set out in Annex VIII. Records must be kept for five years for single-use packaging and 10 years for reusable packaging, and manufacturer identification and contact details must be provided on the packaging or through a QR code or other data carrier.

Importers must verify the required steps have been fulfilled, provide their own details, and make the documentation available to authorities on request. Businesses should ensure that sufficient technical information is available throughout the supply chain to support the preparation and maintenance of conformity documentation.

The packaging/packaged product manufacturer remains legally responsible for the contents of the conformity assessment and for the EU Declaration of Conformity.

Extended producer responsibility

EPR remains largely a Member State-specific compliance obligation. Businesses should determine who qualifies as the producer in each Member State and confirm that applicable registration, reporting, and financing obligations are being met.

There is no single EU-wide EPR registration system, and national requirements continue to evolve. Businesses selling directly to end users in the EU should also consider whether authorized representative requirements apply in relevant Member States.

Recyclability, minimization, and reusable packaging

The PPWR already requires packaging to be recyclable, although harmonized design for recycling criteria and grades will apply from 2030 or later, depending on the timing of the relevant Commission acts. Stricter minimization requirements, recycled content targets, and many reuse obligations also apply at later dates.

Businesses should nevertheless collect packaging composition and design data now, because redesign, testing, and supplier qualification can take considerable time. Businesses using reusable packaging should also confirm that it meets the PPWR criteria and operates within an appropriate reuse system.

Transport and industrial packaging

Transport and bulk packaging, including pallets, crates, drums, canisters, and bulk bags, deserves particular attention in industrial supply chains. For EPR purposes, the producer of transport packaging must be determined by reference to the packaging when empty, the entities involved in supplying and filling it, the Member State(s) concerned, and any name or trademark borne on the packaging.

In addition, reuse targets applicable to certain transport and sales packaging are expected to apply from 1 January 2030. Although exemptions exist for some packaging categories, those exemptions generally relate only to reuse targets and do not displace other PPWR or EPR obligations.

Looking further ahead

From 2028 onwards, the next implementation phases will introduce additional requirements relating to harmonized labeling, recycled content, design for recycling, packaging minimization, reuse targets, and restrictions on certain packaging formats. Businesses should begin collecting packaging composition and design information now, as compliance may require redesign, testing, and supply chain adjustments.

Reflecting PPWR responsibilities in commercial contracts

Although contractual arrangements cannot alter the statutory allocation of responsibility under the PPWR, they remain an important mechanism for allocating risk and coordinating compliance activities.

Customer, supply, distribution, import, logistics, and packaging procurement agreements should address who provides composition data, test reports, technical documentation, and declarations; who performs importer or distributor checks and EPR-related obligations; who bears redesign, labeling, and waste management costs; and how authority requests, noncompliance, shipment delays, withdrawals, or recalls will be handled.

Existing agreements may predate the PPWR and should be reviewed rather than relying only on general compliance clauses.

The PPWR is no longer a future compliance issue. Businesses placing packaged products on the EU market should now ensure that packaging compliance is integrated into product compliance, supplier management, and market access processes.

Companies that have not yet completed their preparations should prioritize reviewing packaging formats, collecting technical and supplier information, determining supply-chain responsibilities, and assessing EPR obligations.

At the same time, businesses should prepare for the next phase of implementation, as additional recyclability, recycled content, reuse, and labeling requirements are expected to come into force over the coming years.

The regulatory framework will continue to evolve through delegated and implementing acts, guidance, FAQs, and national enforcement measures. Businesses should monitor these developments closely and update compliance programs, documentation, and contractual arrangements accordingly.