The ‘E‘ of ESG: An overview of the new EU Packaging Regulation (PPWR)
As of 12 August 2026, a unified packaging law will apply in the European Union: The Packaging and Packaging Waste Regulation (PPWR). This marks a critical compliance moment for almost every company that makes, fills, imports, distributes or sells packaged goods in the Union.
This overview covers the PPWR’s scope, the roles it creates and its core obligations – from substance restrictions and recyclability to reuse, labelling and enforcement.
A single rulebook for packaging across the EU
The PPWR replaces the 1994 Packaging and Packaging Waste Directive (PPWD). From 12 August 2026 onwards, a single rulebook applies across the Union, thereby eliminating the fragmentation of 27 divergent national regimes. Compliant packaging will circulate freely throughout the internal market: Member States may not prohibit, restrict or impede the placing on the market of compliant packaging (Art 4).
The PPWR covers all packaging placed on the EU market, whatever the material, as well as all packaging waste, whether from industry, retail, services or households. This applies regardless of where the manufacturer is established (i.e., also non-EU manufacturers are in scope), but not to packaging manufactured in the EU purely for export outside the Union/EEA. The PPWR governs the entire life cycle – design, manufacture, labelling, use, collection, recycling and reuse. It complements the Ecodesign for Sustainable Products Regulation (ESPR) without duplicating it: the PPWR covers general sustainability rules for packaging, while the ESPR may add product-specific requirements.
Who is affected
The PPWR defines the role of every actor in the value chain. Every business must determine its role and identify the corresponding obligations.
The manufacturer (Art 3(1)(13)) is at the centre of the conformity framework. The manufacturer is not necessarily the company that physically produces the packaging, but the entity that has developed or made the packaging under its own name or trademark, or that determines its design specifications. Before any packaging reaches the market, the manufacturer must carry out a conformity assessment and draw up an EU declaration of conformity (Art 15). Suppliers must provide manufacturers with all the information needed to demonstrate compliance (Art 16).
The producer (Art 3(1)(15)) is a separate concept, used for extended producer responsibility (EPR). The producer is the entity that first makes packaging available on the territory of a given Member State (or unpacks packaged products without being an end user). The producer bears financial responsibility for waste management and must register in the EPR register of every Member State where it first makes packaging available (Arts 44–47).
Importers must verify that the manufacturer has carried out the required conformity assessment before third-country packaging is placed on the market (Art 18). Distributors must act with due care and check producer registration and labelling before making packaging available further (Art 19). Fulfilment service providers (warehouses, logistics and dispatch hubs) must ensure storage and handling do not compromise compliance (Art 20). Online platforms within the scope of the Digital Services Act must obtain the producer’s registration number and a self-certification of EPR compliance before allowing a seller to list products (Art 45(4)).
Any importer or distributor that places packaging on the market under its own name or trademark is treated as the manufacturer (Art 21). Where the brand owner is a micro-enterprise and the supplier is in the same Member State, the supplier becomes the manufacturer (Art 3(1)(13)(b)). All economic operators must identify their upstream and downstream packaging counterparties on request, for 5 years as regards single-use packaging or 10 years regarding reusable packaging (Art 22).
The key obligations are:
Substances of concern (Art 5): A general duty to minimise substances of concern applies from 12 August 2026; per- and polyfluoroalkyl substances (PFAS) in food-contact packaging are restricted from the same date onwards; the heavy-metals limit is carried over from the PPWD.
Recyclability (Art 6): A general recyclability requirement applies from 12 August 2026. Mandatory design-for-recycling criteria apply from 1 January 2030 or 24 months after the relevant delegated acts, whichever is later (those delegated acts are due by 1 January 2028). A “recycled-at-scale” test follows from 2035 at the earliest, measured against EU benchmarks of 55% (all materials) and 30% (wood), and the minimum acceptable grade rises to B from 2038.
Recycled content (Art 7): Plastic packaging must contain minimum post-consumer recycled content from 2030, at the earliest, with higher targets from 2040; plastic parts representing less than 5% of the total unit weight are exempt.
Minimisation and empty space (Arts 10, 24): Packaging must be minimised and grouped, transport and e-commerce packaging may not exceed 50% empty space (also from 1 January 2030, at the earliest).
Reuse and bans (Arts 29, 25): Binding reuse targets apply from 2030 for transport packaging, beverages and grouped packaging, and six categories of single-use formats are banned from 1 January 2030 (Annex V). For transport packaging, the target is 40% reusable overall, rising to 100% for intra-company, linked-enterprise and same-Member-State transports (with pallet wrappings and straps exempted from the 100% requirement by Commission Delegated Decision of 25 February 2026). The PPWR also amends the Single-Use Plastics Directive to introduce additional bans applicable from 12 February 2029 (Art 67(5)).
Compostability (Art 9): Tea and coffee bags and sticky fruit-and-vegetable labels must be industrially compostable by 12 February 2028.
Labelling (Art 12): Harmonised sorting labels and QR codes for reusable packaging phase in from 2028 and 2029 at the earliest respectively. Open-loop reuse systems without a system operator are exempt from the QR code requirement.
Identification and Traceability (Art 15(5)-(6), Art 18(3)): Manufacturers must ensure that packaging bears a type, batch, serial number or other identifying element. They must also indicate their name, registered trade name or trademark, and a single contact postal address directly on the packaging. Similarly, importers must provide their name, registered trade name or trademark and their contact postal address.
Conformity assessment and EU declaration of conformity (Arts. 15, 38, 39): From 12 August 2026, manufacturers must carry out a conformity assessment, compile technical documentation and draw up an EU declaration of conformity before placing packaging on the market.
HORECA (Arts 32–33): Take-away customers must be able to bring their own containers from 2027; reusable packaging must be offered from 2028.
In addition to setting out product rules, the PPWR establishes Member State targets for waste prevention, recycling and separate collection, provides for eco-modulation of EPR fees by recyclability performance, introduces minimum green public procurement requirements from 2030 at the earliest, and requires penalties to be in place by 12 February 2027.
Even though national enforcement regimes are still phasing in, public enforcement by market surveillance authorities and private enforcement by competitors or NGOs already pose risks from the PPWR’s application date.
What businesses should do now
The PPWR allocates obligations by role, and the same business can hold different roles for different product lines or in different Member States. In particular, large multi-jurisdictional groups face a structural challenge in determining PPWR roles in global supply chains. Features common to such groups can blur where a role, and its obligations, actually attach. Precise role-mapping at group level is therefore recommended, since it anchors every downstream obligation tied to that role.
A significant number of obligations apply immediately from 12 August 2026, with no transition period – though stock already placed on the market before that date can still be sold off (see recital 14), in particular:
All economic operators
Substance restrictions under Art 5 – minimising substances of concern, heavy metals and PFAS in food-contact packaging
General recyclability requirement under Art 6
Obligation to keep traceability records on suppliers and customers for 5 years (single-use) or 10 years (reusable) (Art 22)
Ongoing duty of importers, distributors and fulfilment service providers to ensure storage/transport/handling conditions do not compromise packaging compliance (Art 18(5), 19(3), 20)
Manufacturers
Conformity assessment and EU declaration of conformity before placing packaging on the market (Art 15, 38 and 39)
Identification and labelling duties – packaging must bear a type, batch or serial number, and the manufacturer's name, trademark and postal address (Art 15(5) and (6))
Procedures to ensure series production remains compliant (Art 15(4))
Importers and distributors
Importers must verify that the manufacturer has carried out the required conformity assessment before placing third-country packaging on the market (Art 18(2))
Importers must also indicate their own name, registered trade name or trademark and contact address on the packaging itself (or, where this is not possible, via a digital data carrier or an accompanying document) (Art 18(3))
Distributors must act with due care and check producer EPR registration and labelling according to Arts 12, 15(5)-(6), and 18(3) before making packaging available further (Art 19)
Producers (EPR)
Duty to register in the national EPR register of each Member State before first making packaging available there — while some registers already exist, registers are expected to be operational from around mid-2027 (Art 44)
Please note that the reusable-packaging criteria (Art 11) took effect on 11 February 2025, while the carrier-bag reduction target (Art 34) has applied since 31 December 2025. The remaining requirements – recycled content, minimisation, format bans, reuse targets, HORECA refill, harmonised labelling and deposit-and-return systems – will be introduced between 2027 and 2030, after the relevant delegated or implementing acts have been adopted.
The PPWR as an evolving framework
The PPWR is, for all its detail, still a framework. Much of its operative content will crystallise through delegated and implementing acts due between 2026 and 2030. While the Commission’s March 2026 Guidance Document and accompanying Frequently Asked Questions clarify several contested points, there is still room for further guidelines.
This blog post is the starting point of a series tracking the PPWR as it develops — picking up future significant delegated acts, implementing measures and potential further Commission guidance.
Please get in touch if you would like tailored guidance on how the PPWR affects your business.
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