From 12 August 2026, the new EU Regulation on Packaging and Packaging Waste, the PPWR (Packaging and Packaging Waste Regulation), applies. The new rules aim to reduce the amount of packaging waste, improve the recyclability and reusability of packaging, and promote the circular economy.
The Regulation introduces significant changes compared to the current rules, as it does not only address the management of packaging waste, but also sets several requirements for packaging itself. The rules may affect the design, material composition, recycled content and labelling of packaging, as well as the assessment and documentation of compliance.
In this newsletter, we provide an overview of the most important PPWR requirements for businesses, the key changes and deadlines expected in the coming years, and the steps businesses should consider taking now to prepare for the new requirements.
As a general rule, the PPWR applies to all packaging and packaging waste, regardless of the material from which the packaging is made or the product it contains.
The rules may therefore affect a wide range of businesses. These include, among others, manufacturers of packaging and packaged products, importers, distributors and retailers, businesses selling own-brand products, e-commerce businesses, and certain logistics and fulfilment service providers.
When determining the obligations under the PPWR, it is therefore particularly important to identify the role of the business under the Regulation and to determine exactly what packaging it places on the market or uses for its products.
One of the key principles of the PPWR is that the weight and volume of packaging must be limited to the minimum necessary. Packaging must not be larger or heavier than necessary for its intended function, and unnecessarily large empty space must not be used.
One of the main objectives of the PPWR is to ensure that an increasing proportion of packaging is recyclable.
From 2030, recyclability requirements and performance grades will apply. This means that it will not be enough for the material of the packaging to be theoretically recyclable. It will also be necessary to consider whether the packaging can be collected, sorted and recycled within the existing waste management system.
Businesses should therefore already assess what materials their current packaging is made of, what components it contains and whether it is expected to comply with the requirements applicable from 2030.
For plastic packaging, the PPWR requires certain minimum amounts of post-consumer recycled plastic.
The requirements may differ depending on the type and intended use of the packaging, and the Regulation also provides for certain exemptions. A significant part of these requirements will apply from 2030. Businesses should therefore already assess whether their suppliers will be able to provide the necessary recycled-content materials.
This may affect procurement and product development processes in the future. Supplier discussions should therefore not be postponed until the requirements actually start to apply.
The PPWR also restricts the use of certain substances in packaging. These include, among others, lead, cadmium, mercury and certain compounds of hexavalent chromium.
The PFAS restriction for food contact packaging is particularly important. From 12 August 2026, food contact packaging containing PFAS at or above certain concentration levels may not be placed on the market.
Businesses should therefore check the material composition of such packaging and, where necessary, obtain appropriate supplier declarations, technical data sheets or test documentation.
Specific requirements also apply to empty space in e-commerce and transport packaging.
From 2030, the empty space ratio for grouped, transport and e-commerce packaging may generally not exceed 50%, subject to certain exemptions.
Businesses should therefore review their packaging processes already during the preparation phase, with particular attention to the sizing of cardboard boxes, the use of filling materials and the possible use of several types of transport packaging.
The PPWR introduces a harmonised EU packaging labelling system. Its aim is to make it clearer for consumers what material the packaging is made of and how it should be properly handled.
One of the key dates for the application of the harmonised labelling requirements is 12 August 2028.
The Regulation also regulates environmental claims relating to packaging. From 2030, stricter conditions will apply to claims such as „environmentally friendly”, „sustainable”, „100% recyclable” or „compostable”.
Businesses should therefore already review the environmental claims used on their products and packaging and check whether they can be properly substantiated.
One of the important new elements of the PPWR is that compliance with the packaging requirements must also be documented.
Before placing packaging on the market, the manufacturer must, in certain cases, carry out a conformity assessment, prepare the required technical documentation and, where compliance has been demonstrated, draw up an EU declaration of conformity.
The technical documentation and EU declaration of conformity must be kept for 5 years for single-use packaging and 10 years for reusable packaging.
This is an important difference compared to the EPR system. Under the PPWR, businesses will not only need to keep records of the amount of packaging placed on the market but may also need to demonstrate the technical and environmental compliance of the packaging.
The PPWR should not simply be viewed as a new EPR system. EPR mainly relates to extended producer responsibility, the financing of waste management, and the related record-keeping and reporting obligations.
The PPWR, in contrast, also sets requirements for the packaging itself, including its composition, design, recyclability and labelling. At the same time, the two systems are closely connected. Businesses should therefore consider aligning their data collection and related processes.
The PPWR also introduces registration and reporting obligations for producers. Member States must establish national registers in which producers covered by the Regulation are registered.
The registration process may require, among other things, information on the business, its brand names, tax identification number and compliance with EPR obligations.
For reporting purposes, it is particularly important for businesses to have properly structured packaging data already at this stage. This may include the type of packaging, its material, weight, material composition, recycled content, recyclability and the related compliance documentation.
| Date | Key change |
| 12 August 2026 | Start of the general application of the PPWR; among other things, PFAS restrictions for food contact packaging start to apply |
| 12 February 2027 | Deadline for Member States to apply their penalty systems |
| 12 August 2028 | One of the key dates for the application of harmonised EU packaging labelling |
| 1 January 2030 | Application of, among other things, recyclability, recycled content, packaging minimisation, empty space and certain reuse requirements |
It is important to note that the PPWR will not become fully applicable on a single date. Different requirements will apply from different dates. Businesses should therefore start preparing now, taking into account the requirements that will apply over the coming years.
For 2026, the main focus should be on assessment, data collection and preparation. As a first step, businesses should consider:
Preparation is not only the responsibility of teams dealing with EPR or environmental matters. The PPWR may also affect procurement, logistics, quality assurance, product development, marketing and EPR processes. Compliance may therefore require cooperation between several areas of the business.
Compared to the EPR system, the PPWR introduces a much broader packaging compliance framework. In the future, businesses will need to know not only how much packaging they place on the market, but also what packaging they use, what materials it is made of, whether it meets the applicable requirements, whether it is recyclable or reusable, and whether the documentation supporting compliance is available.
Some elements of the Regulation already apply in 2026, while further significant requirements will apply from 2028 and 2030. Businesses should therefore already assess whether they are affected and review the necessary data, documentation and internal processes.
Preparing for the PPWR is therefore not a one-off administrative task, but a multi-year compliance process. Businesses should start preparing for these requirements now.
Tax Advisor
The above summary is provided for information purposes only. We recommend that you consult our experts before making any decision based on this information.
