First published: September 2026
The Packaging and Packaging Waste Regulation (PPWR) is now one of the most important developments in packaging compliance for businesses supplying goods into the European Union.
It entered into force on 11 February 2025 and applies generally from 12 August 2026, replacing the previous Packaging and Packaging Waste Directive with a directly applicable Regulation across the EU.
For brands, manufacturers, importers and distributors, this matters because packaging compliance is no longer just about waste disposal obligations or local labelling rules. It now extends to packaging design, recyclability, recycled content, chemical compliance, technical documentation, reuse systems, and supply chain traceability.
This FAQ guide brings together the questions businesses are most likely to ask as they prepare for PPWR.
What is PPWR?
PPWR is the EU’s new legislative framework for packaging and packaging waste. It covers the full packaging life cycle, from product design and material composition through to reuse, collection, recycling and waste prevention. The European Commission states that the PPWR covers all packaging and packaging waste, regardless of material or origin, and sets requirements for the manufacturing, composition, and reusability or recoverability of packaging placed on the EU market.
In simple terms, PPWR is designed to reduce wasteful packaging, improve the quality and quantity of packaging recycling, increase the use of recycled materials and create more harmonised rules across Member States.
When does PPWR apply?
Does PPWR apply to all packaging?
When does PPWR apply?
PPWR entered into force on 11 February 2025 and applies generally from 12 August 2026.
Requirements such as Technical Documentation, Declaration of Conformity, administrative labelling, reusability, environmental claims and Substances of Concern (e.g. heavy metals and PFAS in food-contact packaging) are already applicable from 12 August 2026.
Many other sustainability and labelling requirements will be implemented via corresponding Implementing Acts at a staged timeline, such as: Recyclability, Packaging minimisation , Recycled plastic content, and prohibited packaging formats (all expected from Jan 1, 2030)
Who does PPWR apply to?
PPWR applies broadly across the packaging value chain. It is relevant to manufacturers, importers, distributors, producers under EPR schemes, authorised representatives, brand owners, and online marketplaces, depending on how packaging is placed on the EU market. PPWR applies to packaging used in industry, retail, distribution, services and households, which means it affects both B2B and B2C activities.
This has major implications for softlines and hardlines businesses. If you sell food, apparel, footwear, accessories, furniture, homeware, electrical goods, electronics, toys, DIY products or other packaged consumer goods into the EU, PPWR is likely to affect at least some of your packaging formats.
What packaging is regulated under PPWR?
PPWR covers all packaging and packaging waste, regardless of material or origin. This includes primary, grouped and transport packaging, along with packaging used in e-commerce and fulfilment chains.
For many businesses, that means PPWR is not limited to visible retail packaging. It may also affect mailers, polybags, cardboard outers, protective inserts, void fill, transit materials, accessory bags, hangers, and other packaging elements used to contain, protect, handle or deliver products.
What are the main PPWR requirements?
The European Commission has established a comprehensive set of objectives and legal requirements aimed at transforming packaging sustainability across the EU. Key priorities include ensuring that packaging is recyclable in an economically viable manner, increasing the use of recycled plastics, minimising packaging weight and volume, eliminating unnecessary packaging, and strengthening packaging waste prevention. The framework also introduces specific measures addressing single-use plastic packaging, reuse and refill systems, and the minimisation of substances of concern.
In practical terms, the PPWR introduces a range of obligations that will significantly impact economic operators. These include harmonised EU-wide labelling requirements, enhanced data and traceability obligations, recyclability performance standards, and design-for-recycling requirements. The Regulation also establishes minimum recycled content targets for certain plastic packaging, packaging minimisation requirements, Extended Producer Responsibility (EPR) obligations, waste prevention measures, and mandatory reuse and refill targets for specific packaging categories. In addition, conformity assessment procedures, technical documentation requirements, and the preparation of Declarations of Conformity form part of the Regulation’s core compliance framework.
Will all packaging need to be recyclable
Yes, PPWR aims to make all packaging on the EU market recyclable in an economically viable way by 2030. That makes recyclability one of the most important design and compliance concepts under PPWR.
In practice, businesses will need to look more carefully at packaging components, composite structures, labels, closures, coatings, inks, laminates and other features that affect collection, sorting and recycling. Packaging that was once considered commercially acceptable may now need to be reassessed through a design-for-recycling lens. Packaging recyclability assessment will be based on future Implementing Acts (expected to be published by Jan 2028 and establishing Design for Recycling (DfR) criteria). Compliance with these requirements must be demonstrated in the Technical Documentation, in accordance with Annex VII of the PPWR.
Does PPWR only regulate plastic packaging
No. PPWR applies to all packaging materials, not only plastic. However, plastic packaging receives particular attention in some areas, especially where PPWR seeks to increase the use of recycled plastics and set minimum recycled-content requirements for certain types of plastic packaging.
That means even companies with packaging portfolios dominated by paper, board, metal or glass should not assume PPWR is unrelated to them. Requirements on recyclability, minimisation, substances of concern, labelling, reuse and documentation may still apply.
What are the PPWR labelling requirements?
PPWR introduces harmonised EU labelling requirements intended to improve packaging communication and consistency across Member States. Stronger labelling obligations can support better sorting, better disposal information and, where relevant, clearer reuse instructions.
For brands, this means packaging artwork, packaging data, and claim approval processes may all need to be reviewed. Labelling decisions will need to align more closely with verified technical information rather than just local commercial preferences.
Are environmental claims affected under PPWR?
Yes. The broader direction of the PPWR and related guidance is that environmental claims must be accurate, clear, and properly substantiated. Where businesses want to claim recyclability, recycled content, or another packaging-related sustainability benefit, they should be prepared to provide evidence to support the statement. Additionally, environmental claims about packaging properties for which the Regulation sets legal requirements can be made only if they exceed the minimum applicable requirements under the Regulation. Claims shall also specify whether they relate to the packaging unit, part of the packaging unit or all packaging.
This is particularly important for B2B suppliers and brand owners making market-facing claims. If the data is weak or inconsistent across suppliers and markets, the claim itself may create risk. Particular attention should also be paid to the requirements governing environmental claims under the ECGT Directive (EU) 2024/825 on Empowering Consumers for the Green Transition
Does PPWR include rules on substances of concern?
Yes. PPWR aims to minimise substances of concern, including restrictions with specific thresholds for heavy metals and for PFAS in food-contact packaging (FCM). For businesses using coatings, inks, adhesives, barrier treatments or specialised materials, this means chemical due diligence should be built into packaging reviews, not treated as a separate issue.
To comply with PPWR, start your PFAS testing today for FCM or wider chemical testing through our smart chemical testing Chem-ST™.
What is the position on packaging minimisation and empty space?
Waste prevention sits at the heart of PPWR. It moves away from wasteful packaging and unnecessary empty space. It aims to minimise packaging quantities and packaging waste while reducing the use of primary raw materials.
This is especially significant for e-commerce, premium packaging, and fragile goods packaging. Businesses may need to justify pack dimensions, protective layers and grouped-pack formats more carefully than before.
What documents will businesses need for PPWR?
This includes technical documentation, Declarations of Conformity, language requirements, stock questions, and enforcement readiness. The same themes appear in role-based guidance, where conformity assessment, technical files and document retention are central to compliance.
If you cannot support your packaging decisions with reliable evidence, supplier information, and traceability, your business may face non-compliance risks. PPWR is not only about having the right packaging. It is also about being able to prove it, and testing is a strategy that can provide the evidence that is required.
Will enforcement be immediate?
In the early stage, enforcement will take a corrective approach rather than assuming instant blanket product bans in every case. However, that should not be mistaken for a grace period: where non-compliances identified by the authorities persist and are not rectified by the economic operator (within a given reasonable timeline), Member States will then be within their rights to take further action. Businesses will still be expected to prepare properly, complete their documentation and understand which economic operator holds which obligation.
What should brands and manufacturers do now?
As a starting point, our experts recommend mapping all packaging formats across your portfolio and identifying which ones are likely to face the greatest challenge under PPWR. Mixed materials, problematic labelling, large empty space, unsupported claims, weak supplier declarations and an appreciation of substances of concern should all be flagged early. Brands and manufacturers should fully understand their obligations and the requirements that apply to them, as well as the different implementation deadlines, to ensure timely compliance and be adequately prepared well in advance.
It is also worth reviewing who within the organisation owns packaging compliance. In many organisations, packaging data sits in different systems across sourcing, design, sustainability, quality and logistics. PPWR makes that fragmentation harder to manage.
Contact us if you have any questions or testing needs about PPWR.
How can testing and compliance services help?
Testing and compliance services help with PPWR compliance by turning broad legal obligations into verifiable evidence, documented processes, and audit-ready records. Because the PPWR applies to all packaging placed on the EU market and covers the full packaging lifecycle, businesses need proof that each packaging type meets the relevant technical and sustainability requirements.
