Last updated: 20th August 2026
PPWR’s purpose is to reduce packaging waste sent to landfill, ensure all packaging on the EU market is recyclable and reusable, and to harmonise packaging labelling across the EU.
The regulation introduces obligations around packaging design, recyclability, reuse, recycled content, labelling and producer responsibility.
EU Extended Producer Responsibility (EPR) enforces reporting and ‘polluter’ fees for a range of EU sustainability regulations, including PPWR. The purpose of this is to shift the financial responsibility of waste and disposal to the producer.
If packaging does not comply with PPWR, then it is at risk of being rejected entry into the EU.
PPWR Producer and Manufacturer Roles
The producer is the entity first placing packaging or packaged products onto the EU market. In the context of a B2B UK to EU transaction, this is usually the responsibility of the EU based importer.
The producer must be able to demonstrate compliance with PPWR, and is also responsible for reporting and financial obligations under EPR.
However, the producer will be reliant upon upstream suppliers to provide the required information. This includes a ‘declaration of conformity’ and ‘conformity assessment’ documentation, giving every stakeholder in the supply chain a responsibility to ensure packaging is compliant with PPWR.
The conformity assessment and declaration will usually be carried out by the manufacturer. If you are placing a packaged product on the EU market, this is the business entity that produced and packaged the product. To assess compliance, they must collaborate with their packaging supplier.
Still unsure of your role? We recommend reviewing pages 5–10 of the official EU PPWR guidance document: Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste.
Exemption
Micro-enterprises (companies with less than 10 employees) placing less than 1 tonne of packaging or packaged products onto the EU market per year are exempt from reuse and recyclability targets, as well as labelling requirements.
Key Dates and Obligations
- Declaration of conformity must be issued to demonstrate compliance with applicable PPWR obligations, evidenced via a conformity assessment and accompanying technical documentation – see Article 15. Please note, many of the delegated acts outlining conformity requirements are yet to be published.
- Introduction of PFAS limit in food-contact packaging, and heavy metals limit in all packaging (to be evidenced in conformity assessment) – see Article 5.
- Packaging must be labelled with a unique identifier, such as a batch or serial number – see Article 15.
- The producer’s business information must be made available on packaging, including their registered name/trademark, address and contact details (a digital carrier containing the data, such as a QR code, is permitted) – see Article 15.
- Under EPR, in each EU country that you sell into, you must register onto the national EPR register and appoint an authorised representative (for more information, see EPR webinar linked in further guidance) – see Articles 45-47.
- Certain packaging types must be compostable (e.g. tea bags, coffee pods, lightweight plastic food bags), and this must evidenced in conformity documentation – see Article 9.
- Packaging labelled and marketed as ‘reusable’ must adhere to design requirements, including a minimum number of reuse cycles, and this must be evidenced in conformity documentation – see Article 11. Subject to delegated act.
- Introduction of harmonised labelling across the EU market for packaging material composition, reusability and recycled-content. Design criteria is set to include pictograms, colour coding, and polymer codes for plastics – see Article 12. Subject to delegated act.
- Packaging recyclability must be graded against % made up of recyclable content, and must achieve an A (95%), B (80%) or C (70%) grade to comply with PPWR and be placed on the EU market. From 2038, grade C packaging can no longer be placed on the market – see Article 6 and Annex II, Table 3. This must be evidenced in conformity documentation. Subject to delegated act.
- Plastic packaging must contain a minimum % of recycled content, dependent upon the packaging type. This must evidenced in conformity documentation – see Article 7.
- Packaging weight, volume and composition must be the minimum required for protective function. Where this is not possible due to product protection or safety, it must be evidenced in conformity documentation – see Article 10. Subject to delegated act.
- Grouped, transport and e-commerce packaging is subject to a 50% empty-space ratio, in this context filler packaging is also considered empty space – see Article 24. Subject to delegated act.
- Various single-use packaging formats will be prohibited, listed in Annex V.
Further Guidance
Webinar Recording: EU Packaging Rules: PPWR Explained
(you will need to create a free account to access the recording)
Webinar Recording: EU Extended Producer Responsibility
Official EU Guidance Document for PPWR
UK Export Support: Ask the export support team a question
Recommended Service Provider: Global Trade Department (provide compliance support and EU authorised representative service)
This information is provided as general guidance only. Organisations should refer to the relevant legislative text to determine their full legal obligations.