What is the PPWR and who does it apply to?
The Packaging and Packaging Waste Regulation (PPWR) sets common rules for all packaging and packaging waste placed on the EU market, from design and materials to labelling, reuse and end-of-life management. It entered into force on 11 February 2025, and its first obligations have applied since 12 August 2026.
Why did the EU adopt the PPWR?
Packaging is one of the largest uses of raw materials in the EU. According to the regulation’s recitals, 40% of plastics and 50% of paper used in the EU go into packaging, and packaging accounts for 36% of municipal solid waste. The PPWR aims to reduce packaging’s impact on the environment and health, and to support the EU’s transition to a circular economy and climate neutrality by 2050.
What does the PPWR replace?
The PPWR replaces Directive 94/62/EC, the Packaging and Packaging Waste Directive. As a directive, it had to be transposed into national law, which led to differing packaging rules across Member States. As a regulation, the PPWR applies directly and identically in every Member State, without transposition. This harmonisation is intended to remove trade barriers and distortions of competition within the EU’s internal market.
Member States may keep or introduce extra national sustainability or information requirements, but these must not conflict with the PPWR and cannot be used to block packaging that complies with regulation.
Who does the PPWR apply to?
The PPWR applies to all packaging types, whatever its material, and to all packaging waste, whether it comes from industry, retail, offices or households. It applies to all packaging placed on the EU market, wherever the business supplying it is based, including UK exporters.
There are minor exemptions, some packaging is exempt from specific requirements, such as certain medical supplies which are exempt from some recyclability requirements.
The regulation assigns responsibilities to two key roles:
- The manufacturer ensures that packaging complies with the PPWR’s design, safety and labelling requirements, and proves it in the technical documentation. There is one manufacturer per packaging across the EU, usually the brand owner.
- The producer is responsible for extended producer responsibility (EPR): registration, reporting and fees. The producer is identified separately in each Member State, as the business that first supplies the packaging there.
What counts as packaging under the PPWR?
But what does the PPWR actually class as ‘packaging’? Under the PPWR, packaging is defined as:
‘an item, irrespective of the materials from which it is made, that is intended to be used by an economic operator for the containment, protection, handling, delivery or presentation of products to another economic operator or to an end user, and that can be differentiated by packaging format based on its function, material and design’ Article 3(1), point (1)’
Put simply, if the item is not an integral part of the final product, but is used to sell or transport it, it is packaging. If it is an integral part of the final product being sold, it is not in scope as packaging. In the example of a fashion brand, a coat hanger that comes with an item of clothing is classed as packaging, as the final product (the clothing) is not contingent on its presence. A coat hanger sold separately however, is not, it is itself the final product.
The regulation distinguishes four functional categories (sales, grouped, transport and e-commerce packaging), and also defines specific types such as service packaging (including take-away packaging) and primary production packaging.
Who bears what responsibilities under the PPWR?
Under the PPWR, most obligations on packaging design and conformity are placed on the manufacturer, with EPR assigned to the packaging’s producer. In a market of increasingly complex supply chains, how is it decided who actually bears these responsibilities?
The manufacturer and the producer of packaging are two separate concepts with different legal purposes. Although possible, these roles don’t necessarily fall on the same company.
The manufacturer is responsible for the packaging’s conformity with the PPWR, and the producer assumes responsibilities for the products end-of life through Extended Producer Responsibility.
For each supply chain, there is only one responsible manufacturer within the EU, and one responsible producer per packaging in each Member State.
Manufacturers
Under the PPWR, the manufacturer is either the company that manufactures packaging or a packaged product, or the company that has packaging or a packaged product designed or manufactured under its own name or trademark, and places it on the market. In practice, this means the brand owner is usually the manufacturer, even when production is outsourced.
Alternatively, an importer or distributor that places packaging on the market under its own name or trademark is considered the manufacturer, and therefore takes on the manufacturer’s obligations under Article 15. The same applies where an importer or distributor modifies packaging already placed on the EU market in a way that could affect its compliance with the regulation.
There is an exception: if the brand owner is a micro-enterprise and its packaging supplier is established in the same Member State, the supplier is considered the manufacturer instead, and assumes the necessary responsibilities.
Manufacturer responsibilities under the PPWR
Under the PPWR, the manufacturer is responsible for ensuring that the packaging itself complies with the regulation before it reaches the market.
A manufacturer must:
- Ensure the packaging meets the phased sustainability and labelling requirements
- Prove conformity before placing packaging on the market through technical documentation, and must draw up the EU declaration of conformity
- Keep compliance up to date and traceable, retaining their technical documentation and EU declaration of conformity for 5 or 10 years, for single use and reusable packaging respectively.
- Cooperate with the relevant authorities when prompted
Producers
The producer is the economic operator (manufacturer, importer or distributor) that makes packaging or packaged product available for the first time in a given Member State.
Unlike the manufacturer, whose role is defined at EU level, the producer is identified country by country. In most cases, it is the first business established in that Member State to supply the packaging there. The producer is responsible for extended producer responsibility (EPR): registering in the national producer register, reporting packaging volumes and paying EPR fees.
There is only one producer per packaging in each Member State. In practice, a pack sold in five EU countries can have up to five different producers, each registering and paying EPR fees in its own market, and the same company can be the producer in several countries if it is the first to supply the packaging in each.
Non-EU companies that sell to the EU are not automatically producers. A UK business selling to an EU importer or distributor is not the producer; the EU-established business that first supplies the packaging in that country is.
However, a non-EU company that sells directly to end users in a Member State, for example through its own e-commerce site, is the producer there, and must register and appoint an authorised representative for EPR in that country.
What is Extended Producer Responsibility? A closer look
Extended producer responsibility (EPR) is the principle that the businesses putting packaging into circulation should bear the cost and organisation of managing it once it becomes waste.
Instead of local authorities and taxpayers funding the collection, sorting and recycling of packaging, the businesses that supply it pay for it. Their fees are proportionate to how much packaging they supply, and increasingly, to how recyclable it is.
EPR is not new to the PPWR. It was established as a general EU waste policy tool by the Waste Framework Directive (2008/98/EC), and most Member States have run packaging EPR schemes for years. Until now, each country designed its own scheme, with its own rules on who pays, for what and how much, the PPWR harmonises the framework across the EU.
What are a producer's EPR obligations?
- Register. Producers must register in each Member State where they first make packaging available, and cannot sell packaging there until they, or their authorised representative for EPR, are registered.
- Report. Producers must report their packaging data annually, by 1 June for the previous calendar year. In practice this means volumes by material and packaging type.
- Pay fees. The fees fund collection, sorting and recycling of packaging waste.
It is important to note that the harmonised PPWR registers have not yet been created: Member States have 18 months to set them up once the Commission adopts the implementing act on the registration format, which is still pending. In the meantime, producers register in each country’s existing national EPR system. The annual reporting requirements will also come into effect after this deadline.
The PPWR will make design-based fee modulation harmonised and mandatory across the EU: once the Commission’s design-for-recycling rules are in place, EPR fees across the EU must be modulated according to each package’s recyclability grade, and Member States may also adjust them according to its recycled content.
Eco-design is therefore a direct lever on EPR costs: packaging that achieves a better recyclability grade, and uses less material, will cost less in fees than less recyclable or heavier alternatives
The PPWR timeline: fixed dates and “whichever is later” deadlines
There is not a singular PPWR compliance deadline. Instead, the PPWR has a phased rollout for its obligations, starting on 12 August 2026 when it first became applicable, and running to 2040. Most of the obligations that will reshape packaging portfolios arrive in 2030, and many of the upcoming compliance dates are not fixed, but rather depends on the speed of the European Commission’s decision making.
How the “whichever is later” rule works
Although the PPWR sets out the obligations for packaging and packaging waste, the technical detail of putting these into place is left to the European Commission.
Concrete rulings on requirements for label designs, recycled content calculation methods and recyclability criteria are among the subjects covered by the PPWR on which the Commission must adopt implementing acts.
To give companies ample time to prepare for these obligations, many have two triggers: a calendar date, and a period after the relevant Commission act is adopted. Whichever comes later applies.
The PPWR compliance timeline
The core sustainability requirements
Recyclability and design for recycling
From 2030 at the earliest, all packaging must be recyclable. The manufacturer gives each packaging unit a recyclability grade: A (at least 95% recyclable by weight), B (at least 80%) or C (at least 70%). Packaging below grade C can no longer be sold, and from 2038 only grades A and B are allowed.
Recycled content in plastic packaging
From 2030 at the earliest, plastic packaging must contain a minimum share of recycled plastic. This share ranges from 10% to 35% depending on the type of packaging, and rises to between 25% and 65% in 2040. The share is calculated as an annual average per manufacturing plant, not for each individual package.
Some packaging is exempt, including packaging for medicines, medical devices and infant food, as well as plastic parts that make up less than 5% of a packaging unit’s weight. The European Commission is due to publish the calculation method by the end of 2026.
Minimisation and empty space
From 2030, packaging must be as light and small as its function allows. Companies must be able to prove this in their technical documentation, by explaining why the packaging cannot be made lighter or smaller.
Do PPWR obligations apply to packaging already in stock
The Commission confirms that the PPWR applies to packaging when it is placed on the EU market, not when it was manufactured. Packaging placed on the market before 12 August 2026 can remain on sale, even if it does not meet the new rules. Packaging placed on the market after that date must comply, even if it was made earlier.
Reuse, refill and restricted formats
From 2030, businesses must switch part of their packaging to reusable formats managed within a re-use system:
- Transport packaging: at least 40% must be reusable.
- Internal and domestic B2B flows: 100% of transport packaging must be reusable when it is used between a company’s own sites, with linked or partner companies, or to deliver to other businesses in the same country.
- Grouped packaging: at least 10% of grouped boxes must be reusable.
- Beverages: at least 10% must be offered in reusable packaging.
Cardboard boxes are exempt from the transport and grouped packaging targets. Dangerous goods packaging and flexible food-contact packaging are also exempt from the transport targets, and micro-enterprises handling small volumes are exempt from all the reuse targets.
The 100% rule for internal and domestic B2B flows is one of the most demanding obligations in the regulation. Switching to cardboard to avoid it may seem simpler, but it is not always the lower-carbon option, so a life-cycle assessment is the best way to compare the two.
Take-away outlets must accept customers’ own containers from February 2027 and offer a reusable option from February 2028. From 2030, six single-use formats will be banned (Annex V):
- plastic multipack wrapping;
- plastic packaging for fresh fruit and vegetables under 1.5 kg;
- single-use packaging for food and drinks consumed on site in hospitality;
- single-use plastic sauce and condiment portions;
- hotel toiletry miniatures;
- very lightweight plastic carrier bags.
The Commission will publish guidelines by February 2027 detailing exactly which formats and exemptions are covered.
Strategic CSR challenges: why the PPWR is a carbon, cost and reputation issue
EPR fees will become a design KPI
Under the PPWR, EPR fees will be adjusted according to each package’s recyclability grade, and in some countries according to its recycled content. Better-designed packaging will cost less in fees than less recyclable alternatives. Eco-design therefore becomes a recurring cost lever, not just a compliance task. A life-cycle assessment (LCA) helps companies choose the designs that improve their grade without increasing their carbon footprint.
Supplier data is the new bottleneck
To prove compliance, manufacturers need detailed data on materials, substances and recycled content. Suppliers required to provide this information, but collecting it across a complex supply chain takes time. Companies that start early avoid delays in their technical documentation, and the risk of selling non-compliant packaging.
Penalties and reputational risk
Each Member State must set penalties for breaches of the PPWR by 12 February 2027, including administrative fines for breaches of the empty space, banned formats and reuse rules.
Environmental claims are also more tightly controlled. Under Article 14 of the PPWR, a claim about a packaging property is only allowed if the packaging goes beyond the legal minimum, and it must state whether it applies to the packaging unit, part of it, or all of the company’s packaging.
Since 27 September 2026, the Empowering Consumers Directive (EmpCo) has added a second layer to be transposed into national law: generic claims such as “eco-friendly” are banned without proof, and a claim about the whole product cannot be based on its packaging alone. The two sets of rules apply together, so every claim on packaging must meet both. With no grace period for existing stock, companies should review their packaging claims now.
Some packaging changes that seem greener can increase a company’s carbon footprint, such as switching to a lighter but less recyclable material, or choosing reusable packaging that has to travel long distances. The PPWR itself warns against simply shifting to lighter materials, and the Commission’s review of the reuse targets will be based on life-cycle assessment. For CSR leaders, the lesson is clear: LCA, not intuition, should decide between packaging options, so that choices are both compliant and genuinely lower-carbon.
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Your next steps in PPWR compliance
Operating in the EU? Start building your PPWR compliance roadmap today.
Sami is proud to be part of the SGS Group. Wherever you operate, we can help you meet PPWR requirements and strengthen the sustainability and credibility of your packaging for EU market access:
- In France: work with Sami’s expert in-house consulting team.
- Elsewhere in the EU and worldwide: draw on SGS’s global network of industry experts and solutions.
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FAQ
When does the PPWR apply?
The PPWR has applied since 12 August 2026, but its obligations are phased in until 2040. The first requirements cover PFAS and heavy metal limits, technical documentation and EPR. Most design requirements, such as recyclability grades and recycled content targets, apply from 2030. Many of these dates follow a “whichever is later” rule: they apply on a fixed date or a set period after the Commission adopts the relevant technical rules, whichever comes later.
Does the PPWR apply to UK companies?
Yes. The PPWR applies to all packaging placed on the EU market, including packaging from UK companies. A UK business selling to an EU importer or distributor relies on that business to handle EPR in its country. However, a UK company selling directly to end users in an EU Member State, for example through its own website, is the producer there. It must register for EPR in that country and appoint an authorised representative.
What are the PPWR recycled content targets for plastic packaging?
From 2030 at the earliest, plastic packaging must contain a minimum share of recycled plastic, rising in 2040:
- Contact-sensitive PET packaging: 30% in 2030, 50% in 2040
- Other contact-sensitive plastic packaging: 10% in 2030, 25% in 2040
- Single-use plastic beverage bottles: 30% in 2030, 65% in 2040
- Other plastic packaging: 35% in 2030, 65% in 2040
The targets are calculated as an annual average per manufacturing plant, not per individual package.
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