EU PPWR:
What it is, who it affects, and what to do - by 12 August 2026

A guide to the new EU Packaging and Packaging Waste Regulation - for businesses inside and outside the EU.

The EU has replaced its 30-year-old packaging directive with a new regulation that applies from 12 August 2026. Unlike the old directive, this one applies uniformly across all 27 EU Member States – and it captures every business placing packaging on the EU market, regardless of whether you’re based in the EU or sell into it from outside.

This article sets out what the regulation requires, who it affects, and what businesses should be doing now.

What is PPWR?

The Packaging and Packaging Waste Regulation (PPWR) replaces the 1994 Packaging Waste Directive and covers every aspect of packaging across its lifecycle: design, materials, recyclability, recycled content, reuse, labelling, extended producer responsibility (EPR) fees, chemical safety and waste reduction.

It entered into force on 11 February 2025 and applies from 12 August 2026, with further obligations phased in through to 2040.

Because PPWR is a regulation rather than a directive, it doesn’t need to be transposed into national law – it applies directly across all 27 Member States from the application date. Some provisions allow Member States to introduce additional rules, but the core obligations are uniform.

Who does PPWR affect?

PPWR applies to every business placing packaging on the EU market. This includes:

Manufacturers, importers, distributors and retailers established in the EU
Non-EU businesses (including UK companies) exporting packaged goods into the EU
Online marketplaces and fulfilment service providers that handle EU sales
All packaging types: sales packaging (primary), grouped packaging (secondary), transport packaging (tertiary) and service packaging filled at the point of sale

Unlike the previous rules, there is no general size or volume threshold for being in scope. Specific obligations include carve-outs (for example, micro-enterprises placing fewer than 1,000 kg of packaging per year are exempt from some reuse targets), but the regulation applies to small and large businesses alike.

Key requirements and timeline

PPWR is phased. The dates below are taken directly from the regulation; some are conditional on the European Commission adopting accompanying implementing or delegated acts.

From 12 August 2026:

PPWR applies to all packaging placed on the EU market.
Per- and polyFluorinated Alkyl Substances (PFAS) banned in food-contact packaging above the limits set in Article 5: 25 ppb for any single PFAS (targeted analysis); 250 ppb for sum of targeted PFAS; 50 ppm for PFASs including polymeric.
Heavy metal limits maintained: lead, cadmium, mercury and hexavalent chromium combined must remain below 100 mg/kg.
Each packaging type placed on the market must have an EU Declaration of Conformity.
Producers must register with the EPR scheme in each EU country where they place packaging on the market.

From February 2027:

Food and beverage takeaway operators (HORECA sector) must offer customers the option to bring their own container (Article 32).

From February 2028:

HORECA operators must give customers the option to obtain takeaway products in reusable packaging (Article 33).

From August 2028:

Harmonised pictogram-based labels on packaging, showing material composition to help consumers sort waste (Article 12). Conditional on Commission implementing acts.

From February 2029:

Reusable packaging must carry a label and a digital data carrier (e.g. QR code) providing reuse information.

From 1 January 2030:

All packaging placed on the EU market must be recyclable within Grade A, B or C. Exemptions apply for medicines, medical devices, infant food, dangerous goods. (Article 6).
Minimum recycled content requirements apply to plastic packaging: 30% for single-use PET beverage bottles, 30% for contact-sensitive PET, 10% for contact-sensitive non-PET plastics, 35% for other plastic packaging (Article 7).
Maximum empty space in transport, grouped and e-commerce packaging is capped at 50% (Article 24).
Specific single-use packaging formats banned (Article 25, Annex V).
Binding reuse targets: 40% of transport packaging must be reusable; 10% of beverage packaging at final-distributor level must be reusable (Article 29).

From 2038 and 2040:

Grade C packaging banned from 2038 – all packaging must be Grade A or B.
Higher recycled content targets apply to plastic packaging from 2040 (Article 7(2)).
Member State packaging waste reduction targets: 15% per capita by 2040 versus 2018 baseline (Article 43).

What about non-EU businesses?

PPWR applies to any non-EU business that places packaged goods on the EU market. It applies in addition to any equivalent producer responsibility regime in the company’s home country — for example the UK’s Packaging Extended Producer Responsibility (pEPR) regulations. Compliance with a domestic pEPR scheme does not satisfy PPWR; the two operate independently.

Non-EU producers should be aware of three things specific to PPWR:

Country-by-country registration. Each EU country has its own EPR scheme run by a Producer Responsibility Organisation (PRO) (LUCID in Germany, Citeo in France, CONAI in Italy, Ecoembes in Spain, and so on). Non-EU producers must register separately in each EU country they sell into.
Authorised Representatives. Article 45(3) allows EU Member States to require non-EU producers to appoint an authorised representative in each country where they sell. Rules vary per Member State – confirm before assuming.
PPWR-specific requirements. A domestic EPR registration is not enough on its own. PPWR adds its own requirements including the EU Declaration of Conformity, the A/B/C recyclability grading system, mandatory recycled content thresholds, harmonised EU labelling and chemical restrictions (PFAS, heavy metals). Non-EU producers need to assess every packaging type they place on the EU market against PPWR’s requirements directly.

When is a non-EU company the producer?

Whether a non-EU business carries PPWR producer obligations directly, or whether they shift to an EU counterparty, depends on the commercial structure of the sale. Article 3(1)(15) defines the producer; Recitals 122 and 123 explain the policy intent. In summary:

EU distributor or retailer buys from a non-EU company and resells in the EU → the EU entity is the producer. They take ownership and are the first to make the packaged product available in the EU.
EU customer (business or consumer) buys directly from a non-EU company → the non-EU company is the producer (Article 3(1)(15)(c)/(d)). “End user” includes consumers and business users that consume the product themselves rather than reselling.
EU third-party logistics (3PL) provider handles the non-EU company’s goods without taking ownership → the non-EU company remains the producer. The 3PL is only liable for transport packaging it strips off and disposes of in the EU (Recital 123).
EU online marketplace facilitates a sale between a non-EU seller and an EU consumer → the non-EU seller is the producer. The marketplace has separate verification duties under Article 45(4) but is not the producer.

In practice, the question to ask is: does the EU entity take ownership and resell the goods, or does it merely facilitate the transaction? If the EU entity takes title and resells, it is the producer. If not, the non-EU company retains the producer obligations under PPWR.

What businesses should do now

With the August 2026 application date approaching, here’s where to start:

Inventory your EU-bound packaging. List every packaging component – by material, weight, supplier and SKU. This is the data foundation for everything else.
Check chemical compliance. If you sell food-contact packaging into the EU, request PFAS test data from your packaging suppliers now. Obtain heavy metal limits at the same time.
Map your EU markets. List every EU country you sell into and identify the national EPR scheme in each. Begin registration in priority markets – registration cycles can take 1–3 months.
Obtain Declarations of Conformity. Contact your packaging suppliers to request a DoC for every packaging type you import or sell from August 2026.
Plan ahead for 2030. Packaging redesign, supplier qualification and artwork changes for the harmonised label and digital identifiers all take 12–18 months. Decisions made in 2026 will determine whether you’re ready for the 2030 wave.

Useful links:

The links below take you to official EU publicatons:

At 51toCarbonZero, we help organisations measure, reduce and report their carbon and ESG performance – including navigating regulations like PPWR and UK pEPR. If you’d like to discuss how PPWR affects your business

This article is for general information only and does not constitute legal advice. Compliance decisions should be made with reference to the primary legislation and, where necessary, qualified legal counsel.