EU Packaging and Packaging Waste Regulation (PPWR)

Introduction

Adopted as part of the EU's broader circular economy strategy, the PPWR replaces the previous Packaging and Packaging Waste Directive and establishes a harmonised regulatory framework for packaging sustainability, labelling, disposal, and recycling across all EU Member States.

The PPWR came into force in 2025 and will take effect on 12 August 2026. It imposes substantial obligations on economic operators throughout the packaging supply chain, including Producers, Manufacturers, Importers, and Distributors. Its ultimate objective is to prevent non-compliant packaging from entering the EU market and to drive the transition towards a fully circular economy for packaging materials.

This article answers the most frequently asked questions about EU PPWR compliance, helping businesses understand their obligations, key compliance dates, and the steps required to prepare.

Frequently Asked Questions

What is the EU Packaging and Packaging Waste Regulation (PPWR)?

The PPWR is a new EU regulation that establishes comprehensive rules governing the sustainability, labelling, disposal, and recycling of packaging across the European Union. Unlike its predecessor (the Packaging and Packaging Waste Directive), the PPWR is a regulation, meaning it applies directly in all EU Member States without the need for transposition (albeit Member States will need to put in place national infrastructure for compliance).

The PPWR covers the entire packaging lifecycle. It imposes fees and data collection and reporting obligations on Producers and prescribes sustainability and labelling requirements that primarily fall on Manufacturers. The regulation's overarching aim is to ensure that only compliant, sustainable packaging enters the EU market, thereby contributing to the EU's circular economy objectives.

When does the EU PPWR take effect?

The PPWR came into force in 2025 and will take effect on 12 August 2026. This is the date by which Producers must register with the relevant authorities in each relevant Member State and by which Manufacturers must draw up technical documentation and a Declaration of Conformity. Further implementing legislation at the EU level will phase in sustainability and labelling requirements from 2028  

Who does the EU PPWR apply to?

The EU PPWR applies to economic operators – both inside and outside the EU – that are involved in the supply chains of packaging and packaged goods supplied in the EU:

• Producers: entities that first make packaging or packaged products available on the EU market, including through online / direct to consumer sales.
• Manufacturers: entities that physically manufacturing packaging, or (where packaging is branded) the brand owner.
• Importers: entities incorporated in a Member State that place packaged products from a third country on the EU market.
• Distributors: entities in the supply chain that make packaged products available on the EU market.

Each category of economic operator has distinct obligations under the PPWR. The Producer and Manufacturer may, but will not always be, the same entity.

What packaging is covered by the EU PPWR?

The EU PPWR takes a very broad approach to defining packaging. It covers packaging made from any material that is used for the containment, protection, handling, delivery, or presentation of goods. The regulation applies to all categories of packaging, including:

• Primary (sales) packaging: packaging that forms the sales unit for the end user (e.g. a bottle, jar, or box).
• Secondary (grouped) packaging: packaging used to group a number of sales units together (e.g. a multipack wrapper).
• Tertiary (transport) packaging: packaging used for the transport of goods (e.g. pallets, crates).
• E-commerce packaging: packaging designed specifically for online retail delivery.
• Service packaging: packaging filled at the point of sale (e.g. takeaway containers).

Packaging may include multiple components (for example, a jar, lid, and label; or an outer rigid box with moulded plastic inserts). Not all packaging is immediately obvious. Items such as clothes hangers sold with clothing, tags hung from products, sticky labels, tubes around which foil or film are wrapped, and single-serve units containing tea and coffee may all qualify as packaging under the regulation.

Who is a 'Producer' under the EU PPWR?

A Producer under the EU PPWR will be:

• The entity that, in the Member State where it is established and where the packaging is expected to become waste, makes packaging or packaged products available in that Member State for the first time, or
• The entity established in a Member State or a third country that makes packaging or packaged products available directly to end users in another Member State (for example, through cross-border e-commerce sales), or
• Where there is no Producer in the categories above, the entity established in a Member State that unpacks packaged products without being the end user.

Businesses operating across multiple Member States should assess their Producer status in each jurisdiction, as registration and fee obligations apply on a per-Member-State basis.

What must Producers do under the EU PPWR?

Producers’ obligations include:

• Registration: By 12 August 2026, Producers must register with the appropriate authorities in each Member State in which they make packaging or packaged products available.
• Data collection and reporting: Producers will need to collect and report packaging-related data to Member State authorities. The first year of mandatory reporting is expected to be 2029, covering data from 2028.
• Payment of fees: The PPWR mandates the payment of fees by Producers. Member States are required to modulate those fees based on harmonised recyclability performance grades (expected to take effect from 2028).

Producers should be gearing up to comply now, particularly with regard to registration and the systems needed for data collection.

What must Manufacturers do under the EU PPWR?

Manufacturers bear the primary responsibility for compliance with the PPWR’s requirements as to the sustainability, design, and labelling of packaging. A Manufacturer may be the party that physically manufactures the packaging. However, where packaging is branded, the Manufacturer is likely to be the brand owner rather than the physical producer.

Key obligations for Manufacturers include:

• Preparation of technical documentation and a Declaration of Conformity (applicable from 12 August 2026).
• Compliance with sustainability and design requirements (expected to apply from 2028 onwards).
• Compliance with labelling requirements (also expected from 2028 onwards).

What is a Declaration of Conformity and when is it required?

A Declaration of Conformity is a formal document prepared by the Manufacturer confirming that packaging meets the applicable sustainability requirements set out in the PPWR. The obligation to prepare technical documentation and a Declaration of Conformity is one of the requirements that takes effect from 12 August 2026.

Manufacturers must draw up the Declaration of Conformity alongside supporting technical documentation that demonstrates how the packaging satisfies the relevant requirements. This documentation must be available for inspection by market surveillance authorities.

Businesses that are Manufacturers (or brand owners treated as Manufacturers) should begin preparing their Declaration of Conformity processes ahead of the 12 August 2026 deadline.

What must Importers and Distributors do under the EU PPWR?

Importers and Distributors have subsidiary obligations relating to the sustainability, design, and labelling of packaging. While the primary compliance burden falls on Manufacturers, Importers and Distributors must ensure that the packaging they place on or make available on the EU market meets the applicable requirements.Both Importers and Distributors should ensure their supply chain partners (particularly Manufacturers) are meeting their obligations, and should maintain appropriate records to demonstrate compliance if required by market surveillance authorities.

What are the data reporting requirements under the EU PPWR?

The PPWR requires Producers to collect and report packaging-related data to the relevant Member State authorities. This data reporting obligation is intended to support the effective monitoring and enforcement of the regulation's objectives.

Further implementing legislation is needed at both EU and Member State level to define the precise scope and format of reporting requirements. The first year of mandatory reporting is expected to be 2029, covering data relating to the 2028 calendar year.

Producers should begin developing the systems and processes needed to capture the required data well in advance of the reporting deadline. This is likely to require coordination with supply chain partners to obtain accurate data on packaging volumes, materials, and recyclability.

What fee obligations does the EU PPWR impose?

The PPWR mandates the payment of fees by Producers. These fees are intended to fund the collection, sorting, recycling, and disposal of packaging waste.

A key innovation of the PPWR is the requirement for Member States to modulate fees based on harmonised recyclability performance grades. Packaging that is more readily recyclable will attract lower fees, while packaging with poor recyclability will incur higher costs. These performance grades and the associated eco-modulation rules are being developed through further implementing legislation, which is expected to take effect from 2028.

Producers should factor these anticipated fee structures into their packaging design and procurement decisions, as choosing more recyclable packaging materials and formats will result in lower compliance costs over time.

How should businesses prepare for EU PPWR compliance?

Businesses affected by the EU PPWR should take the following steps to prepare for compliance:

• Identify your role: Determine whether your business is a Producer, Manufacturer, Importer, or Distributor (or a combination) in each relevant Member State.
• Complete Producer registration: Ensure registration with the appropriate authorities in all relevant Member States by 12 August 2026.
• Prepare Declarations of Conformity: If you are a Manufacturer (or brand owner), begin preparing the technical documentation and Declaration of Conformity required from 12 August 2026.
• Audit your packaging: Review all packaging used across your product range to identify potential compliance gaps, particularly in relation to recyclability and sustainability.
• Develop data capture systems: Invest in systems and processes to collect the packaging data that will be required for mandatory reporting from 2029.
• Monitor implementing legislation: Track the development of further EU and Member State legislation that will flesh out the detailed requirements for sustainability, labelling, fee modulation, and data reporting.
• Engage with legal advisers: Seek specialist legal advice to understand the full scope of your obligations and to develop a tailored compliance strategy.

Early preparation is strongly recommended. The complexity of the regulation, combined with the need for coordination across multiple Member States and supply chain partners, means that businesses should not delay in beginning their compliance planning.

For a more detailed briefing, read more on EU & UK Packaging Regulations.