Kerry Stares, Rory Partridge and Lyla Gilbert write in Sustainable Views about how sustainable packaging is becoming a condition of EU market access

The EU’s Packaging and Packaging Waste Regulation is creating immediate compliance obligations for businesses selling packaged goods into the EU, with the rules reaching far beyond traditional packaging companies. From 12 August 2026, manufacturers and brand owners face requirements including conformity assessments, technical documentation and restrictions on substances of concern. 

The regulation applies across the supply chain of packaging and packaged products sold into the EU, regardless of where a business is headquartered. With no minimum size threshold or tonnage exemption, companies ranging from consumer goods groups and retailers to ecommerce businesses may fall within scope. 

Responsibility is shifting closer to brand owners, particularly where they place orders, set specifications or put their name on packaging. Importers, distributors, fulfilment service providers and online marketplace operators may also have subsidiary obligations, meaning businesses cannot simply assume that compliance has been addressed elsewhere in the supply chain. 

The commercial risk is not limited to regulatory penalties. Non-compliant packaging may prevent goods from lawfully entering the EU market, making stopped shipments a key concern for businesses that have not prepared conformity documentation, registrations, packaging audits and reporting systems in advance. 

Kerry Stares, Partner and ESG Advisory Lead, Rory Partridge, Associate, and Lyla Gilbert, Solicitor Apprentice, in our Dispute Resolution team, write in Sustainable Views:

Packaging has spent decades as an operational afterthought, decided late, bought cheaply and often overlooked. The PPWR turns it into a demonstration of how well a business understands its own supply chain.

Read the full article in Sustainable Views here.