The European Union (EU) has overhauled its packaging rules. The new Packaging and Packaging Waste Regulation (PPWR) replaces the previous Packaging and Packaging Waste Directive (PPWD). The PPWR entered into force on February 11, 2025, and generally applies from August 12, 2026. Some obligations apply from that date, while others phase in later through implementing acts and future target dates ( not every PPWR requirement is fully live on August 12, 2026; the Commission confirms the general application date but also has implementation workstreams and later milestones).
Note: If you place packaging on the Great Britain (GB) market, you must comply with United Kingdom (UK) packaging regime(s), including UK packaging producer responsibility and UK Extended Producer Responsibility (EPR) for packaging where applicable. EU PPWR requirements apply when packaging or packaged goods are placed on the EU market (UK Packaging Waste Regulations, UK EPR for packaging) .
Learn how this new regulation impacts your operations in the EU and what to do now to meet the deadline.
Are you ready for PPWR?
If you have worked with packaging compliance for several years, you may know the PPWD as the long-standing EU framework for packaging and packaging waste. As a directive, the PPWD gave member states flexibility in how they implemented requirements. That helped create a patchwork of national rules, different producer responsibility schemes, and varying levels of enforcement across Europe (PPWD [Directive 94/62/EC]).
The PPWR (Regulation (EU) 2025/40) changes that approach. As an EU regulation, it is directly applicable across member states and is intended to create more harmonized packaging rules. National systems will still matter, especially for EPR registration, fees, competent authorities, and enforcement, but the core requirements are now set in a more consistent EU-wide framework.
Key differences between the PPWD and PPWR
- Legal format:
- PPWD: EU Directive – each nation implemented it differently.
- PPWR: EU Regulation – directly applies across all EU member states. GB businesses placing packaging on the EU market must comply (in addition to meeting UK requirements for packaging placed on the GB market).
- EPR requirements:
- PPWD: Varied national EPR schemes
- PPWR: Harmonized EPR rules, mandatory producer registration, eco-modulated fees
- Sustainability targets:
- PPWD: Focused mainly on recycling rates.
- PPWR: Broader scope on all packaging must be recyclable by 2030, with reuse/refill targets, recycled content mandates, and packaging reduction goals
- Enforcement:
- PPWD: Country-specific enforcement and penalties
- PPWR: Stronger evidence, conformity and market-surveillance expectations; noncompliant packaging may be subject to corrective action, withdrawal, recall, or market restrictions.
What do the EU PPWR reforms mean for your organization?
The PPWR’s ultimate goal is to drive a circular economy for packaging: less waste, more recycling and reuse, and greater responsibility on producers. If your organization manufactures, imports, distributes, or sells packaging or packaged goods into the EU, you should assess whether your packaging is in scope and which legal entities have obligations. In other words, if you place packaging on the EU market, whether you’re an EU company or a non-EU exporter, you must comply.
Some of the most important changes under PPWR and how they impact businesses include:
- Uniform EPR registration and reporting: Producers will need to register in the member states where they make packaging available and provide packaging data through national systems. This does not mean every company must register in every EU country; it means the organization needs a market-by-market view of where it places packaging or packaged goods on the EU market and who the responsible producer is in each case.
This is a big shift from the old system. If you haven’t already, identify all your “producer” entities in Europe and prepare to register them as required once national portals go live (implementing acts on the registration system were due by February 2026).
- Packaging design requirements: All packaging should be designed for sustainability. By 2030, all packaging must be recyclable according to EU criteria. Recyclability will be graded (A to C), and packaging that doesn’t reach at least 70% recyclability (grade C) will not be considered recyclable. Importantly, your future EPR fees will depend on these grades. Highly recyclable packaging means lower fees, while hard-to-recycle packaging will cost more (this is the “eco-modulation” of fees).
Take time now to evaluate your packaging portfolio: Can each component be easily recycled? If not, consider redesigning with more recyclable materials or simpler formats.
- Reused and refilled packaging: For the first time, the EU is setting reuse and refill targets. Certain sectors like food service and the hotel, restaurant, and café/catering industry (HORECA) must ensure that 10% of products are in reusable packaging by 2030, rising to 40% by 2040. While these targets phase in later, companies need to start rethinking their packaging models early.
Explore opportunities for refillable containers, deposit-return systems, or reusable transit packaging where feasible, and engage your supply chain and customers in these initiatives.
- Recycled content in plastics: The PPWR regulation mandates minimum recycled plastic content for many types of packaging. The 2030 thresholds include 30% for contact-sensitive polyethylene terephthalate (PET) packaging, 10% for contact-sensitive plastic packaging other than PET, 30% for single-use plastic beverage bottles, and 35% for other plastic packaging, subject to exemptions and calculation rules. Higher thresholds apply in 2040.
Check your packaging specifications and start integrating higher levels of recycled resin in plastic packaging. This not only ensures future compliance but can also reduce your virgin material use and demonstrate commitment to circular economy goals.
- Hazardous substance restrictions: From August 12, 2026, food-contact packaging cannot be placed on the EU market if it contains per- and polyfluoroalkyl substances (PFAS) at or above the PPWR thresholds. PFAS are often used for grease-resistant coatings (think fast-food wrappers or fiber takeout boxes). You may need to reformulate coatings or switch to alternative materials now to meet the PPWR’s PFAS limits (e.g., no more than 25 parts per billion [ppb] for any individual PFAS). The regulation also maintains existing heavy metal limits (100 parts per million [ppm] total for lead, cadmium, mercury, and hexavalent chromium). Most organizations already comply with these, but double-check your materials.
- Mandatory labelling and documentation: The PPWR introduces harmonized labeling to help consumers recycle and improve transparency. Expect new symbols or QR codes on packaging indicating material composition, recyclability, reuse options, or the presence of certain substances. The PPWR will introduce more harmonized labelling and information requirements, but businesses should be careful with the timeline. The Commission is preparing to implement acts on packaging labelling, including consumer sorting, reusable packaging, deposit-return systems, recycled content, and other labels. Material-composition labelling is scheduled to apply from August 12, 2028, or 24 months after the relevant implementing acts enter into force, whichever is later. In addition, technical documentation and an EU Declaration of Conformity (DoC) will be required for each packaging type or family. This means you’ll need to perform a conformity assessment for your packaging (ensuring it meets all PPWR requirements) and maintain documentation proving it.
BSI tip: If you overhaul your packaging now, you might uncover opportunities to save costs (through material reduction), improve brand reputation with consumers (through greener packaging), and reduce long-term risk. EPR and sustainability sit at the intersection of compliance, brand trust, cost, and circular design.
Opportunity in PPWR compliance
Change can be challenging, but it also drives innovation. The PPWR regulation is pushing companies to reimagine packaging from reducing unnecessary volume and weight to designing for reuse and easy recycling. While there may be upfront costs to adjust your materials or systems, many organizations find that smarter packaging design can lead to cost savings (through material reduction and efficiency), enhanced brand image, and even new business models (like offering refills or take-back schemes).
As the PPWR comes into effect, this is a chance for organizations to improve their products and supply chains. Start early and view this holistically. Build a reliable process for packaging data and EPR reporting: something that can be used year after year and across multiple regions.
When you upgrade your compliance processes, you’re also future proofing your business as more laws (and more countries) adopt similar rules.
Learn more about global EPR trends and best practices:
Blog: Extended Producer Responsibility (EPR) Around the World – what global frameworks mean for producers
Guide: Download BSI’s EPR Compliance Guide
EBJ Executive brief: BSI Committed to the Growing Global Market for Extended Producer Responsibility
Meet our EPR and global sustainability experts:
Ethan Redden, Associate Consultant, Circularity and Carbon Reduction Consulting, BSI
Ryan Lynch, Global Practice Director for Sustainability Consulting, BSI
You’re not alone on this journey. We’ve been helping brands and retailers navigate EPR schemes in the UK, the EU, North America, and globally. We understand the common pain points, from missing packaging specs to complex fee calculations, and how to solve them.
