The PPWR in plain language: what the EU packaging rules mean for companies selling products in the EU

What the PPWR is

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, sets EU-wide rules for all packaging placed on the EU market. It entered into force on 11 February 2025 and has applied since 12 August 2026.

It replaces the old Packaging Directive (94/62/EC). The old rules were a directive, so each country wrote its own version. The PPWR is a regulation: the same text applies directly in all 27 EU countries.

Its aim is less packaging waste and more recycling. To get there, it sets rules on:

• what packaging may contain (heavy metals, and PFAS in food packaging);
• how packaging is designed (recyclable, minimal, with less empty space);
• how much recycled plastic it contains;
• how it is labelled, and how compliance is documented;
• who pays for collection and recycling (extended producer responsibility, or EPR).

The rules apply to packaging made in the EU as well as imported packaging, and to packaging sold empty as well as packaging that holds a product. Packaging already placed on the market before 12 August 2026 does not have to be withdrawn.

Who is responsible: the "manufacturer" is usually the brand

Under the PPWR, the manufacturer of packaging is the company that makes it, or has it designed or made under its own name or trademark. In practice, the brand whose name is on the packaging is the manufacturer, even if a supplier produced the box. For sales packaging, this is usually the company that fills it with the product. There is only one manufacturer for each packaging unit.

Example: a clothing brand orders printed polybags and cartons from a packaging supplier and has its garment factory pack the clothes. The brand is the manufacturer of that packaging, not the supplier or the factory.

• Manufacturer

  Who it is:

  The brand that has packaging made or filled under its own name, or makes it itself

  Main duties:

  Make sure packaging meets the rules, draw up technical documentation and an EU declaration of conformity, put its name and address on the packaging, keep the documents for 5 years (10 for reusable packaging)

• Supplier

  Who it is:

  A company that supplies packaging or parts of it to the manufacturer

  Main duties:

  Give the manufacturer the information and documents it needs to show compliance

• Importer

  Who it is:

  A company in the EU that places packaging or packaged products from outside the EU on the market

  Main duties:

  Check that the manufacturer did its part, that the documents exist and that the packaging is labelled; add its own name and address

• Distributor

  Who it is:

  A company that sells packaged products already on the market, such as a wholesaler or retailer

  Main duties:

  Check that the manufacturer and importer met their duties, and act if something is wrong

• Fulfilment service provider

  Who it is:

  A warehouse or logistics company that stores, packs and ships for online sellers

  Main duties:

  Make sure its handling does not break compliance; only work for sellers who met their duties

• Producer (for EPR)

  Who it is:

  The company that first makes packaging available in a given EU country

  Main duties:

  Register in that country's packaging register, report packaging volumes and pay recycling fees, usually through a producer responsibility organisation

Two points often missed:

• A company can have several roles at once. An importer that puts its own brand on the packaging is also the manufacturer.
• EPR applies country by country. If you sell directly to end users in an EU country where you are not established, you need an authorised representative for EPR in that country.

There is one exception for micro-enterprises (fewer than 10 employees and turnover or balance sheet of up to €2 million): if a micro-enterprise has packaging made under its own name by a supplier located in the same EU country, that supplier is the manufacturer.

What applies now and what comes later

The PPWR applies in stages. The paperwork, the substance limits and a basic recyclability duty already apply; most design changes start in 2030.

Already applies (since 12 August 2026)

• Technical documentation and EU declaration of conformity for each type of packaging, drawn up by the manufacturer.
• Heavy metals: lead, cadmium, mercury and hexavalent chromium together must stay at or below 100 mg/kg in all packaging. This limit existed before, but must now be documented.
• Substances of concern: a general duty to keep them to a minimum.
• PFAS in food-contact packaging: strict limits on these "forever chemicals" in packaging that touches food.
• Identification: a type, batch or serial number, and the manufacturer's name and postal address, on the packaging or in a QR code. An accompanying document is only allowed where that is not possible. Importers add their own name and address too.
• Producer registration (EPR): registration in the packaging register of each EU country where you first make packaging available.
• Recyclability: packaging must be recyclable. Until the detailed EU design-for-recycling criteria apply, the recyclability requirements carried over from the old Packaging Directive apply.

Coming next

• From 12 August 2028 at the earliest: harmonised labels showing what the packaging is made of, to help consumers sort waste. The exact date depends on when the Commission adopts the label design.
• From 1 January 2030:
  • All packaging must meet EU design-for-recycling criteria and reach recyclability grade A, B or C (from 1 January 2030, or 24 months after the Commission adopts the criteria, whichever is later).
  • Plastic packaging must contain a minimum share of recycled plastic (from 1 January 2030, or three years after the Commission's calculation rules, whichever is later), for example 35% for most plastic packaging that is not contact-sensitive, meaning not used for food, cosmetics or medicines.
  • Packaging must be reduced to the minimum weight and volume needed. Double walls, false bottoms and unnecessary layers that only make a product look bigger are not allowed. Some experts read this ban as already applying, so avoid such features in new designs now.
  • The company that fills grouped, transport or e-commerce packaging must keep empty space to at most 50%, counting fillers such as paper or air cushions as empty. Shipping a product in its own retail box is exempt.
  • Reuse targets start for transport packaging, and some single-use plastic formats are banned.
• 2038 and 2040: from 2038 only recyclability grades A and B are allowed; from 2040 the recycled-content targets rise.

Several of these dates depend on detailed rules the Commission still has to adopt, so some may move later. We will update this guide when they are published.

What it means for your sector

Every sector has packaging under the PPWR. What changes is where the effort goes.

• Apparel and textiles

  Typical packaging:

  Polybags, shipping cartons, tissue paper, dust bags for shoes and garments, hangers sold with clothing, hang tags attached to the product

  What to watch:

  Plastic polybags need recycled content from 2030; dust bags count as packaging; e-commerce boxes face the 50% empty-space limit

• Furniture

  Typical packaging:

  Large cartons, foam and corner protectors, plastic film, wooden pallets

  What to watch:

  Bulky protective packaging must be minimised; foam and mixed materials need a recyclable design; pallets count as transport packaging

• Toys

  Typical packaging:

  Display boxes with windows, blister packs, plastic ties and trays

  What to watch:

  Mixed paper and plastic is harder to recycle; plastic trays and blisters need recycled content from 2030

• Home goods

  Typical packaging:

  Retail boxes, paper or plastic inserts, shrink film, e-commerce mailers

  What to watch:

  Oversized boxes and false bottoms are not allowed from 2030; heavy metals in printed or coloured packaging must stay within limits now

For all sectors, the first step is the same: list every type of packaging you use, and who supplies it.

The data you need from packaging suppliers

As the manufacturer, you sign the declaration of conformity, but most of the evidence comes from your packaging suppliers and their material suppliers. Since August 2026, suppliers must give you the information you need.

• Description of each packaging type and its parts

  Why you need it:

  Technical documentation

  Who usually holds it:

  You and your packaging supplier

• Material of each part (paper, PE, PP, PET, wood…)

  Why you need it:

  Technical documentation, sorting labels, EPR reporting

  Who usually holds it:

  Packaging supplier

• Weight of each part

  Why you need it:

  EPR fees per material, minimisation

  Who usually holds it:

  Packaging supplier

• Heavy metals test results or supplier declaration

  Why you need it:

  100 mg/kg limit

  Who usually holds it:

  Packaging supplier, ink or pigment supplier

• PFAS test results (food-contact packaging only)

  Why you need it:

  PFAS limits

  Who usually holds it:

  Packaging or paper supplier

• Recycled content, with proof

  Why you need it:

  Recycled-content targets from 2030

  Who usually holds it:

  Plastic or paper supplier

• Recyclability assessment

  Why you need it:

  Design-for-recycling rules from 2030

  Who usually holds it:

  Packaging supplier, checked by you

• Quantities placed on the market, per EU country

  Why you need it:

  EPR registration and reporting

  Who usually holds it:

  You

The hardest part is usually the first step: getting a complete list of packaging parts, with materials and weights, for every product. Once that list exists, most other requirements build on it.

Checklist

The rules already apply, so start with what is required today, then prepare for 2030.

Now

• List every type of packaging you use, per product: sales packaging, outer cartons, shipping boxes, fillers, labels.
• Decide your role for each packaging type and each EU country: manufacturer, importer, distributor, and producer for EPR.
• Ask your packaging suppliers for materials, weights, and heavy metals declarations or test reports. For food-contact packaging, ask for PFAS evidence too.
• Draw up the technical documentation and the EU declaration of conformity for each packaging type where you are the manufacturer.
• Check the packaging carries your name and postal address.
• Register as a producer in each EU country where you first make packaging available, usually through a producer responsibility organisation. If you sell directly to end users in an EU country where you are not established, appoint an authorised representative for EPR there.
• Keep the documents for 5 years (10 for reusable packaging).

Before 2030

• Review your designs for recyclability, and replace mixed materials that are hard to recycle.
• Plan recycled plastic in your plastic packaging, and agree proof of recycled content with suppliers.
• Measure the empty space in grouped, transport and e-commerce packaging, and resize boxes where needed.
• Prepare for the new sorting labels once the Commission publishes the design.