Packaging compliance in Europe is moving from “good practice” to hard commercial requirement. The EU’s new Packaging and Packaging Waste Regulation — the PPWR, formally Regulation (EU) 2025/40 — entered into force on 11 February 2025 and is due to apply generally from 12 August 2026. It replaces the old Packaging and Packaging Waste Directive and is designed to create more harmonised rules across the EU, covering packaging design, recyclability, labelling, reuse, recycled content and waste management.
For brands, this is not simply an environmental update. It affects packaging choice, artwork, substrate selection, supplier data, recyclability claims and market access. For packaging suppliers, it raises the bar on evidence: brands will increasingly ask for detailed, auditable information about materials, composition, recycled content, recyclability, substances of concern and compliance documentation.
Why the PPWR Matters Now
The scale of the issue explains the regulatory pressure. In 2023, the EU generated 79.7 million tonnes of packaging waste — 177.8 kg per person. Paper and cardboard accounted for 40.4% of packaging waste, plastic 19.8%, glass 18.8%, wood 15.8% and metal 4.9%. Plastic packaging waste alone averaged 35.3 kg per person, of which 14.8 kg was recycled.
The EU’s objective is clear: by 2030, all packaging placed on the EU market should be recyclable in an economically viable way. The PPWR also introduces increasing recycled-content targets for plastic packaging in 2030 and 2040, tighter rules on unnecessary packaging, restrictions on some single-use formats, stronger reuse and refill requirements, and clearer labelling for consumers.
The European Commission is also preparing further guidance, FAQs and implementing measures, including work on EPR registration and reporting formats, labelling and recyclability criteria. That means businesses should treat 2026 as the point where packaging compliance becomes a structured data and documentation exercise, not a last-minute design check.
What Changes for Brands Choosing Packaging?
The first implication is that packaging decisions will need to be made with future evidence in mind. A pack that looks sustainable but cannot be evidenced as recyclable, appropriately labelled, minimised or compliant with substance restrictions may create risk.
Brands should review packaging against five practical questions:
1. Can the pack be recycled in practice, not just in theory?
The PPWR moves Europe towards a more harmonised recyclability framework. Packaging will need to be designed for recycling, and future recyclability grades will affect whether a format remains acceptable. This makes material simplicity, compatible coatings, adhesives, labels, closures and inks more important.
2. Is the material choice aligned with recycled-content requirements?
Plastic packaging will be under particular pressure because the PPWR introduces minimum recycled-content requirements for plastic packaging from 2030, with higher targets from 2040. Targets vary by packaging type and application, with industry summaries generally describing 2030 targets in the 10–35% range and 2040 targets rising as high as 65%, depending on category.
3. Is there avoidable empty space or unnecessary packaging?
The PPWR focuses on minimisation as well as recyclability. For e-commerce, transport and grouped packaging, void fill, oversized outers and unnecessary layers will come under greater scrutiny. This will encourage right-sized cartons, leaner secondary packs and fewer decorative or non-functional components.
4. Are labels and claims supportable?
Clear labelling is one of the PPWR’s stated aims. Brands should expect to align packaging marks, sorting instructions and recyclability claims with harmonised EU requirements as they develop, while avoiding vague claims that cannot be substantiated.
5. Is the pack free from problematic substances?
The PPWR includes restrictions on substances of concern, including PFAS in food-contact packaging above certain thresholds. The Commission specifically highlights PFAS restrictions in food-contact packaging as part of the Regulation’s safety objective.
PFAS: The “Forever Chemicals” Issue Brands Cannot Ignore
PFAS — per- and polyfluoroalkyl substances — are used for properties such as grease, water and oil resistance. In packaging, that can mean applications such as fast-food wrappers, takeaway boxes, microwave popcorn bags, pizza boxes and certain paper-based food containers. The problem is persistence: the UK government’s PFAS Plan notes that PFAS are highly persistent, mobile and able to accumulate in soils, plants and animals, with potential exposure through the food chain.
In the EU, the PPWR directly restricts PFAS in food-contact packaging. Separately, the European Chemicals Agency has published an updated proposal for wider PFAS restrictions under REACH, prepared by authorities from Denmark, Germany, the Netherlands, Norway and Sweden.
For brands, the message is simple: if grease resistance, water resistance or barrier performance is being achieved through fluorinated chemistry, now is the time to verify it and evaluate alternatives. “PFAS-free” should not be used casually; it needs to be backed by supplier declarations, specifications and, where relevant, test evidence.
What Changes for Packaging Suppliers?
Suppliers will become compliance partners, not just manufacturers. Brands selling into the EU will increasingly ask suppliers to provide packaging-level data that can support PPWR compliance and EPR reporting.
This will include:
- material composition by component and weight
- recycled content, especially post-consumer recycled content in plastics
- recyclability information and design-for-recycling evidence
- coatings, adhesives, inks and additives information
- confirmation of heavy metals and substances of concern
- food-contact status where relevant
- PFAS declarations or test evidence where relevant
- documentation needed for declarations of conformity and technical files
The PPWR introduces conformity assessment and documentation expectations. Legal commentary and compliance guidance note that manufacturers will need technical documentation and EU declarations of conformity for packaging, while suppliers will need to provide the information required to support those assessments.
For suppliers, this means product data must be structured, current and retrievable. A one-off PDF specification may not be enough if a customer needs to report by market, material, weight, recycled content and recyclability class.
EPR: Reporting Will Become More Demanding
Extended Producer Responsibility is already familiar in many European markets, but PPWR increases the pressure for consistency and transparency. UK government guidance for exporters states that UK businesses selling packaged goods into the EU will need to comply with PPWR and EU EPR rules, including registering with the national authority in the EU country of sale and providing data on packaging type, weight, recyclability and recycled content.
This has two practical consequences.
First, brands need better packaging data from suppliers earlier in the development process. Waiting until launch to collect weights and material details will be too late.
Second, suppliers who can provide reliable data quickly will have a competitive advantage. Packaging choice will increasingly be influenced not only by cost, availability and appearance, but by whether the supplier can support compliance in multiple markets.
Europe Is Harmonising — but Country Differences Still Matter
One of the PPWR’s aims is to reduce fragmented national packaging rules across the EU. The Commission explicitly describes the Regulation as a way to harmonise standards and move away from diverging national approaches.
However, brands should not assume that “EU-compliant” automatically means every national administrative requirement disappears overnight. EPR systems, registration processes, fee structures, deposit-return systems and enforcement practices still vary by country.
The data shows why national context matters. In 2023, packaging waste generation ranged from 80.9 kg per inhabitant in Bulgaria to 223.1 kg in Ireland. Italy, Germany and Luxembourg also generated more than 200 kg per inhabitant, but Italy recycled 162.2 kg per inhabitant and Germany 149.3 kg. By contrast, Croatia, Bulgaria and Romania reported the lowest recycled packaging waste per inhabitant.
Recycling performance also differs sharply. In 2023, seven EU countries had already met the 2030 overall packaging recycling target of 70%: Belgium, the Netherlands, Italy, Czechia, Slovenia, Slovakia and Spain. Romania, Hungary, Malta and Greece were below 50%. Plastic packaging recycling shows another divide: Belgium and Latvia were above the 55% 2030 plastic target, while Hungary, France, Austria and Denmark were among the lowest performers.
These differences matter because packaging that is technically compliant may face different cost and recycling realities depending on where it is sold.
UK versus EU: Aligned Direction, Different Rules
For UK brands, the most important point is that the PPWR applies when placing packaged goods on the EU market. A UK brand exporting to France, Germany, Ireland or Spain will need to comply with EU rules for those markets, even though the UK is outside the EU. UK government guidance warns that non-compliance could result in goods being rejected at EU borders.
The UK has its own packaging Extended Producer Responsibility regime. GOV.UK guidance covers producers, reprocessors, exporters, compliance schemes, material facilities and online marketplaces, with requirements around registration, packaging data, recyclability assessment, fees and reporting.
On PFAS, the EU is moving through PPWR food-contact restrictions and the broader REACH restriction process. The UK’s approach is currently more evidence-led and staged. The UK PFAS Plan says the government will continue to monitor PFAS in food packaging and food-contact materials, strengthen analytical capability, prioritise higher-risk materials and consult on some future limits, including drinking-water standards. It also notes that initial UK sampling of certain food-contact materials, such as takeaway boxes, found negligible PFAS presence.
For businesses operating across both the UK and EU, the safest approach is to design packaging systems for the stricter or more advanced requirement where practical, while keeping separate evidence files for UK EPR, EU PPWR and country-level EU EPR reporting.
What Brands and Suppliers Should Do Now
The PPWR should be treated as a packaging portfolio project, not a legal footnote. Brands should map every packaging format by market, material, weight, recyclability, recycled content, food-contact status and supplier. Suppliers should prepare to provide standardised declarations and technical evidence for each packaging type.
The commercial winners will be the businesses that can combine design, compliance and data. For brands, that means choosing packaging that protects the product, appeals to consumers and survives regulatory scrutiny. For suppliers, it means being ready to answer not only “what is it made of?” but “can you prove it?”
The deadline may say August 2026, but packaging decisions being made now will still be on shelves, in warehouses and in supply chains when the rules apply. PPWR readiness is no longer optional; it is becoming part of responsible packaging procurement.
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