EU Packaging and Packaging Waste Regulation:

New Compliance Requirements to Apply from August 2026

From 12 August 2026, the new EU Packaging and Packaging Waste Regulation – Regulation (EU) 2025/40 (PPWR) will apply and will directly govern how packaging may be designed, used and placed on the EU market. The PPWR replaces the current directive-based system with a single, harmonised set of rules that will apply in the same way in all Member States.

For businesses, this is not just an environmental initiative – it is a market access and cost issue that will directly affect product design, supply chains, pricing, and contractual risk allocation. Companies that treat PPWR implementation as a strategic project in 2026 will be better positioned to avoid disruption and use the changes to drive cost and brand advantages.

What is changing in practical terms?

1. Recyclability becomes a condition for selling in the EU

Under the PPWR, recyclability is no longer simply “nice to have”, it becomes a market access condition for packaging. Packaging will need to meet EU recyclability performance criteria, which will be further detailed in implementing measures and standards.

This means businesses will need to review packaging materials, inks, adhesives, labels, and composite structures to verify whether existing formats will still be allowed on the EU market in the medium term. Non-compliant packaging may ultimately have to be redesigned or phased out, with implications for product launches, rebranding cycles, and SKU rationalisation.

2. Mandatory packaging reduction and “no more empty space”

The PPWR tightens packaging minimisation rules and targets avoidable and excessive packaging, including transport and e‑commerce packaging. Regulators will look more closely at oversized boxes, unnecessary layers, and formats with high empty space ratios.

For e‑commerce, fulfilment, and logistics-heavy businesses, this will require a review of standard box sizes, filler materials, and bundling practices. Optimisation here can both reduce regulatory risk and deliver direct savings on materials, storage, and freight.

Cost impact: EPR fees and data quality

3. Extended Producer Responsibility becomes a cost lever

Extended Producer Responsibility (EPR) remains the backbone of packaging compliance, but fee structures will become more closely linked to the environmental performance of each packaging format. In practice, “eco-modulated” fees will reward packaging that is easier to recycle or which contains recycled content and penalise formats that are hard to recycle or generate unnecessary waste.

For procurement and finance, this turns packaging choices into a recurring cost item, not just a one-off design decision. Redesigning specific high-volume SKUs may significantly reduce EPR charges over time, while failure to adapt may gradually erode margins in certain product lines or markets.

4. Reporting and master data move centre stage

The PPWR will require more granular and reliable packaging data, including quantities by material, type and format. Larger and multi-jurisdictional businesses may need to upgrade product master data, ERP classifications, supplier questionnaires, and reporting workflows to capture the information required for compliance and EPR fee calculation.

Weak or incomplete data can translate into overpayments, correction exercises with Producer Responsibility Organisations, and enforcement exposure if authorities challenge reported figures. Robust data governance around packaging will therefore become a core compliance and finance topic, not just an operational concern.

Product, supply chain and portfolio strategy

5. Restrictions on certain single‑use formats

The PPWR introduces targeted bans and restrictions on specific single-use packaging formats, particularly in hospitality, food service, retail, and for fresh produce, where waste prevention alternatives exist. Impacted businesses will need to assess whether to transition to alternative materials, adapt product formats, or pilot reuse models.

This may create both risk and opportunity: brands that move early to compliant and consumer-friendly alternatives may differentiate themselves, while laggards may face last-minute redesigns, write‑offs of non‑compliant stock, or interruptions in certain channels.

6. Recycled content requirements for plastic packaging

The Regulation sets mandatory recycled content targets for certain plastic packaging categories, with phased application over time. Businesses will need to secure the supply of certified recycled plastics, ensure traceability in their supply chains, and build these requirements into procurement specifications and long‑term supplier contracts.

Competition for high-quality recycled material is likely to increase, which makes early engagement with suppliers and long‑term sourcing strategies important in order to avoid cost spikes or supply constraints when targets become binding.

7. New labelling and consumer information rules

The PPWR will harmonise labelling requirements to support sorting, collection, reuse, and recycling of packaging across the EU. This will likely require artwork changes, packaging redesign, and careful stock management to avoid large write‑offs of non-compliant printed packaging.

Marketing, regulatory, and supply chain teams will need to coordinate timing so that new labels are introduced in line with PPWR deadlines, while minimising disruption to production and inventory.

Where the impact will be felt internally

The Regulation will cut across several functions:

• Product and packaging design: the need to test portfolios against recyclability, minimisation, recycled content, and format restrictions before 2026.
• Procurement and supplier management: the need to obtain detailed technical documentation, recyclability information, and recycled content evidence from packaging suppliers and converters.
• Legal and compliance: the need to determine the role of each group entity (producer, importer, distributor, online platform, fulfilment provider) and ensure correct registrations and responsibilities under EPR and PPWR.
• Data/IT and finance: the need to build systems capable of capturing granular packaging data and linking it to EPR fee calculations, budgeting, and forecasting.
• Commercial and logistics: the need to adjust contracts, service levels, and logistics models where packaging formats, costs, or responsibilities will change.

Given the cross-functional nature of the changes, businesses that treat PPWR as a coordinated implementation project (rather than a siloed legal exercise) will be better placed to manage risk and cost.

From a business perspective, companies that have not yet started preparing should use the coming months to:

• map their packaging footprint: Identify all packaging used for products placed on the EU market (primary, secondary, transport, e‑commerce, promotional) and link it to SKUs, markets and channels.
• clarify roles and responsibilities: Determine which group entities and partners qualify as producers, importers, distributors, marketplaces, or fulfilment service providers for PPWR purposes in each relevant Member State.
• stress-test current compliance: Review existing EPR registrations and reporting flows, and identify where PPWR will change obligations, fee structures, or data requirements.
• prioritise high‑risk formats: Identify non‑recyclable or hard‑to‑recycle packaging, high empty-space formats, and single-use formats likely to be restricted, then prioritise them for redesign.
• upgrade data and contracts: Enhance packaging data systems and revise key contracts (supply, private label, distribution, logistics, marketplace) to address PPWR-related data provision, cost allocation, and liability.

Turning the PPWR self-assessment into an implementation plan

Because the PPWR will be implemented through a sequence of milestones, delegated and implementing acts, and further technical specifications, businesses should approach compliance as a structured implementation project rather than a one-off August 2026 exercise. The immediate priority is to identify where the Regulation will create the greatest pressure within the organisation — whether in packaging design, procurement processes, EPR cost exposure, packaging data and reporting systems, or contractual arrangements with suppliers, distributors, and other commercial partners.

This initial self-assessment is an important starting point. Once the main pressure points are identified, the next step is to convert them into a practical compliance roadmap that is aligned with the PPWR implementation timeline, remains flexible enough to accommodate future technical measures, and clearly allocates responsibilities across the business and the value chain.

This is where legal support can add value. The PPWR is not only an environmental compliance matter. It affects product design, procurement, supplier relationships, contractual risk allocation, EPR cost exposure, reporting governance, and market access. For many businesses, the key challenge will be to determine not only what the Regulation requires, but also who within the value chain is responsible for delivering the relevant information, bearing the related costs, and managing corrective actions if packaging is found to be non-compliant.

A targeted legal review at this stage can help convert a broad regulatory obligation into a clear, prioritised action plan — identifying what must be changed, who should be involved, which contractual protections are needed, and where the main cost and enforcement risks may arise.

If you need support in navigating PPWR requirements and packaging compliance obligations, our team remains at your disposal.