Packaging and Packaging Waste Regulation: is your business ready for new packaging requirements?

What is the Packaging and Packaging Waste Regulation?

The Packaging and Packaging Waste Regulation (PPWR) is the EU’s new directly applicable framework for packaging and packaging waste. Since 12 August 2026, it generally applies across the European Union, marking an important milestone for businesses throughout the packaging value chain. The PPWR now formally applies, but implementation is only beginning.

The PPWR entered into force on 11 February 2025, following its publication in the EU’s Official Journal in January 2025. Its objective is to reduce packaging waste, increase reuse and recycling, and create more harmonised packaging rules across the Single Market. This is in line with the EU waste hierarchy principles, which prioritise waste prevention, reuse, and high-quality recycling measures to effectively decrease the total amount of packaging waste generated each year in the EU. The regulation replaces the previous Packaging and Packaging Waste Directive and introduces directly applicable requirements for businesses throughout the packaging value chain.

However, the passing of the 12 August application date does not mean that every PPWR obligation suddenly applies. The Regulation follows a phased implementation. Some requirements apply today, while major rules on recyclability, recycled content, packaging minimisation and reuse will follow later, in many cases from 2030 onwards.

With different requirements applying at different moments, keeping a clear overview is not always easy. So, what guidance has the Commission provided so far, and what does the Packaging and Packaging Waste Regulation mean for businesses today?

 

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What guidance has the Commission provided on Packaging and Packaging Waste Regulation implementation?

The Commission has published dedicated Guidance and two editions of Frequently Asked Questions (FAQs) to clarify how key PPWR provisions should be interpreted and applied in practice.

 

Packaging and Packaging Waste Regulation Guidance and the initial set of FAQs

In March 2026, the Commission published its implementation Guidance and an initial set of FAQs. Together, these documents provided further clarity on the definitions of manufacturers and producers, the allocation of responsibilities across packaging supply chains, labelling, reuse and the treatment of existing packaging.

The Guidance confirmed an important principle: packaging should generally be assessed according to its function, rather than simply by reference to indicative lists. It also provided more clarity on who bears responsibility under the PPWR. In many cases, the manufacturer is the company that determines the packaging design or places packaging on the market under its own name or trademark, rather than necessarily the company that physically produces it.

The Commission also provided more flexibility in some areas. For example, certain business-to-business reuse systems can use digital or accompanying documentation instead of placing all relevant information directly on durable packaging.

 

Second edition of FAQs

Subsequently, in the summer, the Commission followed up with a substantially expanded second edition of its FAQs. The update does not fundamentally change the Commission’s interpretation of the Packaging and Packaging Waste Regulation, but it gives businesses much more operational detail.

In particular, the updated FAQs provide further guidance on how to identify manufacturers and producers in more complex supply chains, what information suppliers need to provide, how traceability can work, how conformity assessments should be organised and what importers need to check.

They also answer an important practical question: what happens to existing packaging? Packaging produced before 12 August 2026 does not automatically need to be destroyed, remanufactured or relabelled, while packaging already placed on the market before that date may generally remain in circulation.

However, the Guidance and FAQs do not complete the PPWR framework. Important methodologies and technical requirements still need to be developed through delegated acts, implementing acts and European standards. EPR also remains closely linked to national systems, while national enforcement practices will matter in practice. The picture is therefore becoming clearer, but important parts of the PPWR framework are still being developed.

Packaging and Packaging Waste Regulation Timeline 2029 – 2040

 

What are the Packaging and Packaging Waste Regulation requirements for businesses after 12 August 2026?

From 12 August 2026, businesses must comply with a first set of requirements on product compliance, documentation, traceability, substances of concern and Extended Producer Responsibility (EPR), while several major sustainability requirements will apply later.

For businesses, the most important requirements to consider now are:

• Demonstrating packaging compliance: Manufacturers must ensure that packaging placed on the EU market complies with the Packaging and Packaging Waste Regulation requirements that already apply. This includes carrying out conformity assessments and preparing the required technical documentation and EU Declaration of Conformity. Manufacturers and importers must generally retain technical documentation for five years for single-use packaging and ten years for reusable packaging.
• Ensuring packaging can be traced: Packaging must carry information that allows it to be identified and linked to the relevant compliance documentation. The Commission has clarified that this does not necessarily require a unique identifier for every individual item. Depending on the packaging, identification by type, batch or serial number may be sufficient.
• Getting the right information from suppliers: Suppliers must provide manufacturers with the information and documentation needed to demonstrate conformity. Businesses should therefore check whether their contracts and information flows provide access to the technical data they need.
• Checking imported packaging: Importers must verify that manufacturers outside the EU have complied with the applicable PPWR requirements. This includes checking that the required conformity assessment has been carried out and that the necessary documentation is available.
• Complying with new PFAS restrictions: Food-contact packaging placed on the market from 12 August 2026 must comply with the PPWR’s PFAS concentration limits. Packaging already placed on the market before 12 August may remain there. However, there is no general stock-exhaustion exemption for non-compliant food-contact packaging placed on the market after the application date.
• Meeting EPR obligations: Producers are responsible for packaging they make available for the first time in a Member State. While the PPWR harmonises parts of the EPR framework, registration, reporting and financing obligations continue to operate through national systems. Businesses active in several Member States therefore need to determine their obligations country by country. The Commission has also moved the first reporting deadline under the PPWR’s new harmonised reporting requirements from 1 June 2029 to 1 June 2030, without affecting existing national EPR obligations.

Businesses do, however, have more time for some of the PPWR’s most far-reaching sustainability requirements. Recyclability performance requirements, minimum recycled content, packaging minimisation and most reuse targets generally apply from 2030 or later. Harmonised labelling requirements will also be phased in separately.

The Commission has also signalled that the start of application should not create an immediate enforcement cliff. Where authorities identify non-compliance, businesses should generally first be given the opportunity to take corrective action before packaging is prohibited, withdrawn or recalled.

The PPWR applies, but implementation is only beginning. Businesses therefore need to understand and comply with the requirements that apply today, while preparing for the next wave of obligations and monitoring the secondary legislation that will further shape how the PPWR works in practice.

The role of secondary legislation and what businesses can still do

A significant part of the Packaging and Packaging Waste Regulation still needs to be translated into detailed technical rules. The Regulation requires the European Commission to adopt a large number of delegated and implementing acts over the coming years, which will determine how several PPWR requirements work in practice. Implementing acts generally set out uniform conditions and methodologies for applying the Regulation throughout the EU, while delegated acts allow the Commission to supplement or amend certain non-essential elements of the PPWR.

This work is already well underway. Several important pieces of secondary legislation are still expected in 2026, covering producer registration and EPR reporting, harmonised packaging and waste-receptacle labels, recycled content and plastic recycling technologies.

What is important for businesses is that several upcoming PPWR measures are now entering the consultation phase. The Commission has launched a public consultation on the draft implementing act under Article 44(14), which will establish harmonised requirements for national producer registers and EPR registration and reporting. This is particularly relevant for businesses operating across several Member States, as the act will help determine what information producers need to register and report under the new framework.

The Commission is simultaneously gathering input on measures under Article 7 on recycled content in plastic packaging. These measures will further define:

• the sustainability criteria for plastic recycling technologies,
• how recycled content is calculated and verified, and
• how recycled material originating outside the EU is treated.

These consultations will feed into both implementing and delegated acts, which are due to be published by the end of 2026.

Two further implementing acts are expected before the end of 2026, setting harmonised specifications for packaging labels under Article 12(6) and waste-receptacle labels under Article 13(2). Together with the other measures still under development, they show that many of the practical details of PPWR compliance are still taking shape. For businesses, following these developments early is therefore important to anticipate future requirements and, where consultations are open, provide input on how proposed rules could affect their operations.

How can Publyon support businesses with Packaging and Packaging Waste Regulation implementation?

Publyon helps businesses understand what the PPWR means for them in practice. We identify relevant requirements, monitor the secondary legislation that will further shape the PPWR, and assess the impact on your organisation. Where rules are still being developed, we also identify opportunities to provide input and engage with policymakers.

Our support includes Policy Impact Scans to identify risks, obligations and opportunities; strategic sessions to determine priorities and internal next steps; regulatory monitoring of delegated and implementing acts; and public affairs support to help businesses engage with EU policymakers where relevant. This approach is reflected in our work with Reusable Packaging Europe (RPE), where Publyon helped the sector strengthen its voice in the EU packaging debate and engage throughout the development of the PPWR. Read more about our support in our client case on RPE.

Want to know what the PPWR means for your organisation? Publyon can help you understand what applies today and prepare for what comes tomorrow.