What Is the EU PPWR?

The PPWR is the EU’s new packaging and packaging waste regulation. It replaces the previous Packaging and Packaging Waste Directive framework and introduces directly applicable rules across the EU.

The regulation is designed to address several major packaging challenges:

• Increasing packaging waste
• Low levels of reuse in many packaging streams
• Packaging that is difficult to recycle
• Fragmented national packaging rules
• Insufficient use of recycled plastic
• Unnecessary packaging and excessive empty space
• Inconsistent labelling and consumer sorting information
• Complex EPR and packaging reporting requirements

The European Commission explains that packaging uses large quantities of primary raw materials and that increasing packaging waste, combined with low levels of reuse, collection and recycling, creates a barrier to a circular and resilient economy.

For businesses, the PPWR should not be treated as a future environmental policy only. It is a compliance framework that affects how packaging is designed, documented, labelled, reported, reused, recycled, and placed on the EU market.

Why PPWR Compliance Matters for Market Access

PPWR compliance matters because packaging is connected to product marketability. A product may be technically compliant, safe, and ready for sale, but the packaging around it may still create regulatory risk if it does not meet applicable requirements.

Packaging compliance can affect:

The European Commission states that the PPWR aims to make all packaging on the EU market recyclable in an economically viable way by 2030, safely increase recycled plastics in packaging, and reduce the use of virgin materials.

This means PPWR readiness should begin before the main compliance deadlines. Packaging redesign, supplier data collection, artwork updates, EPR registration, and technical documentation can take months or even years depending on the size and complexity of the product portfolio.

Who Is Affected by the PPWR?

The PPWR can affect any company placing packaging or packaged products on the EU market. This includes EU-based companies and non-EU companies exporting packaged goods into the EU.

Affected businesses may include:

• Product manufacturers
• Packaging manufacturers
• Importers
• Distributors
• Retailers
• Online marketplaces
• E-commerce sellers
• Brand owners
• Private-label businesses
• Food and beverage companies
• Cosmetics and personal care companies
• Healthcare and pharmaceutical companies
• Electronics and electrical equipment companies
• Automotive and industrial companies
• Textile, fashion and footwear companies
• Packaging suppliers
• Companies using transport, grouped, or e-commerce packaging

The PPWR is relevant because it covers packaging across the full lifecycle, from design and material composition to use, reuse, collection, recycling, and waste management.

Companies should prepare if they answer “yes” to any of the following questions:

Key PPWR Deadlines Businesses Should Know

The PPWR introduces requirements in phases. Companies should not look only at one date. The regulation includes multiple timelines for application, recyclability, recycled content, labelling, reuse, deposit-return systems, and implementing acts.

The Commission’s packaging waste page confirms the PPWR’s entry into force date and general application date, and it also references 2026 guidance and FAQs intended to support implementation.

Businesses should use 2026 as the start of operational readiness, not as the date to begin learning about the regulation. The companies that prepare early will be in a stronger position to redesign packaging, update supplier requirements, prepare documentation, and avoid last-minute compliance pressure.

Main PPWR Compliance Requirements

The PPWR covers several connected compliance areas. A company should not focus on only one topic, such as EPR or recyclability. A complete readiness plan should cover the full packaging compliance picture.

The attached workshop identifies these areas as part of a full packaging compliance system, including requirements for substances, recyclability, recycled content, labelling, technical documentation, compostability, minimization, reusable packaging, refill, EPR, DRS, online platform obligations, and formal non-compliance risks.

Substance Restrictions in Packaging

Substance compliance is one of the first PPWR readiness checks. Packaging materials may contain substances through inks, coatings, adhesives, barriers, pigments, plastic additives, recycled content, and treatments.

The workshop highlights several substance-related packaging concerns, including:

• Combined concentration limit for lead, cadmium, mercury and hexavalent chromium
• PFAS phase-out direction
• Minimization of Substances of Concern
• Microplastics considerations
• MOAH/MOSH restrictions

For many companies, a common mistake is assuming that product chemical compliance automatically covers packaging. It does not. Packaging must be assessed separately because the packaging bill of materials, suppliers, coatings, inks, adhesives, and recycled content may differ from the product itself.

Practical substance compliance checklist

A strong PPWR readiness plan should include packaging-specific supplier questionnaires, declarations, test reports for high-risk materials, and a controlled way to link evidence to packaging components and products.

Packaging Recyclability Requirements

Recyclability is one of the most important PPWR topics. The regulation is designed to move companies away from vague recyclability claims and toward practical recyclability supported by design, collection, sorting, recycling infrastructure, and evidence.

The European Commission states that the PPWR aims to make all packaging on the EU market recyclable in an economically viable way by 2030. EUR-Lex also explains that all packaging must be recyclable, including being designed for material recycling and able to be collected, sorted and recycled at scale when it becomes waste, with recycled-at-scale requirements entering into force in 2035.

The workshop explains recyclability in practical terms. Packaging should be:

• Designed for recycling
• Efficiently collected
• Properly sorted
• Able to produce quality secondary materials
• Recycled at scale

What companies should assess

The workshop also explains that recyclability performance grades may influence EPR fees. Packaging that is easier to recycle may generally result in lower fees, while packaging with weak recyclability may become more expensive or non-compliant over time.

Practical readiness steps

Companies should:

1- Create a full packaging inventory.

2- Identify materials and packaging components.

3- Review recyclability risks such as multilayer materials, problematic adhesives, full-body sleeves, dark pigments, mixed materials and small components.

4- Request recyclability evidence from suppliers.

5- Track recyclability grades where available.

6- Keep test reports and assessments in a technical file.

7- Start redesign planning for packaging that may not meet 2030 or 2035 requirements.

Recycled Content in Plastic Packaging

Plastic packaging is a major focus of the PPWR. Companies using plastic packaging need to understand whether minimum recycled content requirements apply to their packaging type.

The European Commission explains that the PPWR includes measures such as minimum recycled content in plastic packaging. The workshop identifies recycled content targets for 2030 and 2040, including contact-sensitive packaging, single-use plastic beverage bottles, and other plastic packaging categories.

Recycled content targets highlighted in the workshop

Companies should not treat recycled content as a marketing claim only. It is becoming a compliance requirement that must be backed by data and evidence.

What companies should collect

The workshop also notes that by 31 December 2026, the EU is expected to define the methodology for calculating and verifying recycled content, and from 2029 manufacturers must follow the methodology.

Packaging Labelling and Digital Information

Packaging labelling is one of the PPWR areas most likely to affect artwork, packaging design, regulatory review, and product launch timelines.

The workshop identifies several labelling areas, including:

• Material composition labels
• Reusability information
• Recycled content labels
• Biobased plastic labels
• Compostability labels
• Deposit and return system labels
• Waste collection labels
• Manufacturer information
• QR codes and digital data carriers
• Misleading label restrictions
• Harmonized labelling requirements

The PPWR aims to improve consumer information and reduce confusion caused by different national labelling systems. The European Commission describes the new rules as including improved consumer information and more sustainable choices.

Labelling questions companies should ask

A practical PPWR labelling review should involve regulatory affairs, packaging design, marketing, sustainability, legal, and artwork teams. Labels should not be updated without checking whether the claim or label is supported by technical evidence.

Technical Documentation and Declaration of Conformity

PPWR compliance must be documented. A company may believe its packaging is compliant, but if it cannot prove it, it may still face enforcement issues.

The workshop identifies key elements of packaging technical documentation, including:

• General description of the packaging
• Design and manufacturing details
• List of relevant standards or specifications
• Evidence of recyclability assessments
• Declaration of Conformity

The workshop also states that the declaration should be kept with the technical documentation for at least 10 years after the packaging is placed on the market.

What a packaging technical file should include

Technical documentation should be treated as a live file. It should be reviewed whenever packaging materials, suppliers, coatings, adhesives, labels, dimensions, artwork, or packaging formats change.

Compostable Packaging Requirements

Compostability is another area where companies need to be careful. Compostable packaging is not automatically preferred over recyclable packaging.

The workshop explains that certain packaging types must be compostable in industrial facilities, including tea bags, single-serve coffee pods or capsules, sticky labels attached to fruit and vegetables, and very lightweight plastic bags. It also notes that other packaging, including biodegradable plastics, must allow material recycling and must not disrupt the recycling of other waste materials.

Practical compostability checklist

Companies should avoid broad claims such as “biodegradable” or “eco-friendly” unless they are specific, supported by evidence, and aligned with applicable rules.

Packaging Minimization and Empty Space Rules

Packaging minimization is one of the most practical PPWR requirements. It affects packaging size, weight, material use, shipping efficiency, e-commerce packaging, and product presentation.

The workshop explains that packaging must be designed to use the fewest materials, weight and volume needed to protect and contain the product. It also identifies unnecessary packaging features such as double walls, false bottoms or extra layers that only make a product look bigger.

The workshop also highlights a key empty space rule: grouped packaging, transport packaging and e-commerce packaging must not contain more than 50% empty space. Fillers such as paper cuttings, air cushions, bubble wrap, foam fillers, wood wool, polystyrene and similar materials count as empty space.

Practical packaging minimization checklist

Packaging minimization should be built into packaging specifications, supplier contracts, product development, and e-commerce fulfilment processes.

Reuse, Refill and Reusable Packaging Systems

The PPWR supports a shift toward reuse and refill models. However, reusable packaging must meet specific technical and operational conditions.

The workshop explains that reusable packaging should be designed and placed on the market for multiple uses, durable enough for multiple trips or rotations, capable of being emptied or unloaded without damage, safe to refill or reload, capable of being reconditioned where needed, safe for users, and recyclable at end of life.

Reuse system requirements

Reusable packaging often needs a structured system for reuse, such as:

Companies using reusable packaging should consider:

• Collection process
• Cleaning process
• Inspection and reconditioning
• Rotation tracking
• Hygiene and safety
• Product quality protection
• End-user information
• End-of-life recyclability
• Technical documentation

For refill models, companies should inform end users about acceptable containers, hygiene standards, and health and safety responsibilities. Refill stations must comply with applicable requirements and may refuse containers that do not meet the communicated conditions.

Important 2026 update on pallet wrapping and straps

The workshop includes reuse target information for transport packaging, including pallet wrapping and straps. However, companies should note that the European Commission adopted a delegated act in February 2026 exempting wrapping and straps used to secure goods on pallets during transport from the PPWR’s 100% reuse requirement. The Commission explained that the exemption responds to feasibility concerns and avoids disproportionate adaptation costs while keeping the broader reuse target approach.

This is a good example of why companies should monitor PPWR updates continuously. Some details may change through delegated acts, implementing acts, guidance, and national implementation measures.

Restrictions on Certain Packaging Formats

The PPWR restricts certain packaging formats to reduce avoidable packaging waste. Companies should review their packaging portfolio to identify formats that may be affected.

The workshop identifies restricted packaging formats such as:

These restrictions are especially relevant for food, beverage, hospitality, cosmetics, personal care, retail and consumer goods companies.

Businesses should identify affected formats early because alternatives may require supplier qualification, packaging trials, cost analysis, consumer communication, and changes to packaging operations.

Extended Producer Responsibility and Producer Registration

Extended Producer Responsibility, or EPR, is central to packaging compliance. Under EPR, producers are responsible for financing and supporting the management of packaging waste.

The workshop explains that producers must register in the Member State where they make packaging available on the market for the first time. Producers should not make packaging available on a market if they, or their appointed representatives where applicable, are not registered in that Member State.

EPR obligations companies should assess

EPR readiness depends on accurate packaging data. Without reliable packaging weights, material composition, product mapping and country mapping, EPR reporting becomes difficult and error-prone.

Deposit and Return Systems

Deposit and Return Systems, or DRS, are important for beverage packaging and collection targets.

The workshop explains that by 1 January 2029, Member States must ensure DRS setup for single-use plastic beverage bottles up to 3 liters and single-use metal beverage containers up to 3 liters, with certain exemptions and collection-rate conditions. It also identifies requirements such as fair access, data collection, minimum deposit levels, transparency, deposit refunds, consumer convenience, return points, and clear labelling of deposit-bearing packaging.

DRS questions for companies

Beverage producers, importers and retailers should review DRS obligations early because packaging labels, barcodes, deposits and reporting systems may need operational changes.

Online Marketplace and Seller Obligations

Packaging compliance is increasingly important for online marketplaces and e-commerce sellers. Marketplaces may need to verify producer registration and collect EPR evidence before allowing sellers to place products on the market.

The workshop explains that online platforms should verify producer registration, obtain registration numbers, require self-certification, facilitate compliance, cooperate with authorities and prevent non-registered producers from selling where required. Sellers should register as producers where applicable, provide registration details, comply with EPR requirements, self-certify and provide accurate packaging data.

Marketplace readiness checklist

For companies selling online, packaging compliance is not only a back-office requirement. It can directly affect whether a product listing remains active in a market.

PPWR Data Companies Need to Collect

PPWR compliance depends on data. Companies need more than a general packaging description. They need structured information that can support compliance assessments, EPR reporting, labelling decisions, recyclability reviews, recycled content verification and technical documentation.

Core PPWR data checklist

The workshop highlights the importance of producer identification, national identification codes, packaging quantities, EPR scheme details, recycling and recovery data, deposit-return data, packaging composition, reusable packaging data and updates to registration information.

A company that cannot collect and maintain this data will struggle with PPWR compliance, even if its packaging design is technically strong.

Common PPWR Compliance Mistakes to Avoid

Many PPWR readiness gaps come from incomplete data, unclear responsibility or late preparation.

The workshop identifies formal non-compliance risks such as missing declarations, incorrect declarations, wrong or incomplete QR codes, technical documentation problems, missing information, packaging restriction violations, reusable packaging system failures, refill information gaps and reuse/refill target failures.

Practical PPWR Readiness Roadmap

Companies should approach PPWR readiness as a structured program, not a one-time legal review.

Step 1: Build a packaging inventory

List all packaging used across products, suppliers and markets. Include sales packaging, grouped packaging, transport packaging, e-commerce packaging, reusable packaging, refill packaging and service packaging.

Step 2: Map packaging to products and countries

Connect each packaging type to SKUs, product families, suppliers and EU markets.

Step 3: Collect material and weight data

Gather material composition, component weights, total packaging weights and composite material breakdown.

Step 4: Assess substance compliance

Collect declarations and test reports for heavy metals, PFAS, Substances of Concern, inks, coatings, adhesives and high-risk materials.

Step 5: Review recyclability

Assess design-for-recycling, sorting compatibility, collection compatibility, recycled-at-scale readiness and performance grades where available.

Step 6: Verify recycled content

Identify plastic packaging categories and collect recycled content evidence where applicable.

Step 7: Review labels and claims

Check sorting labels, QR codes, reusable packaging labels, recycled content labels, deposit-return labels, manufacturer information and environmental claims.

Step 8: Prepare technical documentation

Create packaging technical files with specifications, declarations, standards, test reports, assessments and conformity evidence.

Step 9: Review EPR and DRS obligations

Identify producer obligations, registration needs, PRO participation, appointed representatives, DRS requirements and annual reporting duties.

Step 10: Monitor PPWR updates

Track delegated acts, implementing acts, guidance documents, FAQs and national measures. The PPWR implementation process is ongoing, and companies should keep their compliance assessments updated.

How ComplyMarket Supports EU PPWR Compliance

PPWR compliance requires more than understanding the regulation. Companies need a system to manage packaging data, supplier evidence, regulatory obligations, technical documentation, EPR requirements and country-specific updates.

ComplyMarket supports companies with product compliance, sustainability reporting, material compliance, packaging compliance, Extended Producer Responsibility services, Digital Product Passport readiness and global market access. The attached workshop identifies ComplyMarket’s capabilities across product compliance management software, sustainability reporting software, material compliance software, packaging compliance, EPR services, Digital Product Passport and global market access.

ComplyMarket’s packaging compliance service page also explains that packaging requirements can affect primary, secondary and tertiary packaging, as well as plastic, metal, paper, cardboard, glass, wood, labels, inks, coatings, adhesives and other packaging components. It also highlights that packaging compliance may include labelling, substance restrictions, recycling obligations, registration, reporting, documentation, recyclability and EPR obligations.

ComplyMarket can help companies prepare for PPWR by supporting

• Identification of applicable packaging compliance requirements
• Country-specific packaging obligation tracking
• Packaging material and component data management
• Supplier declaration and evidence collection
• Substance compliance evidence for packaging materials
• Recyclability and recycled content documentation
• Technical documentation and conformity evidence management
• EPR registration and reporting preparation
• Packaging labelling and documentation control
• Digital Product Passport and circular economy data readiness
• Cross-functional visibility for compliance, sustainability, procurement and product teams

For companies selling across multiple EU markets, the challenge is not only knowing what the PPWR says. The real challenge is proving compliance, keeping packaging data updated, responding to customer or authority requests, and managing obligations across many suppliers, materials, products and jurisdictions.

ComplyMarket helps businesses move from fragmented packaging compliance work to a more structured, traceable and scalable compliance process.