PPWR stands for “Packaging and Packaging Waste Regulation”. It’s a piece of EU legislation closely linked to EPR (Extended Producer Responsibility) and supersedes the existing Packaging Waste Directive. However, some rules from the Directive will still be effective. PPWR came into force in February 2025 but broadly speaking, the real-world application begins on the 12 of August 2026.
PPWR covers all packaging and packaging waste in the EU market. The rules it introduces can be split into two broad categories:
If you sell anything in packaging to the EU, PPWR is likely to affect you and your business.
The Packaging and Packaging Waste Regulation has three main goals:
Together, these aims should move the EU closer to achieving a circular, sustainable economy. The end goal is climate neutrality by the end of 2050. In real-world terms the plan is to reduce the EU’s reliance on fossil fuels and cut the amount of plastic in our rivers and seas.
Let’s look at the specific targets set by the packaging regulation.
Packaging made of plastic will need to be made at least in part from recycled post-consumer plastic. The specific percentage can be set by the Member State, so what the minimum quantity is will vary by country. There are some exceptions to this, like packaging that contains food for infants, pharmaceuticals and compostable plastics.
The deadline for compostable packaging is a little later – not until February 2028. That’s because the EU is going to be setting a composting standard. Your packaging won’t be considered compostable unless it meets that standard. Member States have the power to require certain types of packaging to be compostable (like stickers on fruit, for example). The composting standard will be based on industrially controlled conditions in bio-waste facilities. Member States can also raise the bar to require compostable packaging to be compostable by consumers at home.
Functional-first design is going to be the law. You need to design packaging to reduce weight and volume as much as possible, whilst maintaining its functionality.
This rule also targets deceptive packaging. You will no longer be able to sell goods in packaging that disguises how much product buyers are actually getting. Things like false bottoms and double walls are out.
Marketing, or the fact that shoppers are used to a certain kind of packaging aren’t valid reasons to ignore this rule. However, there are some exceptions. The two main examples are:
I once ordered a pack of ink cartridges for a fountain pen. They arrived in a cardboard box big enough for our very fat cat to sleep in. PPWR is aiming to make that experience a thing of the past. By 2028, empty space needs to be reduced to a minimum. Filing a box with paper, air cushions or packing peanuts won’t work either – they're all considered empty space too. Right sizing your packaging is turning into a necessity.
PPWR also adds targets to make certain kinds of packaging reusable. Namely, beverage containers and transport packaging. Here, transport packaging refers to things like pallets, boxes, trays and crates, especially those made of plastic.
In the context of the Packaging and Packaging Waste Regulation, reusable packaging must:
There are a lot of specific exceptions to this rule. For example, containers for milk products, or transport packaging for dangerous goods.
Reusable packaging targets are where PPWR most closely lines up with the classic understanding of Extended Producer Responsibility (EPR). The final distributor will be expected to contribute to the cost of achieving these targets. However, we won’t know the details of that until 2027, when the guidance is due to be published.
There are several Extended Producer Responsibility (EPR) elements baked into the PPWR. If you’re considered a “producer”, you have to be registered for the EPR schemes in the countries you sell to. Previously, EPR enforcement could have been considered somewhat lax (a problem not unique to the EU). PPWR makes EPR more cohesive across the single market and stricter in its enforcement.
EPR registrations come with a reporting requirement. You have to provide the authorities data about your packaging, including:
This information informs the compliance fee. Now, PPWR links the design of packaging to its cost. You’ll have to contribute more towards the cost of dealing with packaging waste that’s harder to recycle or safely dispose of.
Ecommerce is specifically mentioned in the Packaging and Packaging Waste Regulations several times. There’s no doubt that it will impact your business. Here’s a look at some things you can do now to get prepared.
Take a look at what your current packaging – both what your products are sold and shipped in. This step is important as it’s the basis of all your compliance. Consider what your packaging is made of. It will need to meet the weight and recycling requirements. Depending on the countries you ship to, the materials your packaging is made of might trigger more than one EPR regulation.
When it comes to redesign, look for ways you can reduce:
The design phase is where you need to make sure your packaging is truly reflective of the volume of the product. Get rid of double walls and false floors.
Make a list of all the countries in the EU you currently ship to. If you’ve got plans to expand, add the new markets to the list. For each country you need to work out what your role is (producer, importer, distributor) and what obligations that creates for you. If you’re an Amazon seller, you might be able to take advantage of Pay on Behalf.
You can’t get PPWR right without the help of your suppliers and partners. You need to know that your packaging supplier is following your design specifications. If you’re partnered with a 3PL or logistics supplier to ship to the EU, you’ll need to work with them to eliminate empty space.
