The PPWR Regulation – what do you need to know about EU packaging regulations?

The PPWR Regulation is a new EU law on packaging and packaging waste, which changes the way packaging is designed, labelled, placed on the market and accounted for within the European Union. It covers not only packaging manufacturers, but also importers, brand owners, distributors, online retailers and companies that dispatch products in packaging.

The PPWR, or Packaging and Packaging Waste Regulation, came into force on 11 February 2025, and its provisions will generally apply from 12 August 2026. For businesses, this means they must check whether the packaging they use meets the requirements regarding recyclability, material composition, labelling, weight minimisation, recycled content and reusability.

If your company manufactures, imports, packages, repackages or sells products on the EU market, the PPWR is not some distant legal change. It is an issue that should already be included in your environmental and operational compliance plan.

What is the PPWR Regulation?

PPWR stands for the Packaging and Packaging Waste Regulation, i.e. the European Union regulation on packaging and packaging waste. The full title of the legislation is Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste.

The most significant change is that the PPWR is a regulation, not a directive. A directive requires transposition into national law, which meant that differences in interpretation and practice could arise between individual EU Member States. A regulation is directly applicable and is intended to harmonise packaging requirements across the entire EU market.

The PPWR is intended to ensure that packaging placed on the EU market is designed with recycling, reuse, waste reduction and lower consumption of virgin raw materials in mind.

For businesses, this means a shift from viewing packaging as a „logistics cost” to seeing it as a „key element of legal, environmental and product compliance”. In practice, packaging must be treated with the same seriousness as product labelling, technical documentation or reporting obligations.

Why is the European Union introducing new packaging regulations?

The new EU packaging regulations are a response to the growing volume of packaging waste, the poor quality of some recycling streams, the problem of excessive packaging, and the lack of uniform rules for companies operating across several European markets.

Until now, businesses have often had to contend with fragmented requirements: different labelling rules, different registration systems, different reporting obligations and varying levels of enforcement across Member States. The PPWR aims to reduce this confusion and establish a common framework for the design, use and accounting of packaging.

It is not just about recycling. PPWR covers the entire life cycle of packaging: from design and material selection, through production, logistics, sales and consumer use, right through to collection, sorting and waste treatment.

Who is the PPWR aimed at?

The PPWR applies to a wide range of businesses operating within the European Union. It is not a regulation intended solely for packaging manufacturers.

The new obligations may relate, amongst other things, to:

– packaging manufacturers,
– manufacturers of products sold in packaging,
– importers of products from outside the EU,
– owners of own-brand products,
– distributors and wholesalers,
– online shops,
– e-commerce platforms,
– logistics and fulfilment companies,
– businesses that use individual, bulk or transport packaging.

If a company places a product in packaging on the EU market, it should determine its role in the supply chain. The packaging manufacturer, the importer, the brand owner and the online retailer using shipping packaging may each have different obligations.

Companies that sell products outside Poland should combine their PPWR analysis with an assessment of the obligations in individual EU markets. The following may be helpful in this regard compliance with packaging requirements in EU markets, particularly when a company operates in several countries and has to take into account local registration and reporting systems, as well as recovery organisations.

The first step in the preparation process should not be to replace all packaging straight away, but to carry out a risk assessment. That is precisely what this is for PPWR audit, which enables packaging to be assessed in terms of its design, composition, recyclability, labelling and compliance with environmental and legal requirements.

What types of packaging does the PPWR cover?

The PPWR covers packaging placed on the EU market, regardless of material, sector or origin. The analysis should cover both unit packaging visible to the consumer and collective, transport and dispatch packaging.

In practice, this means that the company should check, amongst other things:

– plastic packaging,
– paper and cardboard packaging,
– glass containers,
– metal packaging,
– wooden packaging,
– multi-material packaging,
– transport packaging,
– shipping boxes,
– films, tapes, labels and fillers,
– packaging used in e-commerce, retail, manufacturing, catering and logistics.

The following require particular attention multi-material packaging, as their recyclability depends not only on the predominant material, but also on the layers, coatings, laminates, adhesives, dyes, labels and the feasibility of separating the individual fractions.

The greatest risk of PPWR arises where packaging consists of multiple materials, is difficult to sort, is overly complex, or bears environmental claims without reliable supporting documentation.

The key obligations under the PPWR

The PPWR introduces a number of requirements, but from a business owner’s perspective, the most important ones are those that affect packaging design, procurement, production, logistics, sales, marketing and documentation.

Recyclability of packaging

One of the key principles of the PPWR is that packaging placed on the EU market should be designed with recycling in mind. The mere fact that packaging is made from a „recyclable” material is not necessarily enough. What matters is the actual ability to collect, sort and process the packaging within a functioning waste management system.

Example: a cardboard box with extensive finishing – such as film, a plastic window, varnish and permanent adhesives – may be considerably more difficult to recycle than simpler packaging made from a single dominant material. In PPWR, packaging design becomes part of the compliance strategy.

Recycled content

The PPWR provides for an increase in the proportion of recycled materials used in certain types of packaging, particularly plastic packaging. This requirement could be of significant importance to manufacturers, importers and brand owners who use large volumes of plastic packaging.

The issue is not merely purchasing packaging made from recycled material. The company should also have documentation confirming the type of material, the proportion of recycled content, the technical specifications and compliance with the requirements for the specific application, particularly where the packaging comes into contact with food, cosmetics or sensitive products.

Minimising packaging

The PPWR restricts practices whereby packaging is larger, heavier or more elaborate than is necessary for its actual protective, logistical or informational function. Excessive packaging can give rise to regulatory risks, but also cost risks: greater packaging weight means higher costs for materials, transport and environmental charges.

For businesses, this means they need to check that packaging does not contain unnecessary layers, excess space, excessive fillers or elements that serve primarily a marketing purpose without any technical justification.

Labelling of packaging

The PPWR is also intended to standardise packaging labelling. The aim is to make it easier for consumers to sort their waste and to reduce unclear, contradictory or misleading environmental messages.

The company should check whether the labelling corresponds to the actual composition of the packaging and whether the environmental claims made can be substantiated. This applies in particular to terms such as „eco”, „organic”, „recycling”, „made from recycled material”, „environmentally friendly” or „suitable for recycling”.

Any environmental claim on the packaging should be supported by documentation, a bill of materials or reliable confirmation from the supplier.

Reusable packaging and refills

The PPWR reinforces the importance of solutions based on reuse and refill. Not every sector will face the same obligations, but the regulatory direction is clear: where packaging can be reused multiple times, companies should explore such models.

However, introducing reusable packaging is not simply a matter of changing the material. A system is needed: for returns, cleaning, quality control, labelling, logistics and record-keeping. Without this, reuse may increase operating costs rather than reduce them.

PPWR and e-commerce – why should online shops get a head start?

The PPWR is of particular importance to e-commerce, as every product dispatch involves the use of packaging: cardboard boxes, envelopes, film, tape, labels, void-fill material or returnable packaging. An online shop may therefore be subject to packaging obligations even if it does not manufacture the packaging itself.

Online retailers should check:

– what kind of packaging do they use for dispatch,
– aren’t the boxes too big for the products,
– what kind of filling materials are used in parcels,
– are the packaging items easy to sort,
– whether the materials used have a verified composition,
– do overseas sales give rise to additional registration obligations,
– whether the company is correctly recording packaging in BDO and foreign systems.

A good starting point for online shops is e-commerce audit, which enables you to analyse sales, packaging and dispatch processes in terms of environmental responsibilities. The broader context of international sales is also explored in an article on how to account for Packaging in e-commerce: BDO and LUCID.

PPWR, BDO and LUCID, and packaging obligations in the EU

The PPWR does not automatically replace national registration, reporting and accounting obligations. A company must still analyse the requirements of the countries into which it imports packaged products.

In Poland, BDO remains an important point of reference; this is a system relating, amongst other things, to record-keeping, reporting and obligations concerning packaging and waste. The VerpackG and LUCID are of particular importance for sales to Germany.

If a company sells products to the German market, it should check whether registration with the German LUCID system is required and whether its current sales model meets the requirements of the German packaging scheme. The following may be helpful: LUCID audit, particularly for businesses that ship products to Germany or use online marketplaces.

The PPWR should be regarded as an EU-level framework that sets out the requirements for packaging, but does not exempt businesses from analysing their national obligations.

How can you prepare your company for the PPWR?

The best way to prepare for PPWR starts with the data. A company should know what packaging it uses, what materials it is made from, who supplies it, which markets it is destined for, and what documents confirm its specifications.

1. Carry out an inventory of packaging

The first step is to draw up a list of all packaging types: unit, bulk, transport and dispatch packaging. It is worth taking into account the weight, material, structure, supplier, intended use, target market and volume.

Without such an inventory, the company does not know which packaging is neutral and which poses legal, environmental or cost risks.

2. Determine the company’s role in the supply chain

The packaging manufacturer, product importer, distributor, e-commerce retailer and brand owner may have different obligations. A mistake in determining their respective roles leads to an incorrect assessment of liability.

Example: An online shop may not manufacture packaging itself, but it uses cardboard boxes, labels, film, tape and packing materials. This is enough to make the PPWR a matter of practical importance to it.

3. Assess recyclability and material composition

Particular attention must be paid to packaging made of multiple materials, varnished, laminated, coloured, difficult to separate, or containing elements that interfere with sorting.

Sometimes, improving compliance does not require a complete redesign of the packaging. It may be enough simply to remove the problematic component, change the label, reduce the level of finishing, or choose a simpler material.

4. Check the labelling and environmental declarations

Labels, pictograms, waste sorting instructions and environmental slogans should reflect reality. The risk increases when marketing claims go beyond what is supported by the documentation.

A good follow-up question is: can the company substantiate every environmental claim made on the packaging?

5. Check the documentation provided by suppliers

Packaging suppliers should provide information on composition, materials, recycled content, chemical substances, recyclability and compliance with the requirements for a specific application.

The absence of documentation does not always mean that the packaging is non-compliant, but it does indicate a lack of readiness to demonstrate compliance.

6. Combine PPWR with an environmental audit

PPWR affects many areas of the business: procurement, logistics, production, warehousing, sales, compliance and reporting. It is therefore worth combining the analysis of packaging with a broader environmental audit, which enables the assessment of the flow of materials, packaging, waste and documentation throughout the organisation.

If a company does not have an in-house environmental compliance department, one solution could be a permanent environmental consultancy for businesses, including an analysis of obligations, documentation, records, reports and regulatory changes.

PPWR as part of the circular economy

The PPWR is not a single change to packaging legislation. It is part of a broader transition from a linear model to a circular economy, in which packaging is to be designed with a view to reuse, recycling and reducing the consumption of virgin raw materials.

For businesses, this means a change in the way they make purchasing decisions. The cheapest packaging option on the invoice will not always be the cheapest over the product’s entire life cycle. If it generates higher reporting costs, recycling difficulties, labelling risks or problems in foreign markets, it may become a source of hidden costs.

The PPWR concept ties in well with the circular economy approach. You can read more about this model in the section on circular economy, which shows how companies can reduce their resource consumption and design more environmentally efficient processes.

PPWR risk map for businesses

The risks associated with PPWRs can be divided into five categories.

The first category is design-related risk. The packaging is too complex, difficult to recycle or excessive in relation to the function it is intended to fulfil.

The second category is material risk. The packaging contains problematic substances, its composition has not been verified, or it does not meet the requirements for recycled material.

The third category is labelling risk. Labels are unclear, inconsistent from one country to another, or contain unsubstantiated environmental claims.

The fourth category is documentation risk. The company does not have data from suppliers, declarations of conformity, material specifications or procedures for updating documentation.

The fifth category is organisational risk. No one in the company has overall responsibility for packaging, and decision-making is spread across the purchasing, marketing, production and logistics departments.

The PPWR is a packaging regulation, but its implications are organisational: a company must integrate technical, legal, environmental and operational data into a single decision-making system.

Why is it worth carrying out a PPWR audit in good time?

The worst time to analyse packaging is when a new product already has a finalised design, a selected supplier, an approved label and a planned sales campaign. At that stage, any change means extra costs, delays or conflict between departments.

A PPWR audit carried out previously enables:

– to identify which packaging requires changes,
– assess regulatory risk,
– prepare documentation for suppliers and customers,
– check that the labelling is correct,
– identify problematic packaging,
– plan changes to materials without causing chaos in the procurement process,
– to align the PPWR with national and EU obligations.

In practice PPWR audit It should be regarded as a decision-making tool for senior management, procurement, production, logistics, sales and marketing. It enables users to identify which packaging is safe, which requires modification, and which may pose a significant risk once new requirements come into force.

Frequently asked questions

Since when has the PPWR been in force?

The PPWR came into force on 11 February 2025, and its provisions will, in principle, apply from 12 August 2026. Some of the requirements will be implemented in stages over the coming years, including those relating to recyclability, recycled content, labelling and reuse.

Does the PPWR apply only to packaging manufacturers?

No. The PPWR may apply to packaging manufacturers, product manufacturers, importers, distributors, brand owners, online shops and companies that use transport or shipping packaging.

Will paper packaging always comply with the PPWR?

No. The material itself does not determine whether it is recyclable. Paper packaging can be problematic if it is coated, laminated, permanently bonded to other materials, or difficult to recycle effectively.

Does an online shop have to analyse PPWR?

Yes, if they use packaging to dispatch products or place packaged products on the EU market. E-commerce businesses should pay particular attention to checking cartons, envelopes, plastic film, packing materials, labels and returnable packaging.

Does PPWR mean that all packaging must be replaced immediately?

Not always. An analysis needs to be carried out first. Some packaging may only require adjustments to the labelling or documentation, whilst others may require more substantial changes to the materials or design.

How do I start preparing for the PPWR?

It is best to start by carrying out an inventory of packaging, determining the company’s role in the supply chain, gathering documentation from suppliers and conducting a compliance audit. This helps to distinguish between genuine risks and apparent problems.

Do you need help preparing your business for the PPWR?

If your company manufactures, imports, packages, repackages, dispatches or sells packaged products on the European Union market, the PPWR should already be included in your compliance plan.

The EKOPRO GROUP helps companies assess their packaging obligations, prepare the necessary documentation and plan their actions ahead of the introduction of new requirements. Find out more PPWR audit or go straight to the tab Contact Eko-Pro and describe your company’s situation.