EU PPWR Packaging Rules: What Manufacturers and Importers Need to Know

The EU’s new Packaging and Packaging Waste Regulation (PPWR) is now in effect. If you manufacture or source products in China and sell products into the EU, your packaging is now part of your compliance considerations. From 12 August 2026, Regulation (EU) 2025/40 establishes harmonised requirements for packaging and packaging waste across the European Union. This regulation covers areas including packaging composition, recyclability, substances of concern, documentation, labelling, reuse and waste management.

However, the PPWR is not a single deadline. Different requirements apply at different dates, with some obligations taking effect from 12 August 2026 and others being introduced progressively through 2028, 2030 and beyond.

For manufacturers, importers and businesses sourcing products from China and other countries outside the EU, these changes can affect how packaging is specified, documented and managed throughout the supply chain.

Understanding what applies now, what will be phased in later, and what information needs to be obtained from suppliers, can help businesses avoid unnecessary packaging changes and last-minute compliance problems.

What is the PPWR?

The Packaging and Packaging Waste Regulation (PPWR) is the EU’s new framework for packaging and packaging waste.

Regulation (EU) 2025/40 replaces the previous EU Packaging and Packaging Waste Directive and establishes a more harmonised framework for packaging across the EU.

The regulation applies to packaging placed on the EU market, with specific provisions depending on the type and use of the packaging.

The regulation addresses areas including:

• Packaging design and composition

• Recyclability

• Recycled content

• Substances of concern

• Packaging waste prevention

• Reuse and refill

• Packaging labelling

• Technical documentation and conformity

• Packaging waste management

The European Commission’s guidance on the PPWR provides further clarification on how the regulation applies to various packaging categories and economic operators, which is particularly relevant for businesses importing products from outside the EU.

Packaging specifications, material choices and supporting documentation may therefore need to be considered alongside the wider product development and supply chain process, rather than being addressed solely when the final product is ready for shipment.

What applies from 12 August 2026?

1. Restrictions on certain substances in packaging

The PPWR introduces requirements relating to substances of concern in packaging and packaging components.

For example, the Regulation (EU) 2025/40 sets a maximum combined concentration of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium in packaging or packaging components 

The PPWR also introduces specific restrictions on PFAS in food-contact packaging.

From 12 August 2026, food-contact packaging cannot be placed on the EU market if the PFAS concentrations are equal to or exceed the limits specified in the regulation. These limits include:

• 25 ppb for any individual PFAS

• 250 ppb for the sum of PFAS measured through targeted analysis, and

• 50 ppm for PFAS including polymeric PFAS.

The precise application of these provisions depends on the conditions and definitions set out in the Regulation and related Commission guidance.

For manufacturers and importers, this raises a practical question:

Do you have enough information from your packaging supplier to identify what materials and substances are being used in your packaging?

Where packaging is sourced through a manufacturing partner, obtaining relevant material information and supporting evidence can be an important part of demonstrating compliance.

2. Packaging must meet the general recyclability requirement

The PPWR establishes a general requirement for packaging placed on the EU to meet the applicable recyclability requirements.

The European Commission’s PPWR guidance confirms that the general recyclability requirement in Article 6 applies from 12 August 2026.

However, the detailed design-for-recycling criteria and recyclability performance grades are being introduced progressively, with additional requirements applying from later dates.

For businesses developing new products, this means packaging design should be considered with both current and future requirements in mind.

A packaging format may meet the requirements that apply today while still needing to adapt as the later PPWR requirements come into effect.

3. Technical documentation and conformity

The PPWR also introduces requirements relating to conformity assessment and technical documentation.

Manufacturers are required to prepare technical documentation demonstrating compliance with the applicable requirements. The Regulation specifies the necessary information to be included, such as details concerning the packaging, its materials and the relevant conformity assessment. Regulation (EU) 2025/40 establishes these requirements.

Importers also have responsibilities. Before placing packaging on the EU market, importers must ensure that the required conformity assessment has been carried out, that the manufacturer has prepared the technical documentation and EU declaration of conformity where required, and that applicable labelling and identification requirements have been met.

For businesses sourcing products from outside the EU, this makes supplier documentation an important part of the packaging compliance process.

Instead of simply asking a supplier, “Is this packaging compliant?”, it can be more useful to establish:

• What materials are being used?

• What is the material composition?

• What recycled content is included?

• Are restricted substances present?

• What testing has been carried out?

• What declarations or technical specifications are available?

• Can the supplier provide evidence supporting the relevant compliance claims?
  

The exact documentation required will depend on the packaging and the applicable PPWR provisions.

What does not start immediately?

One of the most important points to understand about the PPWR is that 12 August 2026 is not a deadline for every requirement. 

Several significant requirements come into effect later.

Harmonised EU packaging sorting labels

The new harmonised EU label for packaging material composition and consumer sorting is scheduled to apply from 12 August 2028, or 24 months after the relevant implementing acts come into force, whichever is later. Regulation (EU) 2025/40 establishes this timetable.

The PPWR does not imply that every package needs to carry the new harmonised EU sorting label immediately.

For companies currently reviewing packaging artwork, this distinction matters.

The European Commission’s guidance also clarifies the scope of the harmonised labelling requirements and the later timetable for reusable-packaging labelling. Businesses should therefore avoid making packaging artwork changes solely on the assumption that the new sorting label is already mandatory.

Empty-space requirements

The PPWR also introduces measures aimed at reducing unnecessary empty space in packaging.

From 12 February 2028, economic operators who fill sales packaging must ensure that empty space is reduced to the minimum necessary for the functionality of the packaging, including product protection. Regulation (EU) 2025/40 specifies how the empty-space ratio for sales packaging is calculated and how filling materials are treated. 

A separate 50% maximum empty-space ratio will apply later to grouped packaging, transport packaging and certain e-commerce packaging, subject to the specific rules and exemptions in the Regulation.

Under the current Regulation, this requirement is scheduled to apply from 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later.

The Regulation also specifies that filling materials such as paper cuttings, air cushions, bubble wrap, sponge fillers, foam fillers, wood wool and polystyrene chips are considered empty space when calculating the ratio.

For manufacturers and e-commerce businesses, these rules could eventually make packaging dimensions and pack-out design an even more important part of product and logistics planning.

Reusable transport packaging

The PPWR introduces reuse targets for certain transport packaging. From 1 January 2030, economic operators using specified transport packaging, or sales packaging used for transporting products within the EU, will generally need to ensure that at least 40% of that packaging is reusable within a reuse system, subject to the specific conditions and exemptions outlined in the Regulation.

The Regulation also introduces stricter reuse requirements for certain transport between sites of the same company, linked or partner enterprises, and deliveries to another economic operator within the same Member State.

Specific exemptions and subsequent Commission measures apply to certain packaging formats and situations. Regulation (EU) 2025/40 establishes the relevant requirements.

From 1 January 2040, the relevant economic operators must endeavour to use at least 70% of the specified transport packaging in a reusable format within a reuse system. This is an objective to endeavour to achieve rather than a mandatory 70% requirement.

These targets therefore represent future changes rather than requirements that suddenly take effect on 12 August 2026.

What actions should manufacturers and importers take now?

Businesses sourcing products from China or other countries outside the EU do not necessarily need to redesign every package immediately.

A more effective approach is to establish what packaging you currently use, what evidence you already have, and which future PPWR requirements could affect your products.

A. Review your packaging specifications

Start by identifying every packaging component supplied with your products.

This could include:

• Product packaging

• Protective inserts

• Bags and films

• Boxes and cartons

• Transport packaging

• Pallets and pallet wrapping

• Other packaging supplied with the product
  

Assess whether the materials, construction and design meet the current requirements and whether future PPWR requirements could impact the existing design.

B. Ask suppliers for supporting information

Speak to your packaging and manufacturing suppliers about the information they can provide to support your compliance assessment. Depending on the packaging, this could include:

• Material composition

• Relevant test results

• Declarations

• Technical specifications

• Information on recycled content

• Evidence relating to restricted substances
  

The specific documentation required will vary based on the packaging and the applicable requirements.

The important point is to establish what evidence is available rather than relying solely on a generic statement of compliance.

C. Review packaging as part of product development

Packaging decisions can affect considerably more than regulatory compliance.

Changing packaging materials, dimensions or construction can affect:

• Product protection

• Transport efficiency

• Palletisation

• Storage

• Packing and assembly processes

• Shipping costs

• Supplier processes

• Product documentation

Considering these factors during product development gives businesses more opportunity to make changes before production is finalized.

D.  Understand your role in the supply chain

Businesses should establish which PPWR obligations apply to them.

Depending on the arrangement, responsibilities can involve manufacturers, importers, distributors and other economic operators.

For businesses importing products into the EU, understanding where the packaged product is first placed on the EU market and which party is responsible for the relevant obligations is important when assessing compliance.

What does the PPWR mean for products manufactured in China?

For businesses manufacturing products in China and selling them in the EU, the PPWR makes communication with packaging and manufacturing suppliers increasingly important. The packaging may have been designed and manufactured outside the EU, but where the packaged product is placed on the EU market, the PPWR may apply.

This means EU compliance should not be treated as something that begins when the shipment reaches Europe.

Businesses should consider PPWR requirements when:

• Choosing packaging materials

• Designing new products

• Developing packaging artwork

• Approving supplier specifications

• Reviewing existing packaging

• Requesting compliance documentation

• Planning future product changes
  

A useful supplier conversation might therefore include questions such as:

• What materials are used in each packaging component?

• Can you provide the material specifications and relevant test evidence?

• Does the packaging include any substances that are restricted under the PPWR? 

• What percentage of recycled content is present in the packaging, if applicable? 

• Can you provide documentation that supports the compliance claims made?

• Could the packaging design be adapted if future EU requirements require changes?
  

These questions can help turn regulatory compliance into a structured part of supplier management rather than a last-minute request.

Conclusion: Looking beyond 12 August 2026

The PPWR is not a single packaging change with one deadline.

The regulation introduces requirements with different application dates extending into the coming years.

For businesses manufacturing or sourcing products outside the EU, the immediate priority is to understand which requirements apply to their packaging and role in the supply chain, review existing packaging specifications and documentation, and discuss future requirements with suppliers. The later requirements also give businesses time to plan.

Changes in packaging can affect product protection, logistics, manufacturing processes, supplier specifications and costs. Addressing them early allows these factors to be considered together rather than requiring last-minute changes when a new requirement becomes mandatory.

As the implementation of the PPWR progresses, companies should keep an eye on the European Commission’s packaging and packaging waste guidance and update their packaging specifications and compliance processes accordingly.

Frequently Asked Questions

1. What is the EU Packaging and Packaging Waste Regulation (PPWR)?

The PPWR, identified as Regulation (EU) 2025/40, establishes requirements for packaging and packaging waste across the EU. It covers areas such as packaging composition, recyclability, substances of concern, labelling, reuse and waste prevention. The Regulation applies from 12 August 2026, although individual requirements have different application dates.

2. Can the PPWR apply to products manufactured outside the EU?

Yes. The PPWR can apply to packaging associated with products manufactured outside the EU when those products are placed on the EU market. The specific obligations depend on the role of the business and the type and use of the packaging.

For businesses importing products into the EU, understanding their responsibilities and obtaining the necessary information from manufacturers and suppliers is therefore important. 3. Do all PPWR requirements apply from 12 August 2026?

No. While 12 August 2026 is the date from which the Regulation generally applies, individual requirements have different implementation timelines.

For example, harmonised packaging sorting labels are generally scheduled to apply from 12 August 2028 or 24 months after the relevant implementing acts come into force, whichever is later. Other requirements, including certain empty-space and reuse provisions, will take effect later.

4. Does packaging need to be recyclable from 12 August 2026?

The PPWR establishes a general recyclability requirement that applies from 12 August 2026. However, the more detailed recyclability requirements and performance grades are being introduced progressively.

Businesses should therefore distinguish between the general requirement that applies now and the more detailed requirements that will come into effect later.

5. Does the PPWR restrict PFAS in packaging?

Yes. The PPWR introduces specific restrictions on PFAS in food-contact packaging, with the relevant limits taking effect from 12 August 2026, subject to the thresholds and conditions set out in the Regulation.

Businesses using food-contact packaging should obtain appropriate information about the materials and substances used by their packaging suppliers.

6. What are the PPWR rules regarding empty space in packaging?

The PPWR introduces different requirements depending on the type of packaging.

From 12 February 2028, economic operators filling sales packaging must reduce empty space to the minimum necessary for the functionality of the packaging.

A separate 50% maximum empty-space ratio will apply later to grouped packaging, transport packaging and e-commerce packaging, subject to the specific rules and exemptions in the Regulation.

7. Will the PPWR affect packaging sourced from China?

Yes. Where products manufactured in China are placed on the EU market, the PPWR may apply to the packaging associated with those products. For transport-packaging reuse targets, the Commission's guidance clarifies that the relevant requirements apply to imported goods after they have been placed on the EU market, typically from the first EU warehouse where the goods are intended for onward distribution within the EU.

This makes communication with Chinese packaging and manufacturing suppliers particularly important when businesses need information about material composition, restricted substances, recyclability or technical documentation. 8. When do the PPWR reuse targets for transport packaging come into effect?

From 1 January 2030, certain economic operators using specified transport packaging or sales packaging used for transport within the EU must ensure that at least 40% of that packaging is reusable within a reuse system, subject to the conditions and exemptions outlined in the Regulation. 

Additional reuse requirements apply to certain intra-company, linked-company and same-Member-State transport. 

From 1 January 2040, the relevant operators must endeavour to use at least 70% of the specified transport packaging in a reusable format.

These targets should be assessed alongside the specific conditions, exemptions and subsequent measures applicable to the packaging concerned.