What is the PPWR? The new Packaging Ordinance explained for business owners

Packaging Regulation: what will change for those selling products in the EU?

The rules on packaging in the EU are about to undergo a major overhaul. The new Packaging Regulation, officially the Packaging and Packaging Waste Regulation, or PPWR for short (Regulation (EU) 2025/40), replaces the old 1994 Packaging Directive and imposes requirements on almost every package that enters the European market. From the box around your product to the padding material, the tape and the pallet underneath.

Do you sell through your own webshop, through marketplaces like Bol or Amazon, or import products from outside the EU? Then the PPWR is not “something for packaging manufacturers,” but something that affects you directly in your packaging design, documentation and registration obligations.

Why is there going to be new legislation?

For years, packaging waste has been growing faster than we can recycle it. The EU wants to reverse that trend and is heading for packaging that is fully recyclable, uses less material and contains more recycled material. The old Packaging Directive left too much room for this: as a directive, it was translated differently by each member state, resulting in 27 different interpretations.

The PPWR puts an end to that. As a regulation, it applies directly and identically in all EU countries, with no national transposition and no differences in interpretation. This creates a level playing field, but also less latitude: the requirements are the same for everyone and are more strictly enforced.

Specifically, what will change?

Packaging must become recyclable

At the heart of the PPWR: from 2030, virtually all packaging on the EU market must be recyclable according to established design for recycling criteria. Packaging that does not comply will soon be banned from the market. From 2038 the requirements will be even stricter and will also count whether a material is actually collected and recycled on a large scale.

Minimum percentages of recycled material in plastic

Plastic packaging must contain a minimum proportion of recycled material. These percentages increase toward 2030 and vary by type of packaging and application. For those who use plastic, this means you must be able to prove to your supplier how much recyclate is actually in it.

Packaging minimization: as little material as possible

Redundant packaging is being curbed. Think of empty space in boxes, double layers of packaging and deceptively large packaging. You must be able to substantiate that your packaging is no heavier or larger than functionally necessary.

Mitigation of substances of concern

The PPWR restricts certain substances in packaging materials, including PFAS in food contact packaging and heavy metals. This particularly affects those who use packaging that comes into contact with food.

Labeling with sorting symbols

Packaging will have harmonized labels indicating what material it is made of and how consumers should separate it. This should make sorting easier and more uniform throughout the EU.

Producer registration and EPR

Anyone who puts packaging on the market must register in every state where it is done and is subject to extended producer responsibility (EPR). You then help pay for the collection and treatment of the packaging waste you generate.

Who does the PPWR apply to?

The PPWR affects virtually every link in the chain, not just packaging manufacturers. Manufacturers of packaged products are covered, even if you buy the packaging yourself. So do importers who source packaged products from outside the EU, as do distributors and retailers who resupply within the EU, and web shops and marketplace vendors who sell remotely to EU consumers. In practice, one company often carries multiple roles simultaneously. And each role brings its own obligations.

When does the PPWR go into effect?

The PPWR is already enacted and in effect. General application will begin on Aug. 12, 2026. From then on, the first obligations will apply. After that, the more stringent requirements phase in, with key milestones toward 2030 (recyclability and recycled material) and 2038 (stricter recycling criteria).

That seems a long way off, but for business owners with many SKUs, multiple packaging types or multiple suppliers, 2026 is fast in practice. Changing packaging design, requesting recyclate data from suppliers and registering in multiple states almost always takes more time than you think beforehand.

FAQ for entrepreneurs

I simply purchase my packaging. So does the PPWR apply to me?

Yes. If you put a packaged product on the EU market, you are generally responsible for the PPWR compliance of that packaging, even if a supplier makes it for you. You must then be able to prove that the packaging is compliant, which means you have to request the appropriate information and declarations from your supplier.

I sell through marketplaces. Is this getting stricter?

It probably will. Marketplaces are already moving toward stricter document checks and intervening more quickly on non-compliant products. As the PPWR deadlines approach, platforms are likely to start testing for packaging as well. Those dependent on listings will want to get this in order sooner than later.

Does it include transport packaging and padding?

Yes. The PPWR has several categories, namely primary (sales) packaging, secondary (collection) packaging and transport packaging, and almost everything falls into scope. However, there are different requirements per category and sometimes exceptions, for example around recycled material in transport packaging.

Do I really have to register separately in each EU country?

For the countries where you market packaging: yes. Producer registration and EPR obligations are regulated per member state. If you sell across borders, you may be subject to registration requirements in multiple countries.

What happens if I don’t comply?

Non-compliant packaging is not allowed to enter the EU market (anymore). You also risk enforcement by market regulators, possible fines and removal of your products from platforms. The reputation risk towards customers adds up.

How do I know where to start now?

With a scope check: mapping out what packaging you use, what role(s) you perform, and what requirements apply to you at what time. From that overview, determine where the biggest risks and fastest deadlines are.

Conclusion

The PPWR pulls packaging compliance into today’s reality: recyclability, less material, more recyclate, cleaner materials and clear record keeping. For business owners, this means more control over packaging design, suppliers and product data, as online sales and enforcement become less and less tolerant of “we’ll fix it later.”

Those who start now with structure in scope, packaging inventory and supplier agreements will prevent 2026 from becoming a scramble.

Want to know what the PPWR means for your products, packaging and sales channels? Instrux will help you with a scope check, packaging inventory, review for recyclability and substances, labeling and registration. Check out our PPWR service or contact us and find out where you can eliminate the most risk with the least effort.