Think of the box, bottle, or bag that carries your product into the hands of a customer in Europe. Since 12th August 2026 packaging has to comply with the EU packaging rules and if you do not comply, your consignment can be held at the border even if the product itself is absolutely fine.
Ask these questions about your best selling product:
- What is the packaging material name?
- How much does it weigh?
- Who pays for it to be recycled in each country where it is sold?
Many companies may not know, but all three pieces of information are required by the new regulations.
The regulations called PPWR apply to all 27 EU countries and even to companies based outside Europe. There is another set of regulations called EPR which makes sellers pay for the recycling of their packaging. Below, we explain what these rules are, the mistakes that come up most often and how Ingenious e-Brain can help.
What Is PPWR?
PPWR stands for Packaging and Packaging Waste Regulation (officially Regulation (EU) 2025/40). It replaced the old Packaging Directive (94/62/EC). A Directives has to be turned into national law, so each country wrote its own version of it. However, regulations are legally binding as written, so the same rules now apply in every EU country. This means there are now common standards across Europe.
PPWR applies to any type of packaging format including boxes, bottles, bags, jars, pouches, wrapping and pallets. The aim is to reduce packaging waste and help increase reuse and recycling. The majority of PPWR rules have applied since 12th August 2026, some will come into force between 2027-2030, and a few will follow later on.
What is EPR and How Does It Link to PPWR?
EPR stands for Extended Producer Responsibility. Once a company puts its packaging on the market, it is responsible for the funding of collection, sorting, and recycling of their packaging.
Most companies do this by paying a recycling organization (PRO) or by signing up to the national register of sellers. There are different fees, forms, and lists depending on the country. You will need to check what is required in your market.
The main EPR packaging requirements are:
| Duty | What it means for you |
|---|---|
| Sign up in each country | You have to register in all EU countries where your packaging is becoming waste. |
| Pay recycling fees | You must pay to have your packaging collected, sorted and recycled. The fees encourage better packaging design. |
| Fees linked to recyclability | From 2030 packaging that is harder to recycle will have higher charges. |
| Local representative | You will usually need a local representative if your company is not based in the country where you are selling. However, the EU has suggested small businesses may be exempt from this obligation – although this has not been confirmed. |
| Lighter rules for small sellers | Sellers with less than 10 tonnes of packaging per year can have a simplified registration, reporting and fees. |
Who Has to Follow the EU Packaging Rules?
The rules reach more than packaging makers. They apply to:
- Makers of packaging and of packaged products
- Importers bringing goods into the EU
- Distributors and retailers
- Online sellers shipping parcels to EU customers
The EU packaging rules also apply to companies which are based outside the EU. If you sell packaged products in a particular EU country, the law regards you as the ‘producer’ in that country, and it is therefore your responsibility to make the payment for recycling. The packaging manufacturer carries the most responsibility, including a signed declaration that the packaging meets the rules, backed by supplier documents.
What Do the New EU Packaging Rules Change for Businesses?
These are the main PPWR compliance requirements businesses need to act on:
- Harmful substances: Packaging can carry only tiny amounts of lead, cadmium, mercury, and hexavalent chromium, 100 mg per kg in total. Food packaging also faces limits on PFAS, the “forever chemicals”.
- Documentation: For every type of packaging, you will need a technical file and declaration that it meets the rules. Your supplier can provide supporting documentation.
- Labels: New labelling will show the material of your packaging so it makes it easier for shoppers to recycle. This will be introduced in coming years.
- Recycling: Packaging must be recyclable and it must contain more recycled material. These targets start in 2030.
- Less packaging: Empty space in parcels will be limited. The EU aims to reduce packaging waste by 5% by 2030, 10% by 2035 and 15% by 2040 measured against 2018.
- Reuse: This applies to certain types of packaging such as drink bottles and transport packaging. Refill and return systems get their own rules.
- Penalties: Each country will introduce their own penalties by 12 February 2027. The penalty will depend on the country you sell in.
Common PPWR Compliance Issues
Issues are often seen during the quick checks:
- No list of what packaging is used in which country.
- Records of Product name only but no list of what packaging components are used such as box, filler, tape etc.
- Supplier documents not being up to date or not having them at all.
- Assuming your distributor or online marketplace will pay for recycling.
- Registered in one country but selling in five.
- Not tracking online sales by country, which forces you to guess your fees.
What Happens If You Ignore These Gaps?
Packaging which does not comply with the rules is not allowed to be sold in the EU. Goods may be detained at the border or removed from the shelves. The EU has left it to each individual country to determine the size of the fines, so the cost will vary depending on where you are selling. If recycling fees have not been paid or if the necessary signups have been missed can lead to back payments and blocked sales. Furthermore, retail buyers can request evidence from suppliers before placing their next order, meaning that a single missing document can delay the entire product line.
How Ingenious e-Brain Helps with PPWR and EPR Compliance
Ingenious e-Brain (IeB) is an experienced research and consultancy company with over 14 years of experience and has completed over 6,000 projects worldwide. Our packaging consulting provides advice regarding recyclable, renewable, biodegradable and water-soluble packaging choices backed up with market research, technology scouting and competitor analysis.
Here is how we can help:
- PFAS Regulatory Intelligence: Identify and understand PFAS regulations, exemptions and transitions in EU and US. Get insights via heat map on which products and markets they are relevant for.
- Application Mapping: Understand where PFAS is being used within your packaging and what function it is performing and who are the key suppliers and converters.
- Competitor and IP landscape: Understand who are the key players developing genuine alternatives, what patents they hold and any potential freedom to operate issues.
- Cost and Market Analysis: Understand the cost implications of switching, premium pricing and a ranked roadmap of what to tackle first.
Frequently Asked Questions
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Will the EU packaging rules apply to companies outside the EU?
Yes. Any company putting packaging or packaged items onto the EU market will be included. If you are not based in your selling countries, you will usually require a local representative to carry out recycling responsibilities. However, the EU has proposed to defer this requirement for small businesses.
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What is the difference between PPWR and EPR?
PPWR is the rules for how packaging needs to be designed, labelled and documented. Whereas EPR determines who will pay to collect and recycle.
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When should we get started?
As soon as possible to gather evidence, documentation and registrations for PFAS. Design work for 2030 should start in 2027 at the latest.
Book a PPWR and EPR Gap Review with IeB
Send IeB your packaging list and target markets so that we can provide you with a targeted gap analysis. This will show us where your packaging is exposed and therefore what to focus on.
Contact Ingenious e-Brain at contact@iebrain.com or fill out the form below.
