What the EU Packaging and Packaging Waste Regulation means for UK businesses

The European Union’s Packaging and Packaging Waste Regulation (EU PPWR) is a major overhaul of packaging rules that applies to all businesses placing packaging on the EU market 

EU PPWR aims to reduce packaging waste, encourage reuse and refill, increase recycling, remove harmful materials in packaging, and harmonise packaging rules across EU member states. The European Commission, which requires all packaging to be recyclable by 2030, says: 

‘Unnecessary packaging waste is growing faster than our economies and even our population. Packaging uses too many resources and is inefficient and expensive for businesses and consumers. Packaging waste is too difficult to recycle and dealing with it costs taxpayers.  
 

‘Most businesses already use sustainable packaging and laws are in place throughout Europe. But more is needed. The Packaging and Packaging Waste Regulation (PPWR) is designed to boost business and innovation in Europe while protecting people and the planet.’ 

The regulation, which replaces the previous Packaging and Packaging Waste Directive (PPWD),  entered into force on 11 February 2025 and was applied generally from 12 August 2026. Further requirements will be introduced in phases until 2040.  

The EU aims to reduce packaging waste per capita. The targets are 5% by 2030, 10% by 2035, and 15% by 2040, compared to 2018 levels. 

This guide is a general overview and does not represent legal or compliance advice. You should seek expert advice for the specific requirements of your business.  

Which businesses does EU PPWR apply to? 

EU PPWR applies to all businesses that place packaging on the EU market. This includes: 

• manufacturers 
• importers 
• distributors 
• retailers 
• ecommerce sellers  

Much of the PPWR rules also apply to businesses supplying the Northern Ireland market. More details can be found here. 

What packaging does EU PPWR apply to? 

The regulation applies to all packaging defined as primary, secondary, and tertiary packaging. This broadly covers any item intended for containment, protection, handling, delivery, or presentation of products.  

What steps do businesses need to take? 

The exact obligations you need to comply with depend on factors including your products, packaging, supply chain, and EU markets. Examples include: 

Packaging design 

EU PPWR means businesses increasingly need to demonstrate that their packaging meets EU requirements for recyclability and material efficiency. Businesses should review areas such as: 

• materials used 
• packaging weight 
• coatings, inks, and adhesives 
• recycled content 
• if different materials can be separated 

Recycled content 

The regulation introduces minimum requirements for recycled content for certain plastic packaging. These targets will increase as the rules are phased in. The minimum requirements are: 

Plastic packaging type	Minimum by 2030*	Minimum by 2040
Contact-sensitive packaging mainly made from PET (excluding single-use drinks bottles)	30%	50%
Contact-sensitive packaging made from plastics other than PET (excluding single-use drinks bottles)	10%	25%
Single-use plastic drinks bottles	30%	65%
Other plastic packaging	35%	65%

Businesses should gather information about how much recycled material their packaging contains, where the recycled material comes from, and whether suppliers can provide documentary evidence. 

Extended Producer Responsibility 

If you place packaged products on an EU member state’s market, you may have requirements around registration, reporting, and fees under the country’s Extended Producer Responsibility (EPR) system, a process that came into force before PPWR. This involves providing data on packaging type, weight, recycled content, and recyclability.  

EPR rules apply in each country that you export to and costs vary depending on the market. You may need to appoint an authorised representative in each country you trade with. 

It’s important to note the PPWR and EPR are not the same thing. PPWR is the overarching EU-wide rulebook and EPR is the individual funding system in each EU country. You need to comply with both.   

Declaration of Conformity  

The Declaration of Conformity (DoC) is a mandatory legal document that applies to certain businesses that place packaging on the EU market. It confirms that the packaging meets the requirements of EU PPWR.  

The documents are self-declared rather than issued by a third party, and one DoC is required for each specific packaging format.  

Reuse and refill 

The regulation introduces phased-in reuse targets and requirements for certain types of packaging and sectors. These include: 

• By 2030, 40% of transport packaging must be reusable, increasing to an aspirational target of 70% by 2040. 
• By 2030, 10% of grouped packaging must be reusable, increasing to an aspirational target of 25% by 2040. 
• By 2030, beverage distributors must ensure 10% of products are in reusable packaging, rising to 40% by 2040. 

Labelling 

PPWR introduces harmonised packaging labelling requirements across the EU to replace different national labelling rules.  

The main harmonised material composition labelling requirements are expected to apply from 12 August 2028, subject to relevant implementing legislation. You should not redesign every label on the assumption that the 2028 requirements are already fixed. Keep monitoring the EU’s legislation updates.  

Food-contact packaging 

PPWR places restrictions on use of per- and polyfluoroalkyl substances (PFAS) in food-contact packaging such as takeaway containers, pizza boxes, and food wrappers. Packaging with PFAS above set concentration levels cannot be placed on the EU market. 

Food and Drink Federation guidance says: ‘The European Commission has confirmed that these limits apply to the packaging unit as a whole, including inks, coatings, adhesives, and other components, and apply irrespective of whether PFAS are intentionally added or unintentionally present.’   

Where to find more information 

Here are some resources that provide more details about EU PPWR: 

• Webinar on the government’s Business Academy website 
• European Commission guidance and frequently asked questions 
• Interactive guide from Europen 

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