Packaging and Packaging Waste Regulation (PPWR) Support

Packaging and Packaging Waste Regulation (PPWR)

The EU’s Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, introduces new and progressively developing requirements for packaging placed on the EU market.

The Regulation affects packaging design, recyclability, recycled content, substances in packaging, packaging minimisation, reuse and refill, labelling, Extended Producer Responsibility (EPR), conformity assessment and the information and evidence needed to demonstrate compliance.

PPWR has applied across the EU since 12 August 2026, but implementation is phased. Some requirements already apply, while others will take effect over the coming years and further detail is being developed through delegated and implementing acts.

For organisations, understanding PPWR therefore involves more than identifying a compliance date. Businesses need to understand which requirements apply to their packaging, their responsibilities within the supply chain, what information and evidence they need and how future requirements could affect packaging and material choices.

What does the Packaging and Packaging Waste Regulation cover?

PPWR establishes requirements across the lifecycle of packaging and packaging waste.

These include:

• recyclability and design-for-recycling requirements;
• minimum recycled content in plastic packaging;
• substances in packaging, including restrictions on PFAS in food-contact packaging;
• packaging minimisation;
• reuse and refill requirements;
• harmonised packaging labelling;
• Extended Producer Responsibility;
• conformity assessment and technical documentation; and
• information requirements across the supply chain.

The requirements do not all apply at the same time. PPWR establishes a phased framework extending through 2030, 2035, 2040 and beyond, with the timing of some measures also linked to further secondary legislation.

This makes it important to distinguish between requirements that apply now, future requirements for which organisations can begin preparing and areas where further regulatory detail is still needed.

Who is affected by PPWR?

PPWR can affect organisations involved at different stages of packaging and product supply chains.

Depending on their activities, manufacturers, suppliers, importers, distributors, producers and other economic operators may have different obligations.

For businesses supplying products into the EU, an important starting point is therefore to establish which packaging is within scope and the organisation’s role in relation to that packaging.

Responsibilities may also extend across organisational boundaries. For example, manufacturers may depend on information and documentation from packaging or material suppliers in order to demonstrate conformity.

Understanding the supply chain can therefore be as important as understanding the packaging itself.

What should organisations be considering?

The practical implications of PPWR will vary according to the packaging involved, the organisation’s role and the markets in which it operates.

Organisations preparing for PPWR may need to consider:

• which packaging and packaging formats are within scope;
• their economic-operator roles and associated responsibilities;
• what information is currently available about packaging materials and composition;
• whether suppliers can provide the information and documentation needed to support compliance;
• technical documentation and conformity assessment requirements;
• how future recyclability criteria could affect packaging design and material choices;
• minimum recycled-content requirements for relevant plastic packaging;
• whether PFAS or other substances in packaging create additional regulatory considerations;
• future labelling, reuse and refill requirements;
• EPR responsibilities in relevant EU Member States; and
• which delegated and implementing acts need to be monitored as the framework develops.

For many organisations, PPWR is therefore likely to require coordination between regulatory, packaging, procurement, sustainability, product-development and supply-chain functions.

PPWR, chemicals and product regulation

PPWR is often discussed primarily in the context of packaging waste and the circular economy, but it also creates important chemicals and product-regulatory considerations.

One immediate example is PFAS.

Since 12 August 2026, food-contact packaging containing per- and polyfluoroalkyl substances (PFAS) at or above specified concentration limits cannot be placed on the EU market, subject to the applicable provisions of EU law.

More broadly, PPWR introduces conformity assessment, technical documentation and supply-chain information requirements alongside requirements affecting the composition and design of packaging.

For businesses, this creates potential interactions between packaging regulation, chemicals compliance, product regulation and sustainability requirements.

How RPA can support organisations with PPWR

RPA supports organisations in understanding complex regulatory requirements and translating them into practical considerations for products, packaging and supply chains.

Our PPWR support can include:

• Regulatory interpretation and applicability

Understanding which PPWR requirements are relevant to particular products, packaging formats, activities and supply-chain roles.

• Compliance and evidence requirements

Identifying relevant conformity, technical documentation and information requirements, including where evidence may need to be obtained from suppliers or other parts of the supply chain.

• Chemicals and substances in packaging

Supporting organisations in understanding PFAS requirements and other chemicals and product-regulatory considerations relevant to packaging.

• Recyclability and recycled content

Helping organisations understand the developing requirements for packaging recyclability and recycled content, including the implications of emerging delegated and implementing acts.

• Extended Producer Responsibility

Supporting organisations in understanding relevant PPWR EPR requirements and their implications, particularly where businesses operate across multiple EU Member States.

• Regulatory monitoring and implementation

Monitoring relevant PPWR developments and helping organisations distinguish between established requirements, future obligations and areas where further regulatory detail is still being developed.

Bringing together product regulation and environmental policy

PPWR sits at the intersection of product regulation, chemicals, packaging, waste and circular-economy policy.

RPA brings together expertise from our Chemicals & Product Regulation and Environment & Society practices to help organisations consider these interconnected requirements.

Our approach combines regulatory analysis with scientific, environmental, economic and policy expertise, allowing us to consider not only what the Regulation requires, but what those requirements may mean in practice for organisations and their supply chains.

Speak to RPA about PPWR

If you are assessing how the Packaging and Packaging Waste Regulation affects your products, packaging or supply chain, RPA can help you understand the relevant requirements and the practical implications for your organisation.