One week into new EU packaging rules: What businesses need to know

Packaging placed on the EU market must now comply with the Packaging and Packaging Waste Regulation (PPWR), which has applied since 12 August. 

The rule aims to reduce packaging waste, improve the functioning of the EU single market and support a circular economy, while creating more harmonized requirements for businesses across the bloc.

Measures now in effect include restrictions on the use of per- and polyfluoroalkyl substances (PFAS), also known as “forever chemicals,” in food-contact packaging; limits on the concentration of heavy metals in packaging; and declarations of conformity and extended producer responsibility requirements for manufacturers. 

Further requirements will be introduced in phases through 2030 and beyond.

Updated guidelines

In August, the Directorate-General for Environment of the European Commission (EC) updated its Frequently Asked Questions (FAQ) document about the PPWR, adding new guidance in response to questions raised by industry stakeholders.

One of the new clarifications covers packaging manufactured before 12 August but not yet placed on the EU market by that date. 

The EC confirmed that businesses do not need to destroy, remanufacture or relabel this packaging solely to meet the PPWR. Packaging that was already placed on the EU market before 12 August can also remain there, even if it does not meet the regulation’s requirements.

For packaging manufactured after 12 August, however, the required manufacturer information should generally be displayed directly on the packaging. Businesses may use an accompanying document instead only when it is not possible to incorporate the unique identification and the manufacturer’s name and address directly onto the packaging.

If a supplier of already-produced packaging no longer exists or is unwilling to provide the required information, manufacturers are expected to make “best efforts” to obtain it, including by contacting the former supplier, seeking it from a company that acquired the supplier, or conducting their own assessment.

Compliance and enforcement

The Commission also highlighted that manufacturers bear legal responsibility for ensuring that packaging placed on the EU market complies with the PPWR. To demonstrate compliance, manufacturers and importers must retain technical documentation for 5 years for single-use packaging and 10 years for reusable packaging.

The documentation must include, at minimum, the “conceptual design, manufacturing drawings and materials of components.” The EC noted that manufacturers should protect commercially sensitive information in accordance with relevant EU and national law.

Meanwhile, products with packaging that does not comply with the rules applicable from 12 August will not be immediately banned from the bloc, and enforcement should not disrupt trade flows, supply chains or consumer access to goods.

Where non-compliance is identified, the relevant economic operator will first be notified and given an opportunity to take corrective action within a reasonable timeframe. Member States may take further measures, such as prohibiting, recalling or withdrawing non-compliant packaging, only if the issue is not addressed and the non-compliance persists.

Authorized representative rules

One measure that took effect is the requirement for businesses engaged in cross-border shipping to appoint an authorized representative in each affected EU member state. 

In December 2025, the Commission submitted a legislative proposal to suspend this measure until 1 January 2035. 

The proposal says producers of textiles, textile-related products, footwear, electrical and electronic equipment, and single-use plastic products should be able to choose whether to appoint an authorized representative for EPR when making products available on the market of another Member State where they are not established.

According to the German Retail Federation (Händlerbund), the EU Council suspended deliberations on it a few weeks before the implementation date as a majority of Member States opposed it. 

“Currently, only the European Parliament is negotiating a significantly scaled-back version that provides for an exemption only for micro-enterprises with up to 49 employees and an annual turnover of €10 million ($11.6M). The first reading on this is scheduled for October 2026 at the earliest,” it adds.

What’s next?

The PPWR will introduce additional requirements in phases over the coming years, with several key measures taking effect from 2028 and 2030.

From 2028, a harmonized EU-wide packaging labeling system will be introduced to make it easier for consumers to sort packaging correctly and improve the efficiency of recycling and composting systems.

Further measures to reduce packaging waste will apply from 2030. These will include limits on unnecessary empty space in packaging, restrictions on certain types of single-use plastic packaging and targets for the use of reusable packaging.

The regulation will also introduce measures to strengthen the circular economy, including requirements for recycled plastic content in new plastic packaging and for packaging recyclability.