EU packaging and packaging waste regulation, what businesses need to know

A new set of packaging waste regulations covering how packaging is designed, labelled and managed has now come into application across the EU. The EU packaging waste regulation, commonly known as the PPWR, applies from 12 August 2026 and affects any business placing packaged goods on the EU market, whether the packaging is produced within the EU or imported from outside it.

This guide covers what the PPWR regulation is, who it affects, the key PPWR requirements that apply now and what businesses shipping to the EU should be doing to prepare.

What is the PPWR?

The packaging and packaging waste regulation, formally Regulation (EU) 2025/40, entered into force on 11 February 2025 and became generally applicable across all 27 EU member states from 12 August 2026. The EU PPWR replaces the previous Packaging and Packaging Waste Directive.

Unlike a directive, a regulation applies directly across every member state without needing to be separately written into national law. This means the same core EU packaging regulation rules apply whether you are shipping into Germany, France, the Netherlands or any other EU country, rather than facing 27 different national interpretations.

The PPWR EU framework covers packaging design, recyclability, labelling, substances of concern and end-of-life waste management, with the broader aim of reducing packaging waste and supporting a more circular economy across the EU. It is the single set of EU packaging rules that has replaced the old country-by-country approach.

Who Does the PPWR Affect?

The PPWR applies broadly across the packaging supply chain. It covers manufacturers, importers, distributors, online marketplaces and, notably, fulfilment service providers. If your business ships packaged goods into the EU, or places packaging on the EU market in any capacity, some level of obligation is likely to apply.

Different obligations apply depending on where a business sits in the supply chain. Broadly, this can include:

• Ensuring packaging complies with sustainability and labelling requirements
• Carrying out conformity assessment procedures and maintaining technical documentation
• Providing or verifying packaging information throughout the supply chain
• Meeting Extended Producer Responsibility obligations, including registration, financing waste management and annual reporting

There is no general exemption for small or medium-sized businesses. If your business ships packaged goods to EU customers regularly, it is worth assuming the PPWR applies in some form and working out exactly which obligations are relevant to your role.

PPWR Requirements That Changed from 12 August 2026

A number of core PPWR 2026 obligations became binding from the application date, including:

PFAS Restrictions for Food-Contact Packaging

Per- and polyfluoroalkyl substances above defined thresholds are now restricted in packaging that comes into contact with food.

Heavy Metal Limits and Substance Restrictions

Packaging must be designed to minimise harmful substances, with limits continuing to apply to certain heavy metals across all packaging types.

Mandatory Conformity Documentation

Businesses must be able to produce a declaration of conformity packaging document, plus supporting technical documentation, for each type of packaging placed on the market.

Extended Producer Responsibility Registration

Producers are required to register in each EU member state where packaging is first made available, with registration thresholds in some countries triggered by any quantity placed on the market.

Unique Identification on Packaging Units

Manufacturers must apply a unique identifier to packaging units to support traceability.

Further requirements are being phased in on a rolling basis through to 2040, covering areas such as minimum recycled content, harmonised recycling labelling and stricter recyclability thresholds.

The 12 August 2026 date marks the first major PPWR deadline rather than the end point of the regulation, and businesses should expect the EU packaging law to continue evolving through subsequent phases.

The Empty Space Rule for Ecommerce Packaging

One requirement particularly relevant to ecommerce businesses and fulfilment operations is the restriction on packaging minimisation. From 12 August 2026, empty space within e-commerce parcels must not exceed 40% of the total package volume, unless the extra space is technically unavoidable. This includes void-fill materials such as bubble wrap and packing foam, which count towards the empty space calculation.

For ecommerce brands and fulfilment operations shipping into the EU, this makes packaging size and fill efficiency a genuine compliance consideration, not just a cost or sustainability one. Reviewing current packaging dimensions against typical order contents is a practical first step for any business dispatching regularly to EU customers.

Extended Producer Responsibility: What It Means in Practice

Extended producer responsibility EU obligations, commonly referred to as EPR packaging requirements, place responsibility on producers for the environmental impact of the packaging they place on the market, including financing its collection and recycling once it becomes waste.

Under the PPWR, EPR registration is generally required in each EU member state where packaging is made available. Producer responsibility packaging obligations vary somewhat by country, but the underlying principle is consistent across the EU.

If your business does not have its own legal entity in a particular member state, an Authorised Representative may be required to handle EPR compliance on your behalf. A proposal to ease this requirement for smaller businesses was under discussion in the EU legislative process as of late 2026, but had not been finalised.

Until any change is formally adopted, the existing requirement remains in effect. Treating extended producer responsibility packaging obligations as active now, rather than pending, is the safer approach.

Whether your business is classed as a manufacturer, importer or distributor for a specific product line affects which EPR obligations apply, and this classification is not always obvious. If you influence packaging design, material selection or branding, you may be considered the manufacturer for compliance purposes even if you did not physically produce the packaging. Getting your EPR packaging compliance classification right at the outset avoids having to unpick registrations and documentation later.

Penalties for Non-Compliance

While the core PPWR obligations are already binding, the specific penalty framework for non-compliance is still being finalised at national level in several member states. Enforcement details fall to individual countries even though the regulation itself applies directly.

This is one of the areas where PPWR packaging compliance is easy to underestimate. Businesses should not treat the absence of a fully defined penalty schedule as a reason to delay compliance. National enforcement frameworks are expected to be confirmed and applied progressively.

What Businesses Shipping to the EU Should Do Now

Getting on top of packaging compliance now, rather than waiting for enforcement to catch up, is the safest approach given how broadly the regulation applies. Practical EU packaging compliance steps include:

• Review your business's role and responsibilities under the EU packaging law for each product and packaging type you ship
• Evaluate current packaging against EU packaging requirements, including fill ratio for ecommerce parcels
• Engage with packaging suppliers to confirm compliance information and documentation is available
• Assess whether EPR compliance obligations apply in each EU member state you ship to
• Prepare or request Declarations of Conformity and technical documentation for each packaging type
• Consult a legal or compliance adviser regarding your specific obligations, particularly where your role in the supply chain is unclear

None of these steps are complicated in isolation, but taken together they represent a genuine operational project for any business shipping regularly to the EU. Businesses that leave packaging waste compliance until closer to a deadline typically find it takes longer than expected to gather supplier documentation, which is exactly why starting now rather than later matters.

Carriers and logistics partners vary in how they support customers with this. Some, including certain carriers CSM works with, have confirmed they will ensure compliance for packaging they themselves place on the EU market. This does not remove a business's own responsibility for packaging that it sources, brands or specifies independently. If you are unsure where responsibility sits for a specific shipment, it is worth confirming directly with your packaging supplier and your logistics provider.

How This Connects to Your Wider EU Shipping Compliance

The PPWR sits alongside other EU compliance requirements that UK businesses shipping to Europe already need to manage. These include customs documentation and EU deforestation regulation obligations for certain commodity categories, as well as rules of origin requirements under the UK-EU Trade and Cooperation Agreement. For a broader overview of the customs and documentation requirements for UK to EU shipments, see our European Union import customs guidelines and our guide to rules of origin.

For the fuller picture on documentation, VAT and duty requirements for UK to EU shipments generally, see our UK to EU shipping guide. For an overview of everything that changed after Brexit and what businesses need to have in place, see our guide to shipping from the UK to the EU after Brexit.

For ecommerce businesses specifically, packaging efficiency now has a direct compliance dimension as well as a cost one. If you are reviewing your fulfilment and dispatch setup as part of preparing for the PPWR, our ecommerce shipping solutions page covers how CSM supports platform integration and multi-carrier dispatch for growing EU order volumes.

If you have questions about how the PPWR affects your specific shipments to the EU, contact your local CSM branch to discuss your requirements.

Frequently Asked Questions

What is the PPWR?

The EU PPWR, or Packaging and Packaging Waste Regulation, is EU legislation, Regulation (EU) 2025/40, that establishes a harmonised legal framework for packaging and packaging waste across all EU member states. It applies to all packaging placed on the EU market, whether produced within the EU or imported from third countries, and is the main piece of EU packaging regulations 2026 has brought in.

When Did the PPWR Come into Effect?

The PPWR EU regulation entered into force on 11 February 2025 and became generally applicable from 12 August 2026, which is the key PPWR deadline businesses need to be aware of. Further requirements are being phased in through to 2040.

Does PPWR Apply to UK Businesses?

Yes. PPWR UK applicability follows the same logic as for any non-EU country: the regulation applies to any business placing packaging on the EU market, regardless of where that business is based. UK businesses shipping packaged goods to EU customers are affected in the same way as EU-based businesses, so does PPWR apply to UK sellers is really a question of whether you ship packaged goods into the EU at all, not where your company is registered.

What is the 40% Empty Space Rule?

From 12 August 2026, empty space within ecommerce parcels must not exceed 40% of total package volume, unless the additional space is technically unavoidable. This includes void-fill materials such as bubble wrap and foam.

What is Extended Producer Responsibility Under the PPWR?

Extended Producer Responsibility, or EPR, requires producers to register in each EU member state where their packaging is placed on the market and to contribute towards the cost of collecting and recycling that packaging once it becomes waste. Registration thresholds and requirements vary by member state.

What Should My Business Do to Prepare for PPWR Compliance?

Review your role and responsibilities in the packaging supply chain, evaluate your current packaging against PPWR requirements, confirm compliance documentation with your suppliers, assess whether EPR registration applies to your business, and consult a legal or compliance adviser regarding your specific obligations.