Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) is reshaping the regulatory framework for products placed on the European Union market. Applying from 12 August 2026, the Regulation introduces harmonised requirements intended to reduce packaging waste, improve circularity and make compliance more consistent across Member States. Its impact extends well beyond packaging manufacturers: importers, distributors, retailers, brand owners and businesses using packaging in their operations may all be affected.
The PPWR regulates the full life cycle of packaging, covering its composition, design, recyclability, labelling and eventual treatment as waste. Although several obligations will be phased in over the coming years, businesses should already be assessing their packaging portfolios, contractual arrangements and supporting documentation.
Less Waste and More Circular Packaging
A central objective of the new framework is to prevent unnecessary packaging and ensure that materials remain in economic use for longer. Requirements relating to recyclability will become increasingly significant from 2030, encouraging companies to consider not only the material used for packaging, but also whether it can be effectively collected, sorted and recycled at scale.
The Regulation also addresses excessive packaging. Under the applicable rules, grouped, transport and e-commerce packaging will generally be subject to a maximum empty-space ratio of 50%. Businesses will therefore need to balance product protection with packaging minimisation and may need to revisit technical specifications, logistics processes and supplier requirements.
Restrictions on PFAS in Food-Contact Packaging
From 12 August 2026, food-contact packaging containing per- and polyfluoroalkyl substances (PFAS) at or above the limits prescribed by the PPWR may no longer be placed on the EU market. These highly persistent substances have been used in certain packaging applications for their resistance to grease, water and heat. Companies handling food-contact materials should review product specifications, testing protocols and supplier assurances to determine whether their packaging meets the new thresholds.
Labelling and Environmental Claims
Harmonised EU labelling requirements are intended to help consumers identify packaging materials and dispose of them correctly. At the same time, businesses should examine how they communicate environmental performance. Claims concerning recyclability or recycled content must be accurate, verifiable and sufficiently specific, including whether they relate to the entire packaging unit or only to one component.
This means PPWR compliance is not solely a product-development or procurement issue. Marketing, sustainability and legal teams should work together to ensure that packaging statements are aligned with regulatory requirements and supported by appropriate evidence.
Identifying Responsibilities Across the Supply Chain
The obligations applying to a particular company depend on its role in the supply chain. Manufacturers, importers, distributors, fulfilment service providers and brand owners may have different duties, even when they are involved with the same packaged product. Private-label and customised packaging arrangements require particular attention, as responsibility may be divided among the packaging producer, the company filling the packaging and the business under whose name or trademark the product is marketed.
A clear allocation of roles is essential for determining who must prepare technical documentation, issue declarations of conformity, obtain information from suppliers and communicate relevant data to customers. Incomplete or inaccurate documentation can create regulatory and commercial risk throughout the supply chain.
Practical Steps for Businesses
- map all packaging placed on the EU market and identify the relevant economic-operator role for each product;
- review packaging design, material composition, empty-space ratios and recyclability;
- request updated specifications, test results and compliance documentation from suppliers;
- check contracts to ensure that regulatory responsibilities and information duties are clearly allocated;
- review environmental claims and labelling practices; and
- establish an implementation timetable for requirements that will apply in later phases.
How We Can Assist
For companies operating in multiple jurisdictions, the PPWR calls for coordinated legal, technical and commercial implementation. Our team advises businesses on regulatory scoping, supply-chain responsibilities, contractual risk allocation, compliance documentation and the review of packaging-related environmental claims. Early preparation can reduce disruption, support consistent market access and turn regulatory change into a more manageable business process.
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