PPWR: What you need to do now

Overview

With the EU’s Packaging and Packaging Waste Regulation (PPWR) beginning to take effect from August 2026, we wanted to share a concise update on what this means in practice. Initial requirement, such as restrictions on substances like PFAS, will apply immediately, with broader rules on recyclability, recycled content, and labelling being phased in over time. Early preparation will be essential to ensure continued market access.

What is PPWR?

PPWR is a new EU-wide regulation designed to create a fully harmonised framework for packaging across all member states, with a strong focus on sustainability, recyclability, and waste reduction. Unlike previous directives, it applies directly across the EU, meaning one consistent set of rules for all markets.

Even if your business is UK-based, the PPWR may still apply depending on how your products are placed on the market. In particular, companies supplying goods into Northern Ireland may be required to comply, as Northern Ireland continues to follow EU product regulations under the current trading arrangements. In addition, any UK business selling packaged goods into the EU or supplying customers who then distribute into the EU could fall within scope. As the regulation applies across the entire supply chain, it is important for UK companies to assess where their products are ultimately sold and ensure their packaging meets PPWR requirements to avoid barriers to market access.

Key implications for businesses

Legal experts note that PPWR is a significant shift in responsibility across the entire supply chain, not just manufacturers.

Some of the most important practical implications include:

• Market access depends on compliance
  Packaging that does not meet the requirements may not be allowed on the EU market.
• Shared responsibility across the supply chain
  Manufacturers, importers, distributors, and retailers all carry defined obligations—which may overlap and require clearer contractual agreements.
• Increased scrutiny on environmental claims
  Regulators are expected to focus on greenwashing and unsubstantiated recyclability claims, particularly for high-profile brands.
• Greater emphasis on data and documentation
  Robust technical documentation, packaging data, and governance processes will be essential to demonstrate compliance.
• Complexity and uncertainty in early stages
  Some detailed requirements will be clarified through further guidance, meaning businesses need to work within evolving rules and tight timelines.

PFAS (so-called “forever chemicals”)

From August 2026, the PPWR introduces strict limits on PFAS in food-contact packaging. In simple terms, if these chemicals are present above very low thresholds, the packaging cannot be placed on the EU market, so businesses will need to ensure materials and coatings are PFAS-compliant and supported by testing evidence.

Recycled content (plastic packaging)

The regulation also requires plastic packaging to include minimum levels of recycled content, with targets increasing over time (for example, typical requirements begin from 2030 depending on the application). The aim is to reduce reliance on virgin plastic and drive a more circular packaging system.

What actions should you take now?

Based on current guidance, we recommend customers begin focusing on the following:

1. Review your packaging portfolio

• Assess recyclability, material use, and packaging volumes
• Identify any formats that may not meet future requirements

2. Understand your role and obligations

• Confirm whether you act as a manufacturer, importer, or distributor
• Clarify responsibilities within your supply chain

3. Start collecting accurate packaging data

• Material composition
• Recycled content
• Weight and recyclability performance

(Strong data will be critical for compliance and reporting.)

4. Prepare for Extended Producer Responsibility (EPR)

• Registration and reporting will be required in EU markets
• Fees may be linked to recyclability performance

5. Review claims and customer communications

• Ensure any recyclability or sustainability claims are evidence-based and verifiable

6. Strengthen supplier and contract arrangements

• Ensure responsibilities for compliance, data provision, and testing are clearly defined

How we can support you

At Roberts Mart, we are closely tracking PPWR developments and working proactively with customers to:

• Review packaging specifications against PPWR criteria
• Identify risk areas and improvement opportunities
• Support data collection and reporting readiness
• Develop compliant, future-proof packaging solutions

In summary

While PPWR introduces complexity, it is ultimately designed to standardise requirements and improve sustainability across Europe. Early preparation will be key to avoiding any type of potential issues.

If you would like to review your packaging portfolio or discuss your specific requirements, please don’t hesitate to get in touch.

Email: hello@roberts-mart.com or call us on 0113 2026 500.