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PPWR: What the EU's Packaging Regulation Means for UK Businesses
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By Agnès Potier-Murphy, International Copywriter, on 17/09/2026
If your business ships packaged goods into the EU, the Packaging and Packaging Waste Regulation already applies to you, whether you're based in Leeds or halfway round the world. PPWR is a regulation, not a directive, so there was never a national transposition to wait for, and since 12 August 2026, packaging that doesn't meet its requirements simply can't be placed on the EU market.
For UK exporters, the deadline is already passed. This guide covers exactly what PPWR requires, what's changed since some of the early Brexit-era assumptions stopped holding up, and where the genuine gaps in most existing guidance sit.
In this article, we'll explore how:
PPWR is a regulation rather than a directive, so it took effect identically across the EU with no delay for national transposition
It's been in force since February 2025 and generally applies from 12 August 2026, regardless of where a business is headquartered
Packaging is graded A, B or C for recyclability. Anything that doesn't reach the C threshold can't be placed on the EU market at all
Food-contact packaging faces a PFAS ban from 12 August 2026, with no grace period for pre-deadline stock that hasn't yet reached the market
Northern Ireland follows most of PPWR under the Windsor Framework, though not all of it
What is PPWR?
PPWR stands for the Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40. It's an EU law that sets binding design, recyclability and labelling requirements for all packaging placed on the EU market. Unlike the directive it replaces, PPWR applies directly in every EU member state, with no need for national transposition first. That's what makes its rules identical everywhere from day one.
In practice, it covers three things: how recyclable packaging has to be, how much recycled material it has to contain, and what documentation a business needs to prove both.
| Requirement | What it means |
|---|---|
|
Recyclability
|
All packaging must be recyclable. From 2030, it's graded A, B or C based on how recyclable it is. Anything below a 70% recyclability threshold is barred from the EU market entirely. |
|
Recycled content
|
Plastic packaging must contain a minimum share of recycled material. The exact percentage depends on the plastic type and whether it touches food, with a first tier of targets from 2030 and a higher second tier from 2040. |
|
Declaration of Conformity
|
Every packaging unit needs technical documentation and an EU Declaration of Conformity showing it meets PPWR's design and recyclability requirements before it goes on the market. |
Does PPWR apply to UK businesses?
Yes, and it doesn't matter where your business is registered. What matters is whether your packaging ends up on the EU market. If a UK company sells a packaged product to a customer in France, Germany or any other EU member state, that packaging has been "placed on the market" in the EU, and PPWR applies to it. This covers online sellers too: selling a packaged product to an EU-based customer brings it into scope, regardless of where the sale itself takes place.
Micro-enterprises get some relief here, but it's narrower than it sounds. A micro-enterprise is a business with fewer than 10 employees and annual turnover or balance sheet total under €2 million. Where a micro-enterprise has packaging designed or made under its own brand, and its packaging supplier is based in the same EU member state, the supplier becomes legally responsible for PPWR compliance instead. The obligation moves but doesn't disappear.
Does PPWR apply in Northern Ireland?
Northern Ireland sits in an unusual position under the Windsor Framework. Most of PPWR's substantive requirements apply there just as they do across the rest of the EU: restrictions on substances of concern, recyclability rules, recycled content targets, compostability, packaging minimisation and labelling.
What doesn't carry over are the system and infrastructure obligations: reuse targets, refill infrastructure requirements and the wider waste collection and management measures. Those stay governed by the UK's own packaging Extended Producer Responsibility scheme (pEPR) rather than PPWR. For a business supplying goods to Northern Ireland specifically, or trading further into the EU, that means checking which parts of PPWR apply where, rather than assuming one answer covers the whole UK.
How does PPWR differ from the UK's own packaging rules?
It's easy to conflate PPWR with the UK's domestic packaging rules, and understandably so, since the names and subject matter overlap. But they're separate systems doing different jobs.
The UK's Plastic Packaging Tax is a domestic tax on packaging with insufficient recycled plastic content, administered by HMRC, and it only concerns the UK market. Alongside it sits the UK's own packaging EPR (pEPR) scheme mentioned above, the same one that continues to apply in Northern Ireland where PPWR's own infrastructure rules don't reach.
PPWR, by contrast, governs packaging placed on the EU market. A UK business trading in both directions may need to comply with its own domestic obligations for what it sells in the UK, and with PPWR separately for anything it exports into the EU. Neither replaces the other.
What are the PPWR compliance deadlines?
The European Commission’s PPWR regulation's obligations arrive in stages rather than all at once.
| Date | What happens |
|---|---|
|
11 February 2025
|
PPWR enters into force. |
|
12 August 2026
|
General application begins. PFAS limits in food-contact packaging apply, and a Declaration of Conformity is required for packaging placed on the market. |
|
1 January 2028
|
The European Commission's delegated acts defining the detailed design-for-recycling methodology are due. |
|
1 January 2030
|
Recyclability grading requirements apply (or 24 months after the Commission's delegated acts, if later). The first tier of recycled content targets applies. Packaging minimisation requirements apply. |
|
1 January 2035
|
A "recycled at scale" requirement is added to the recyclability assessment (or five years after the related implementing act, if later). |
|
1 January 2038
|
Grade C packaging is banned from the market; only Grade A or B remains compliant. |
|
1 January 2040
|
The second, higher tier of recycled content targets applies. |
What are the PPWR recyclability grades?
PPWR grades packaging recyclability as A, B or C. Any packaging that doesn't reach the Grade C threshold is classed as "technically non-recyclable" and barred from the market.
| Grade | Recyclability threshold (from 2030) | Status from 2038 |
|---|---|---|
|
A
|
95% or higher | Remains compliant |
|
B
|
80% or higher | Remains compliant |
|
C
|
70% or higher | Banned from the market |
|
Below 70%
|
— | Classed as technically non-recyclable; barred from the market from 2030 |
From 2035, a second factor is added: packaging also has to be recycled at scale in practice, not just theoretically recyclable, to keep its grade.
Does PPWR ban PFAS in packaging?
Yes, in food-contact packaging specifically. From 12 August 2026, food-contact packaging can't be placed on the market if it contains PFAS, often called "forever chemicals," above set limits: 25 parts per billion for any single PFAS substance, 250 parts per billion for the combined total of targeted PFAS, and 50 parts per million total fluorine, which acts as a trigger for further testing.
"Food-contact packaging" here means any packaging that's intended to touch food, or already does, under the scope of EU food law, which is broader than just packaging explicitly marketed as food-safe.
There's no grace period for existing stock, either. Food-contact packaging placed on the market after 12 August 2026 has to meet these limits. Packaging that was already on the market before that date can stay there and doesn't need to be pulled, but nothing new that fails to comply can be added to the shelf. That includes packaging made using recycled material, which gets no separate exception here.
Who needs an authorised representative?
If your business isn't established within the EU, a local branch office isn't enough to count as "established" for PPWR purposes. A branch has no separate legal identity from its parent company, so it can't take on the manufacturer's legal obligations in its own right. Where an EU member state requires it, that means either an EU-incorporated subsidiary, or an authorised representative appointed by written mandate to handle PPWR compliance on your behalf.
This is exactly the step the UK government's own guidance flags as part of getting ready: businesses are advised to consider whether an authorised representative needs to be appointed to manage EU compliance obligations locally, alongside registering with the relevant national EPR schemes in each country they sell into.
How can businesses prepare for PPWR compliance?
It isn't too late. Here are some of the actions you can start implementing right now:
Map your packaging
Build a full inventory of what you use, by material, format and supplier, across primary, secondary and transport packaging.
Assess recyclability against the grading
Identify anything likely to fall below the Grade C threshold now, before 2030 turns it into a market-access problem rather than a design one.
Start supplier engagement early
PPWR's technical documentation requirements (Article 16) mean collecting real data from suppliers rather than estimating it. It's much the same discipline as Scope 3 supplier engagement more broadly, and often the slowest part of the process to get moving.
Prepare your technical documentation and DoC
These need to be kept for 5 years for single-use packaging, or 10 years for reusable packaging, and made available to authorities within 10 days of a request.
Confirm your authorised representative needs
If you're not established in the EU, work out whether the Member State you're selling into requires an EU-incorporated subsidiary or an authorised representative to handle PPWR compliance on your behalf.
Register with national EPR schemes
Register and report packaging data with the relevant EPR scheme in each EU country you sell into.
Frequently asked questions about PPWR
What's the difference between the old Packaging Waste Directive and PPWR?
The old directive (94/62/EC) let each EU country write its own national rules. PPWR is a regulation, so it applies directly and identically everywhere in the EU, with no national version to look up.
Does everything that holds a product count as "packaging" under PPWR?
Not automatically. The test is functional: an item counts as packaging if it's used to contain, protect, handle, deliver or present a product without being an integral part of it. A pre-filled IV bag, for instance, isn't packaging. It's an integral delivery device instead. A dust bag for shoes is packaging if it's supplied as part of the product; if it's sold separately, it isn't.
Are micro-enterprises exempt from PPWR?
Not exempt. The compliance obligation shifts instead. If a micro-enterprise has packaging designed under its own brand and its supplier is based in the same EU country, the supplier takes on the legal manufacturer role, not the micro-enterprise.
Is packaging for dangerous goods or custom industrial equipment exempt from PPWR?
Partially. Packaging for dangerous goods is exempt from three specific requirements: recyclability, recycled content and reuse targets. It still needs technical documentation, a Declaration of Conformity and EPR registration like any other packaging. Custom-designed packaging for large machinery is exempt from re-use targets specifically, not from PPWR as a whole.
What about Greenly?
Getting PPWR-ready comes down to data: what your packaging is made of, how recyclable it really is, and being able to prove it when asked. That's the same groundwork behind a solid Life Cycle Assessment, and behind genuine supplier engagement, both of which Greenly's platform is already built to support. If gathering PPWR-ready data feels like starting from zero, it's worth checking how much of it your existing LCA or supplier work already covers.
Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste, EUR-Lex
Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste, European Commission
EU PPWR – Packaging and Packaging Waste Regulation, Department for Business, Innovation, Science and Trade
Packaging & Packaging Waste Regulation, European Commission
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