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Media > All articles > Legislation & Standards > PPWR: What the EU's Packaging Regulation Means for US Businesses

PPWR: What the EU's Packaging Regulation Means for US Businesses

ESG / CSRLegislation & Standards

Level

By Agnès Potier-Murphy, International Copywriter, on 09/17/2026

What is PPWR?
Does PPWR apply to US businesses?
What are the PPWR compliance deadlines?
What are the PPWR recyclability grades?
Does PPWR ban PFAS in packaging?
Who needs an authorised representative?
How can businesses prepare for PPWR compliance?
Frequently asked questions about PPWR
What about Greenly?

PPWR can sound like a distant EU problem, easy for a US-based business to write off. But the assumption doesn't hold up: if a packaged product you sell ends up with a customer anywhere in the EU, whether it shipped from Ohio or Oregon, the Packaging and Packaging Waste Regulation already covers it. Because it's a regulation, it took hold across the EU all at once rather than rolling out country by country. And since August 12, 2026, packaging that falls short of its requirements can't legally reach the EU market at all.

For US exporters, the deadline is already behind us. This guide walks through what PPWR actually requires, how it relates to (and stays entirely separate from) the state-level packaging laws you may already be tracking domestically, and where a surprising amount of existing guidance gets the details wrong.

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, no matter 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 August 12, 2026, with no grace period for pre-deadline stock that hasn't yet reached the market
PPWR doesn't replace the packaging EPR laws already in effect in seven US states. They're separate obligations that simply coexist

What is PPWR?

PPWR is short for the Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40. It's the centerpiece of the EU's sustainable packaging agenda: binding requirements for how packaging is designed, how recyclable it has to be, and how it's labeled, for anything placed on the EU market. Because it's a regulation rather than a directive, it took effect the same way in every EU member state at once, with no country-specific version to wait on or watch for.

At its core, PPWR asks three things of a business: is your packaging recyclable, does it contain enough recycled material, and can you document 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 US businesses?

Yes. PPWR applies based on where the packaging ends up, regardless of where the business itself is based. If a US company ships a packaged product to a customer in Germany, France, or any other EU country, that packaging counts as "placed on the market" in the EU, and PPWR applies to it, full stop. Selling through an online store doesn't change that: a sale to an EU-based customer brings the packaging into scope regardless of where the transaction happened.

There's a narrower exception for micro-enterprises, though it's easy to overstate. A micro-enterprise is defined as 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 the company supplying that packaging is based in the same EU member state, that supplier simply becomes responsible for PPWR compliance in the micro-enterprise's place.

How does PPWR differ from US state packaging laws?

It's tempting to think of PPWR as simply Europe's version of the packaging laws already reshaping compliance work in the US, but treating the two as interchangeable is a real risk.

Seven states have their own packaging extended producer responsibility (EPR) laws already on the books: California, Oregon, Colorado, Maine, Minnesota, Maryland and Washington. Each has its own scope, registration deadlines and fee structure. There's no federal program tying them together. A business selling packaged goods nationwide is already juggling seven separate sets of domestic rules, with more states expected to follow.

California's SB 54 is the one most businesses have heard of, partly because its path to implementation hasn't been smooth. The state withdrew its draft regulations in January 2026 to revise them, and it wasn't until 1 May 2026 that the Office of Administrative Law approved permanent regulations, which took effect immediately upon filing.

None of that touches PPWR, and PPWR doesn't touch any of it. PPWR governs packaging placed on the EU market only. Complying with SB 54, or Oregon's Recycling Modernization Act, or any other state program, doesn't satisfy a single PPWR requirement for goods headed to the EU, and PPWR compliance doesn't excuse a business from its state obligations at home. The two simply run in parallel.

If it's any consolation, the state-by-state patchwork is a useful comparison point. It's close to the exact fragmentation PPWR itself was designed to avoid at the EU level, replacing a directive that let each EU country set its own rules with a single regulation instead of 27 separate national versions.

What are the PPWR compliance deadlines?

The European Commission’s PPWR regulation's obligations arrive in stages rather than all at once, and the schedule doesn't change based on where a business is exporting from.

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, and only those three. A lot of guidance circulating online describes a five-tier A-to-E scale instead, a claim the European Commission's own guidance on the regulation directly contradicts. Packaging that falls short of the Grade C threshold gets no letter grade at all. It's classified as "technically non-recyclable" and kept off the market entirely.

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

A second factor gets added from 2035: packaging also has to actually be recycled at scale in practice to hold onto its grade.

Does PPWR ban PFAS in packaging?

Yes, specifically in food-contact packaging, and this is one area where US businesses may already have more context than they realize, given how much attention "forever chemicals" gets domestically. It's also one of the European Commission's own headline aims for the regulation. From August 12, 2026, food-contact packaging containing PFAS above set limits can't go on the EU market: 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 triggers further testing if exceeded.

"Food-contact packaging" isn't limited to packaging explicitly marketed as food-safe. It covers anything intended to touch food, or already in contact with it, under the scope of EU food law.

There's no grace period tied to when packaging was manufactured. What matters is when it's placed on the market: food-contact packaging placed on the market after 12 August 2026 has to meet these limits, full stop, even if it was produced earlier using existing stock. Packaging already on the market before that date can stay there without being pulled. Packaging containing recycled material gets no separate exception either way.

Who needs an authorised representative?

A US business without any EU establishment can't rely on a local branch office to satisfy PPWR. A branch has no legal identity separate from its parent company, so it can't take on the manufacturer's legal obligations in its own right. Where the EU member state in question requires it, that means either setting up an EU-incorporated subsidiary, or appointing an authorized representative by written mandate to handle PPWR compliance on the business's behalf.

This is a step worth budgeting real time for: identifying the right representative, confirming which member states actually require one, and getting the mandate in writing all take longer than most businesses expect on a first pass.

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.

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, counts as an integral delivery device rather than packaging. 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. Responsibility for compliance simply shifts to someone else: if a micro-enterprise has packaging designed under its own brand and its supplier is based in the same EU country, that supplier takes on the legal manufacturer role.
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 gets a narrower carve-out: exemption from re-use targets specifically, rather than from PPWR altogether.
Does complying with my state's packaging EPR law also satisfy PPWR?
No. State programs like California SB 54 govern packaging sold domestically; PPWR governs packaging placed on the EU market. Meeting one doesn't fulfill the other, and a business doing both needs to track them separately.

What about Greenly?

Thumbnail for the Greenly product overview video (July 2026 version)

Getting PPWR-ready comes down to data: what your packaging is made of, how recyclable it actually is, and being able to prove it when asked. If you're already navigating state-level packaging EPR reporting, some of that groundwork will feel familiar. It's also close to the same discipline behind a solid Life Cycle Assessment and behind genuine supplier engagement, both of which Greenly's platform already supports. If PPWR data collection feels like starting over, it's worth checking how much of it your existing LCA or supplier work already covers.

See how Greenly can help!