Businesses sending packaged products to the European Union need to prepare for a major change to the rules governing packaging and packaging waste.
The EU Packaging and Packaging Waste Regulation, commonly known as PPWR, entered into force in February 2025 and will begin applying from 12 August 2026 (See the European Commission overview.)
Its requirements extend well beyond consumer-facing boxes, bottles and containers. The regulation covers packaging used throughout the supply chain, including grouped packaging, shipping cartons, pallets, protective materials and certain forms of e-commerce packaging.
For UK exporters, the PPWR may affect how products are packaged, what information must be obtained from suppliers, and which party is responsible for demonstrating compliance before packaged goods are placed on the EU market.
What is the EU Packaging and Packaging Waste Regulation?
Regulation (EU) 2025/40 replaces the existing EU Packaging and Packaging Waste Directive with a directly applicable regulation.
Its purpose is to reduce packaging waste, improve recyclability, increase the use of recycled material and encourage greater reuse across the EU.
Rather than introducing every requirement at once, the PPWR establishes a series of obligations and targets that will be phased in over several years. Some provisions will generally apply from August 2026, while further labelling, recyclability, recycled-content, minimisation and reuse requirements will follow later.
The legislation applies to packaging placed on the EU market, regardless of whether the packaged product was manufactured within the EU or imported from another country.
Who could be affected?
The PPWR creates responsibilities for different economic operators, including manufacturers, importers, distributors and fulfilment service providers.
For goods exported from the UK, the EU-based importer will often have an important role because it is placing imported packaged products on the EU market. However, UK manufacturers and exporters are still likely to be asked to provide packaging information and supporting documentation.
Businesses likely to be affected include:
- UK manufacturers selling packaged goods into the EU
- exporters supplying EU distributors or retailers
- e-commerce businesses selling to EU customers
- packaging manufacturers and suppliers
- EU importers receiving products from the UK
- businesses that pack, repack or add packaging to goods
The exact responsibilities will depend on the contractual arrangements, supply-chain structure and the role each business performs.
What types of packaging are covered?
The PPWR has a broad scope and applies to packaging used to contain, protect, handle, deliver or present products.
This includes:
Primary packaging
Packaging that directly contains or surrounds the product, such as bottles, jars, tubs, cartons and sachets.
Grouped or secondary packaging
Packaging used to group several products together, including multipack cartons and certain types of wrapping.
Transport packaging
Packaging used to protect or handle products during storage and transportation, such as shipping cartons, crates and pallets.
E-commerce packaging
Packaging used when products are delivered through online sales and fulfilment networks.
Whether a particular item is legally considered packaging will depend on its purpose and how it is supplied. Items that form an integral and permanent part of a product may fall outside the definition, while disposable items used to contain or present that product are more likely to be covered.
What changes from 12 August 2026?
The PPWR will generally apply from 12 August 2026, although individual provisions have their own dates and some requirements depend on further EU legislation or technical standards.
One of the most significant areas is packaging conformity.
Manufacturers of packaging must carry out the relevant conformity assessment, prepare technical documentation and draw up an EU Declaration of Conformity before covered packaging is placed on the EU market.
Importers must also check that the relevant conformity procedures have been completed and that required documentation and information are available.
This does not necessarily mean a Declaration of Conformity will accompany every freight movement or routinely be presented during customs clearance. However, businesses may need to make documentation available to the appropriate market-surveillance authority when requested.
UK exporters should therefore speak with their packaging suppliers and EU importers to establish:
- who is responsible for the packaging concerned
- what conformity documentation is required
- where supporting records will be stored
- how information can be supplied if requested
- whether packaging materials or designs need to change
Restrictions affecting food-contact packaging
From 12 August 2026, the PPWR restricts food-contact packaging containing per- and polyfluoroalkyl substances, commonly known as PFAS, at or above specified concentration limits.
PFAS have been used in some packaging applications because of their resistance to grease, oil and water.
Businesses exporting food, drink or other products using food-contact packaging should confirm the material composition of their packaging with suppliers and obtain appropriate supporting information.
The regulation also contains restrictions concerning the concentration of certain heavy metals in packaging.
Future packaging requirements
The PPWR is not limited to the August 2026 application date. Several important measures are due to be introduced later.
Recyclability
From 2030, packaging placed on the EU market will need to meet recyclability requirements established under the regulation.
The EU intends to assess packaging according to recyclability performance grades. Packaging falling below the required threshold may eventually be prevented from being placed on the market.
More detailed criteria and assessment methods will be established through further EU measures.
Recycled plastic content
Minimum recycled-content requirements will apply to a range of plastic packaging from 2030.
The required percentage will vary according to the type and use of the packaging, with further targets scheduled for 2040.
Businesses using plastic packaging should begin discussing recycled-content data and future material availability with suppliers.
Packaging minimisation
By 2030, packaging will generally need to be designed so that its weight and volume are reduced to the minimum necessary while maintaining its function.
Factors such as product protection, transportation, storage, hygiene, legal requirements and usability may be considered when determining what packaging is necessary.
Empty space
The regulation introduces a maximum empty-space ratio for certain grouped, transport and e-commerce packaging from 2030.
This is intended to reduce oversized cartons and unnecessary void-fill materials. The detailed calculation method will be established through further legislation.
Reuse targets
Reuse targets will apply to certain forms of transport and sales packaging from 2030.
These provisions are detailed and contain conditions, exemptions and different rules for different packaging formats and movements. Businesses should avoid assuming that one percentage applies universally across every pallet, carton, wrap or strap used in their operations.
What should UK exporters do now?
Although some technical details are still being developed, businesses do not need to wait before beginning their preparations.
Review the packaging used for EU shipments
Create a record of the primary, grouped and transport packaging used when products are sent to the EU.
This should include packaging materials, suppliers, weights and available composition information.
Speak with packaging suppliers
Ask suppliers what technical documentation, material declarations and conformity information they will be able to provide.
Where food-contact packaging is used, businesses should also ask about PFAS and other restricted substances.
Confirm responsibilities with EU customers
Establish who acts as the EU importer and which party will be responsible for the different compliance requirements.
These responsibilities should be clearly reflected in commercial agreements where appropriate.
Assess future packaging design
Packaging that is difficult to recycle, contains unnecessary material or leaves excessive empty space may require changes ahead of the later PPWR deadlines.
Early planning could reduce the risk of rushed redesigns, restricted material availability or increased compliance costs.
Review national EPR obligations
Extended Producer Responsibility requirements are administered at Member State level.
Businesses selling packaged products into the EU should establish whether they or another party in the supply chain must register, report packaging quantities or pay packaging-related fees in each relevant country.
Specialist advice may be needed where products are sold directly to consumers across several EU markets.
What does PPWR mean for freight movements?
The PPWR is principally a product and packaging compliance regulation rather than a new customs procedure.
Businesses should not assume that a Declaration of Conformity will automatically need to be submitted with every customs declaration. However, packaging compliance may still affect whether goods can legally be placed on the EU market.
Missing records, non-compliant packaging or unclear responsibilities could result in questions from importers or authorities and may cause commercial or operational disruption.
Exporters should ensure that their product, packaging, customs and logistics teams are working from the same information before goods are dispatched.
How Beckchoice can support your EU supply chain
Responsibility for meeting the PPWR requirements rests with the relevant economic operators rather than the freight forwarder simply arranging transportation.
However, Beckchoice can help customers plan their EU freight movements and understand where packaging-related changes may interact with their wider shipping arrangements.
Our team can support businesses with:
- UK and European road freight
- sea and air freight movements
- customs clearance and documentation
- coordination with overseas customers and supply-chain partners
- planning ahead for changes that may affect EU trade
We cannot issue packaging Declarations of Conformity or provide legal certification on behalf of manufacturers or importers. Businesses should obtain specialist legal, packaging or environmental advice where required.
Preparing for August 2026
The PPWR represents a significant change to the way packaging is regulated across the EU.
Not every obligation begins on 12 August 2026, and further detailed rules will continue to emerge. However, businesses exporting packaged goods to the EU should already be reviewing their packaging, speaking with suppliers and confirming responsibilities with their EU importers.
Preparing early will make it easier to identify missing information, adapt packaging designs and reduce the possibility of disruption as the new requirements take effect.
To discuss an upcoming shipment to or from the EU, contact the Beckchoice team.
References
European Commission – Packaging and Packaging Waste Official overview of the Packaging and Packaging Waste Regulation (PPWR), including implementation timelines, guidance and FAQs.
Regulation (EU) 2025/40 – EUR-Lex The full legal text of the Packaging and Packaging Waste Regulation, including definitions, scope and legislative requirements.
European Commission Guidance on PPWR (June 2026) Official guidance designed to help businesses and Member States interpret and implement the Regulation.