EU Packaging and Packaging Waste Regulation: Is your business ready?

On 12th August 2026, the Packaging and Packaging Waste Regulation (PPWR), Regulation 2025/40, will begin to apply across the European Union, introducing a new harmonised framework for packaging placed on the EU market.

While much of the discussion around the PPWR has focused on its long-term ambitions —such as recyclable packaging, recycled content targets and reusable packaging— it is important to note that not all those requirements become applicable from 12th August 2026. Many provisions will apply gradually over the coming years, while others depend on the adoption of further implementing acts by the European Commission, such as the ones related to the recyclability of packaging and minimum recycled content.

Nevertheless, businesses should not assume the Regulation can be set aside until 2030. Several important obligations begin to apply from August 2026, and the Regulation may bring new responsibilities for businesses that have not traditionally regarded themselves as packaging manufacturers.

Why should businesses pay attention?

Unlike the previous Packaging and Packaging Waste Directive, the PPWR is a Regulation, meaning it applies directly across all EU Member States without requiring national transposition (i.e. the need to create, rewrite or update domestic laws to become applicable).

One of the most significant changes is the introduction of a product compliance framework for packaging, like the approach already used for other regulated products such as machinery, electrical equipment and medical devices.

From 12th August 2026, businesses under the PPWR scope will be required to carry out a conformity assessment, prepare technical documentation and draw up an EU Declaration of Conformity for the packaging they place on the market.

For many businesses, these may be entirely new obligations.

Could your business now be considered a manufacturer?

Many companies do not physically manufacture packaging themselves but still place packaged products on the EU market.

Under the PPWR, the definition of manufacturer is broader than simply producing packaging materials. For example, a company selling own-brand packaged products could have manufacturer responsibilities under the PPWR, even where its packaging has been produced and supplied by a third party.

However, manufacturers are not the only businesses covered by the PPWR. The Regulation also assigns obligations to other economic operators, including importers, distributors, authorised representatives and fulfilment service providers. The obligations that apply under the PPWR will therefore depend on each organisation's role within the packaging supply chain.

What actually applies from August 2026?

Although the PPWR contains a wide range of new requirements, only some become applicable from 12th August 2026, while others will apply progressively over the coming years.

For example, Article 5 of the PPWR, which sets requirements relating to substances in packaging, will be applicable, while other well-known PPWR requirements —such as recyclability, minimum recycled content, harmonised labelling and certain reuse requirements— will become applicable at later dates or once further delegated or implementing acts have been adopted.

Businesses should therefore distinguish between:

• requirements that apply from August 2026;

• and future requirements that should already be considered as part of longer-term packaging planning.
  

Understanding which provisions apply to your organisation will depend on your role in the packaging supply chain, the packaging you intend to place in the EU market and your specific business activities.

Changes to Packaging Extended Producer Responsibility (EPR)

Businesses should also be aware that the PPWR introduces important changes to Packaging Extended Producer Responsibility (EPR).

Under Article 44, all producers will be required to register in the Producer Register of each Member State in which they make packaging or packaged products available on the market for the first time.

This is particularly relevant in Ireland, where many businesses have historically assessed their packaging EPR obligations by reference to annual turnover and packaging-tonnage thresholds.

Businesses that have not previously been considered to be within the EPR scheme obligations scope should therefore review whether their obligations may change as the new framework is implemented in Ireland.

What should businesses do now?

Although the PPWR will be implemented progressively over the coming years, there are several practical steps businesses can begin taking now:

• Assess whether your organisation is in scope of the PPWR and identify your role within the packaging supply chain (e.g. manufacturer, importer, distributor or supplier).

• Understand which PPWR requirements apply from 12th August 2026, and which apply at a later date.

• Engage with your packaging suppliers to understand what compliance information and supporting documentation is available.

• Review your Packaging EPR obligations and monitor forthcoming implementation measures.

• Begin considering how future packaging innovation may support compliance with upcoming recyclability, recycled content and circular design requirements.
  

For many organisations, particularly SMEs, the greatest challenge may not be the immediate obligations but understanding how the Regulation applies to their business and preparing for the more significant changes that will follow.

How we can support from CIRCULÉIRE

The PPWR represents one of the most significant changes to packaging regulation in recent years. Its relevance extends beyond the packaging industry itself. While not every business will be directly affected in the same way, organisations across manufacturing, retail, construction, food, healthcare and many other sectors should take the opportunity to understand how the new framework may affect their operations.

The CIRCULÉIRE membership includes one-to-one Policy Clinics to better understand emerging policy and regulatory developments, discuss how new legislation may apply to their organisation and identify practical next steps. Not sure whether the PPWR applies to your organisation? If you would like to better understand your obligations or discuss how the Regulation may affect your business, please get in touch with the CIRCULÉIRE team to arrange a Policy Clinic. We'd be happy to support you. #PPWR #EURegulation #Packaging #PackagingWaste #PolicyUpdate #CIRCULÉIRE #CircularEconomy