If your business sells into the EU, there’s a new piece of regulation you need to have on your radar: the Packaging and Packaging Waste Regulation (PPWR).

And yes, packaging regulation might not be the most exciting thing on your to-do list, but this one matters.

The new rules affect packaging placed on the EU market and introduce requirements around everything from recyclability and documentation to labelling, recycled content and Extended Producer Responsibility (EPR).

The first obligations started applying from 12 August 2026, so now is the time to understand where your business sits.

With guidance from Hooper & Co International Trade Consultancy, we’ve broken down the key points into a practical HGA Takeaway.

First things first: what is the PPWR?

The EU Packaging and Packaging Waste Regulation - Regulation (EU) 2025/40 - replaces the previous Packaging Directive.

The important difference is that this is a Regulation rather than a Directive. That means the core rules apply directly across EU Member States rather than each country having to introduce them separately into national law.

It came into force on 11 February 2025, with obligations beginning to apply from 12 August 2026.

“But we're a UK business. Does this actually apply to us?”

Potentially, yes.

What matters isn't where your business is based or where your packaging was manufactured.

Packaging originating anywhere in the world can fall within the regulation once it reaches the EU market, whether it is supplied on its own or around a product.

For HGA members exporting products from the UK into the EU, this is an important distinction.

What actually counts as packaging?

Potentially more than you might think.

The regulation covers:

• Sales packaging
• Grouped packaging
• Transport packaging
• Service packaging
• E-commerce packaging
• Primary-production packaging

And it isn't limited to plastic.

Paper, cardboard, glass, metal, wood, textiles and composite materials can all be covered.

For anything less straightforward, the regulation points businesses towards the definitions in Article 3 and examples within Annex I.

One of the most important things to establish: your role

This is where things can get confusing.

Under PPWR, your responsibilities depend on the role you're performing within the supply chain, rather than simply what type of company you consider yourself to be.

In fact, the same business could be considered a manufacturer for one product line and a distributor for another.

What changed from 12 August 2026?

This is the date businesses should have firmly in their diaries.

From 12 August 2026, the first design and documentation requirements are live, including requirements relating to substances of concern, recyclability and reusable packaging where relevant.

Depending on your role and packaging, requirements can include:

• Carrying out a conformity assessment against the applicable packaging requirements
• Keeping technical documentation in line with Annex VII
• Having an EU Declaration of Conformity in line with Annex VIII
• ID and type, batch or serial marking
• Keeping records for five years for single-use packaging and 10 years for reusable packaging

Importers also have requirements around identification and checking manufacturers, while distributors have due-care responsibilities.

What's a Declaration of Conformity?

Put simply, it's the manufacturer's signed statement confirming that the packaging meets the applicable requirements.

It's based on the conformity assessment and information provided by suppliers.

Other parties can help prepare the supporting information, and an authorised representative can draft the declaration under a written mandate, but the responsibility remains with the manufacturer.

If you're already producing another EU Declaration of Conformity, the PPWR guidance says a combined declaration can be used, provided it clearly distinguishes the packaging requirements from those relating to the product.

What about chemicals and substances of concern?

There are also concentration limits businesses need to be aware of.

For packaging generally, the combined concentration of:

Food-contact packaging

There are additional PFAS limits specifically for food-contact packaging:

What happens next?

Not every part of PPWR lands at once.

There are several important dates ahead.

Some other deadlines, particularly around sorting and reuse labels, aren't yet fixed because they depend on further European Commission acts.

Do you need to register or pay into an EPR scheme?

If you're classed as a producer, you may have another important responsibility.

Producers must register nationally in each Member State where they first supply packaging. According to the guidance, the registration requirement itself has no threshold.

There is a practical exception involving certain micro-businesses where a micro brand owner purchases from a supplier within the same Member State, in which case the supplier takes the producer role.

Whether you need to participate in a collective EPR scheme can also vary by Member State.

Some of the detail is still being worked out

This is particularly important.

PPWR is now applying, but parts of the framework are still pending.

These include:

• The thresholds for recyclability grades A, B and C
• The methodology for calculating recycled-content percentages
• Sorting and reuse label pictograms
• The methodology for calculating empty space
• Further guidance on Annex V packaging formats, due by 12 February 2027

So, while businesses need to act on the requirements already in place, it's equally important to keep an eye on further European Commission guidance as it develops.

The HGA Takeaway

Start by mapping your packaging and supply chain.

Work out what packaging you place on the EU market, what role you play, where you sell it and who is responsible for the relevant documentation.

From there, you can identify which requirements apply now and which future deadlines you need to prepare for.

And most importantly, don't make assumptions based simply on being a UK business. If your products are reaching customers in the EU, PPWR is something you need to understand.

A final note