EU Packaging Restrictions Compliance: Latest PPWR Updates and What Businesses Must Do Before 2026

EU Packaging Restrictions Compliance is now a major market-access topic for any business placing packaging or packaged products on the EU market. The new Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and will generally apply from 12 August 2026. It replaces the older Packaging and Packaging Waste Directive and creates a more harmonised EU framework for packaging design, restricted substances, recyclability, recycled content, labelling, reuse, refill, Extended Producer Responsibility and technical documentation.

For manufacturers, importers, brand owners, retailers, packaging suppliers and online sellers, the message is clear: packaging can no longer be managed only through artwork files, supplier emails and spreadsheets. Under PPWR, packaging compliance needs structured data, supplier evidence, conformity documentation and marketability decisions.

Step 1: Identify all packaging in scope

Start by mapping every packaging type used by your business. Include sales packaging, grouped packaging, transport packaging, e-commerce packaging, service packaging and reusable packaging.

This should include packaging used for finished products, spare parts, samples, promotional kits, private-label products and online orders.

What is the latest update on EU Packaging Restrictions Compliance?

The most important update is that PPWR is no longer a proposal. It is adopted EU law. The European Commission also published Frequently Asked Questions on 30 March 2026 to support businesses and Member States with implementation.

The Regulation aims to reduce unnecessary packaging, make packaging more recyclable, increase the use of recycled materials and limit harmful substances. The European Commission states that the Regulation covers all packaging and packaging waste, regardless of material or origin, and aims to make all packaging on the EU market recyclable in an economically viable way by 2030.

3. Packaging minimisation and empty-space control

PPWR requires companies to reduce unnecessary packaging and avoid excessive packaging. The European Commission states that the Regulation aims to limit unnecessary packaging and reduce packaging waste.

This is especially important for e-commerce, transport and grouped packaging. Businesses should review oversized cartons, unnecessary layers, excessive void fill and packaging designs that make the product appear larger than it is.

For fulfilment and logistics teams, this means packaging optimisation is no longer only about cost reduction. It is also part of compliance.

Does PPWR apply to your business?

PPWR may apply to your business if you place packaging or packaged products on the EU market. This includes companies based inside or outside the EU.

You should assess EU Packaging Restrictions Compliance if your company:

• manufactures packaging;
• imports packaged products into the EU;
• sells packaged goods in the EU;
• sells through e-commerce channels;
• supplies private-label products;
• uses transport, grouped or e-commerce packaging;
• places food-contact packaging on the EU market;
• manages packaging artwork, labels or packaging specifications;
• has EPR reporting obligations in EU Member States.

The Regulation applies to manufacturers, importers, distributors and retailers, and it covers primary, secondary, tertiary and service packaging. UK government guidance for exporters also highlights that non-EU companies selling packaged goods into the EU need to review PPWR obligations before the 12 August 2026 application date.

Why EU Packaging Restrictions Compliance matters now

Packaging compliance is not only a sustainability issue. It affects whether a product can be placed on the EU market, whether packaging evidence can be shown during an audit, whether EPR data can be reported correctly and whether suppliers can prove that materials meet the required restrictions.

Non-compliance can create practical business risks such as delayed product launches, rejected shipments, missing EPR registrations, urgent packaging redesign, unsupported recycled-content claims, incomplete supplier evidence, artwork rework and customer pressure. For exporters, official UK guidance notes that non-compliance could result in goods being rejected at EU borders.

Key PPWR requirements businesses need to understand

1. General application date: 12 August 2026

The main PPWR application date is 12 August 2026. From this date, many companies will need to show that packaging placed on the EU market meets relevant requirements on substances, design, minimisation, documentation and conformity.

This date is closer than it looks. Packaging redesign, supplier data collection, material testing, label updates, EPR checks and technical documentation preparation can take months, especially for companies with large product portfolios or complex supply chains.

2. Restricted substances: heavy metals and PFAS

PPWR continues the EU restriction on heavy metals in packaging. The combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg in packaging or packaging components.

A major update is the restriction of PFAS in food-contact packaging. From 12 August 2026, food-contact packaging cannot be placed on the EU market if PFAS exceed the relevant thresholds. Reported thresholds include 25 ppb for any individual targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS including polymeric PFAS.

For businesses, this means food-contact packaging should be reviewed carefully. High-risk areas may include grease-resistant papers, moulded fibre, coatings, inks, adhesives, recycled inputs and other materials where fluorinated substances may be present.

4. Recyclability requirements by 2030

One of the central PPWR objectives is to make all packaging recyclable by 2030. The Regulation introduces recyclability performance grades from 2030, with stricter obligations later, including recycled-at-scale expectations from 2035.

This affects packaging design decisions today. Companies should review material combinations, multilayer structures, labels, sleeves, inks, adhesives, coatings, closures and separability. A packaging item that appears recyclable in theory may still create compliance risk if it cannot be sorted, collected and recycled effectively.

5. Recycled content targets for plastic packaging

PPWR introduces minimum recycled-content targets for plastic packaging by 2030 and higher targets by 2040. The Commission describes recycled content in plastic packaging as one of the main measures under the new Regulation.

This creates a documentation challenge. Companies will need reliable evidence showing recycled-content levels, material origin, supplier declarations and traceability. Recycled-content claims should be supported by controlled data, not marketing statements alone.

6. Labelling and consumer information

PPWR introduces new labelling and consumer information requirements to support sorting, recycling and reuse. The Regulation aims to ensure that packaging is clearly labelled and that consumers can sort packaging waste more effectively.

Companies should prepare early because packaging labelling changes affect artwork, translations, SKU management, packaging suppliers and stock planning. Poor artwork control can easily create compliance gaps if old and new packaging versions are mixed in the supply chain.

7. Reuse, refill and single-use restrictions

PPWR includes measures to promote reuse and refill and to restrict certain unnecessary single-use packaging formats. The European Commission states that the new rules include promoting reuse and refill alternatives and improving consumer information.

This matters for food service, takeaway packaging, beverage packaging, transport packaging and certain retail formats. Companies should assess whether their packaging is affected by reuse, refill or single-use restrictions, rather than assuming that recyclability alone is enough.

8. EPR registration and reporting

Extended Producer Responsibility remains a key part of packaging compliance. Businesses selling packaged goods into EU Member States may need to register with national EPR schemes, report packaging data and pay relevant fees. Official UK guidance highlights the need to provide packaging data such as packaging type, weight, recyclability and recycled content, and to consider whether an authorised representative is needed.

This is one of the areas where clients often struggle most. EPR data depends on accurate packaging weights, material categories, country rules, supplier information and product-level packaging records.

What documents do companies need for PPWR compliance?

To prepare for EU Packaging Restrictions Compliance, companies should start collecting and controlling evidence now. Typical documentation may include:

• packaging Bill of Materials;
• packaging material composition data;
• packaging component specifications;
• supplier declarations;
• heavy metal evidence;
• PFAS evidence or test reports where relevant;
• recycled-content documentation;
• recyclability assessment records;
• packaging weight and volume data;
• empty-space or packaging minimisation assessment;
• labelling and artwork approval records;
• EPR registration and reporting data;
• technical documentation;
• EU Declaration of Conformity where required.

The European Commission guidance notes that the manufacturer is the obligated party that needs to carry out the conformity assessment and draft the technical documentation and EU declaration of conformity for packaging.

Practical PPWR compliance roadmap

Step 2: Build a packaging Bill of Materials

Create a structured packaging Bill of Materials for each packaging item or packaging configuration. At minimum, capture:

• packaging item name or code;
• packaging type;
• material type;
• component weight;
• supplier;
• country of use;
• recycled content;
• coatings, inks and adhesives;
• food-contact status;
• relevant evidence and declarations.

Without this structure, it becomes difficult to assess compliance, prepare EPR data or prove why a packaging item is marketable.

Step 3: Classify your role

Determine whether your company acts as a manufacturer, importer, distributor, producer, retailer, fulfilment service provider or online seller for each packaging scenario.

This matters because obligations can vary depending on your role in the supply chain.

Step 4: Screen restricted substances

Review heavy metals, PFAS and other substances of concern. Food-contact packaging should receive special attention because of the PPWR PFAS restriction from August 2026.

Supplier declarations may be useful, but for high-risk materials, companies may also need test reports or additional technical justification.

Step 5: Assess recyclability and design

Check whether packaging is designed for recycling and whether it may meet future recyclability performance requirements. Focus on material complexity, separability, labels, adhesives, dark colours, coatings and incompatible material combinations.

Step 6: Review packaging minimisation

Assess whether the packaging weight and volume are limited to what is necessary for product protection, logistics, hygiene, safety and consumer acceptance.

For e-commerce and transport packaging, review carton sizing, air pillows, paper fill, bubble wrap and other void-fill materials.

Step 7: Prepare labelling updates

Plan packaging label changes early. Artwork updates should be controlled through version history, approval workflows and market-specific review.

This is especially important for companies selling the same product in multiple EU countries.

Step 8: Organise EPR data

Collect packaging weights, material categories, sales countries, product links and supplier records. EPR reporting becomes easier when packaging data is connected to product and market data from the beginning.

Step 9: Keep evidence audit-ready

Create a controlled record for each packaging item, including declarations, test reports, assessments, supplier communication and approval status.

A compliance conclusion is only reliable if the evidence behind it is easy to find, current and linked to the correct packaging version.

Why spreadsheets are not enough for PPWR compliance

Spreadsheets may help at the beginning, but they become risky when packaging portfolios grow, suppliers change materials, evidence expires or requirements differ by market.

PPWR compliance requires a live connection between packaging items, materials, suppliers, substances, regulations, documents, deadlines and markets. A spreadsheet can easily show a packaging item as “compliant” without proving which regulation was checked, which evidence was reviewed, whether the evidence is still valid or whether the same status applies in every EU country.

This is where software becomes valuable. Companies need a system that can track requirements, collect supplier evidence, manage documentation, flag missing information and support marketability decisions before products are released.

How ComplyMarket product compliance software can help

ComplyMarket helps companies turn packaging compliance into a controlled, audit-ready process. Its Packaging Compliance Management approach is built around identifying applicable packaging rules, linking those rules to packaging items or packaged products, collecting data and supplier evidence, validating compliance status and deciding where packaging can be placed on the market.

ComplyMarket’s Product Compliance Management Software is designed to give manufacturers, importers and product managers a centralised platform for managing regulatory obligations. It supports regulatory libraries, evidence management, marketability monitoring, early warnings and collaboration with suppliers and internal teams.

For EU Packaging Restrictions Compliance, ComplyMarket can help companies:

How ComplyMarket supports a step-by-step PPWR readiness process

1. Packaging inventory management

ComplyMarket can help companies build a central packaging inventory where each packaging item is treated as a compliance object. This allows teams to connect packaging records with materials, suppliers, products, documents and applicable regulations.

2. Supplier questionnaire management

Much of PPWR compliance depends on supplier data. ComplyMarket can support structured supplier questionnaires so companies can request consistent information about material composition, recycled content, restricted substances, test reports and declarations.

3. Evidence and documentation control

ComplyMarket helps organise compliance evidence such as declarations, certificates, test reports, technical documents and supplier responses. This supports audit readiness and reduces the risk of losing evidence in emails or shared folders.

4. Regulatory requirement mapping

ComplyMarket enables companies to build and manage regulatory libraries, then assign regulations to products, components, materials or substances. This helps teams understand which requirements apply to each packaging item.

5. Marketability and risk monitoring

ComplyMarket supports marketability checks and warning systems to help companies identify missing evidence, expired documents or non-compliant products before they reach the market.