EU PPWR Compliance Guide for Market Access 2026

06-07-2026

EU PPWR Compliance Guide for Packaging Readiness 2026

The EU Packaging and Packaging Waste Regulation, commonly known as the PPWR, is one of the most important packaging compliance changes for companies placing packaged products on the EU market.

Packaging is no longer only a design, branding, logistics, or sustainability topic. Under the PPWR, packaging becomes a direct compliance and market access issue. Businesses must be able to prove that their packaging meets sustainability, labelling, recyclability, recycled content, reuse, minimization, documentation, and Extended Producer Responsibility requirements.

Regulation (EU) 2025/40 on packaging and packaging waste entered into force on 11 February 2025 and will generally apply from 12 August 2026. The European Commission states that the PPWR covers all packaging and packaging waste, regardless of material or origin, and sets requirements for manufacturing, composition, reusable or recoverable nature, waste management, and waste prevention.

For manufacturers, importers, distributors, retailers, online sellers, and brand owners, this means packaging compliance must be managed with the same discipline as product compliance. Companies need accurate packaging data, supplier evidence, technical files, market-specific EPR information, and a clear process for updating documentation when packaging changes.

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Restrictions on Certain Packaging Formats

The PPWR restricts certain packaging formats to reduce avoidable packaging waste. Companies should review their packaging portfolio to identify formats that may be affected.

Restricted packaging formats include:

Packaging Format	Example
Single-use plastic grouped packaging	Collation films and shrink wrap used to encourage multi-buy sales
Single-use packaging for fresh fruit and vegetables	Nets, bags, trays and containers for certain uses
Single-use food and beverage packaging in HORECA	Disposable plates, cups, trays, bags, foil and boxes
Single-use condiment and seasoning packaging	Sachets, tubs and small serving packs
Miniature hotel packaging	Small shampoo bottles, lotion bottles and soap sachets

These restrictions are especially relevant for food, beverage, hospitality, cosmetics, personal care, retail and consumer goods companies.

Businesses should identify affected formats early because alternatives may require supplier qualification, packaging trials, cost analysis, consumer communication, and changes to packaging operations.

Extended Producer Responsibility and Producer Registration

Extended Producer Responsibility, or EPR, is central to packaging compliance. Under EPR, producers are responsible for financing and supporting the management of packaging waste.

Producers must register in the Member State where they make packaging available on the market for the first time. Producers should not make packaging available on a market if they, or their appointed representatives where applicable, are not registered in that Member State.

EPR obligations companies should assess

EPR Topic	What Companies Should Prepare
Producer role	Determine who is responsible for each packaging scenario
Market mapping	Identify where each packaged product is placed on the market
Registration	Register in each required national system
Appointed representative	Appoint where required for cross-border sales
PRO participation	Join producer responsibility organizations where applicable
Packaging data	Track material type, weight, category and quantity
Annual reporting	Prepare accurate and timely submissions
Fee payment	Track EPR fees and fee modulation factors
Marketplace evidence	Provide registration numbers and self-certifications where needed

EPR readiness depends on accurate packaging data. Without reliable packaging weights, material composition, product mapping and country mapping, EPR reporting becomes difficult and error-prone.

Deposit and Return Systems

Deposit and Return Systems, or DRS, are important for beverage packaging and collection targets.

By 1 January 2029, Member States must ensure DRS setup for single-use plastic beverage bottles up to 3 liters and single-use metal beverage containers up to 3 liters, with certain exemptions and collection-rate conditions. Requirements include fair access, data collection, minimum deposit levels, transparency, deposit refunds, consumer convenience, return points, and clear labelling of deposit-bearing packaging.

DRS questions for companies

Question	Why It Matters
Is the packaging a covered beverage container?	Determines whether DRS may apply
What national DRS rules apply?	Requirements can differ by country
What deposit value applies?	Affects pricing and financial processes
What label or barcode is required?	DRS packaging often needs specific marking
What data must be reported?	Producers may need to report placed and collected packaging
Are exemptions available?	Some categories may be excluded

Beverage producers, importers and retailers should review DRS obligations early because packaging labels, barcodes, deposits and reporting systems may need operational changes.

Online Marketplace and Seller Obligations

Packaging compliance is increasingly important for online marketplaces and e-commerce sellers. Marketplaces may need to verify producer registration and collect EPR evidence before allowing sellers to place products on the market.

Online platforms should verify producer registration, obtain registration numbers, require self-certification, facilitate compliance, cooperate with authorities and prevent non-registered producers from selling where required. Sellers should register as producers where applicable, provide registration details, comply with EPR requirements, self-certify and provide accurate packaging data.

Marketplace readiness checklist

Requirement	What Sellers Should Prepare
EPR registration numbers	For each relevant Member State
Self-certification	Confirmation of packaging EPR compliance
Packaging material data	Material type, weight and category
PRO evidence	Proof of participation in compliance schemes
Labelling evidence	Sorting labels, DRS marks, QR codes where relevant
Technical documentation	Evidence supporting packaging conformity
Country mapping	Countries where products are sold and packaging is placed

For companies selling online, packaging compliance is not only a back-office requirement. It can directly affect whether a product listing remains active in a market.

PPWR Data Companies Need to Collect

PPWR compliance depends on data. Companies need more than a general packaging description. They need structured information that can support compliance assessments, EPR reporting, labelling decisions, recyclability reviews, recycled content verification and technical documentation.

Core PPWR data checklist

Data Category	Examples
Product mapping	Which packaging is used for which SKU or product family
Packaging type	Sales, grouped, transport, e-commerce, reusable, refill or service packaging
Material type	Plastic, paper, cardboard, glass, metal, wood or composite
Component weight	Weight by component and material
Country placed on market	Member State-specific EPR and reporting obligations
Supplier declarations	Substances, recycled content, material composition and food-contact data
Recyclability evidence	Design-for-recycling assessment and performance grade
Recycled content evidence	Percentage, source and verification method
Labelling evidence	Artwork, QR code content and DRS labels
EPR registration	Register numbers, PRO membership and representative details
DRS data	Deposit-bearing packaging placed on the market and collected
Technical documentation	Declarations, standards, drawings, tests and reports

Producer identification, national identification codes, packaging quantities, EPR scheme details, recycling and recovery data, deposit-return data, packaging composition, reusable packaging data and updates to registration information are important.

A company that cannot collect and maintain this data will struggle with PPWR compliance, even if its packaging design is technically strong.

Common PPWR Compliance Mistakes to Avoid

Many PPWR readiness gaps come from incomplete data, unclear responsibility or late preparation.

Common Mistake	Business Risk
Treating packaging as a sustainability-only topic	Compliance, reporting and market access risks may be missed
Not mapping all packaging types	Transport, grouped and e-commerce packaging may be ignored
Not collecting supplier evidence	Substance, recyclability and recycled content data may be missing
Using unsupported environmental claims	Labels and claims may be considered misleading
Waiting until final deadlines	Redesign, testing and artwork updates take time
Not tracking packaging weight	EPR reporting and fee calculations may be wrong
Managing data in spreadsheets only	Version control and audit readiness become difficult
Ignoring marketplace requirements	Online listings may be affected
Not updating technical files	Documentation may become outdated
Assuming EU harmonization removes national work	EPR and local systems still require country-level management

Formal non-compliance risks include missing declarations, incorrect declarations, wrong or incomplete QR codes, technical documentation problems, missing information, packaging restriction violations, reusable packaging system failures, refill information gaps and reuse/refill target failures.

Practical PPWR Readiness Roadmap

Companies should approach PPWR readiness as a structured program, not a one-time legal review.

Step 1: Build a packaging inventory

List all packaging used across products, suppliers and markets. Include sales packaging, grouped packaging, transport packaging, e-commerce packaging, reusable packaging, refill packaging and service packaging.

Step 2: Map packaging to products and countries

Connect each packaging type to SKUs, product families, suppliers and EU markets.

Step 3: Collect material and weight data

Gather material composition, component weights, total packaging weights and composite material breakdown.

Step 4: Assess substance compliance

Collect declarations and test reports for heavy metals, PFAS, Substances of Concern, inks, coatings, adhesives and high-risk materials.

Step 5: Review recyclability

Assess design-for-recycling, sorting compatibility, collection compatibility, recycled-at-scale readiness and performance grades where available.

Step 6: Verify recycled content

Identify plastic packaging categories and collect recycled content evidence where applicable.

Step 7: Review labels and claims

Check sorting labels, QR codes, reusable packaging labels, recycled content labels, deposit-return labels, manufacturer information and environmental claims.

Step 8: Prepare technical documentation

Create packaging technical files with specifications, declarations, standards, test reports, assessments and conformity evidence.

Step 9: Review EPR and DRS obligations

Identify producer obligations, registration needs, PRO participation, appointed representatives, DRS requirements and annual reporting duties.

Step 10: Monitor PPWR updates

Track delegated acts, implementing acts, guidance documents, FAQs and national measures. The PPWR implementation process is ongoing, and companies should keep their compliance assessments updated.

What Is the EU PPWR?

The PPWR is the EU’s new packaging and packaging waste regulation. It replaces the previous Packaging and Packaging Waste Directive framework and introduces directly applicable rules across the EU.

The regulation is designed to address several major packaging challenges:

Increasing packaging waste
Low levels of reuse in many packaging streams
Packaging that is difficult to recycle
Fragmented national packaging rules
Insufficient use of recycled plastic
Unnecessary packaging and excessive empty space
Inconsistent labelling and consumer sorting information
Complex EPR and packaging reporting requirements

The European Commission explains that packaging uses large quantities of primary raw materials and that increasing packaging waste, combined with low levels of reuse, collection and recycling, creates a barrier to a circular and resilient economy.

For businesses, the PPWR should not be treated as a future environmental policy only. It is a compliance framework that affects how packaging is designed, documented, labelled, reported, reused, recycled, and placed on the EU market.

Why PPWR Compliance Matters for Market Access

PPWR compliance matters because packaging is connected to product marketability. A product may be technically compliant, safe, and ready for sale, but the packaging around it may still create regulatory risk if it does not meet applicable requirements.

Packaging compliance can affect:

Business Area	PPWR Impact
Product compliance	Packaging must meet sustainability, substance, labelling, and documentation rules
Regulatory affairs	Teams must track EU and national packaging obligations
Packaging design	Packaging must be recyclable, minimized, and suitable for future requirements
Procurement	Suppliers must provide packaging composition, substance, and recycled content data
Sustainability	Reuse, refill, recyclability, recycled content, and waste prevention must be tracked
Quality management	Technical documentation and evidence must be maintained
Logistics	Transport, grouped, and e-commerce packaging must be assessed
E-commerce	Online sellers may need EPR proof and packaging registration data
Finance	EPR fees, reporting obligations, and fee modulation may affect costs
Sales	Non-compliant packaging can delay market entry or customer approvals

The European Commission states that the PPWR aims to make all packaging on the EU market recyclable in an economically viable way by 2030, safely increase recycled plastics in packaging, and reduce the use of virgin materials.

This means PPWR readiness should begin before the main compliance deadlines. Packaging redesign, supplier data collection, artwork updates, EPR registration, and technical documentation can take months or even years depending on the size and complexity of the product portfolio.

Who Is Affected by the PPWR?

The PPWR can affect any company placing packaging or packaged products on the EU market. This includes EU-based companies and non-EU companies exporting packaged goods into the EU.

Affected businesses may include:

Product manufacturers
Packaging manufacturers
Importers
Distributors
Retailers
Online marketplaces
E-commerce sellers
Brand owners
Private-label businesses
Food and beverage companies
Cosmetics and personal care companies
Healthcare and pharmaceutical companies
Electronics and electrical equipment companies
Automotive and industrial companies
Textile, fashion and footwear companies
Packaging suppliers
Companies using transport, grouped, or e-commerce packaging

The PPWR is relevant because it covers packaging across the full lifecycle, from design and material composition to use, reuse, collection, recycling, and waste management.

Companies should prepare if they answer “yes” to any of the following questions:

Question	Why It Matters
Do you place packaged products on the EU market?	Your packaging may need to meet PPWR requirements
Do you import packaged goods into the EU?	Importers may need to verify compliance evidence
Do you use plastic packaging?	Recycled content and recyclability requirements may apply
Do you use e-commerce packaging?	Empty space and packaging minimization rules may be relevant
Do you sell through online marketplaces?	EPR registration checks may affect online sales
Do you use reusable packaging or refill systems?	Specific reuse and refill conditions may apply
Do you sell beverages?	Deposit and return system obligations may apply
Do you make packaging environmental claims?	Claims must be evidence-based and not misleading

Key PPWR Deadlines Businesses Should Know

The PPWR introduces requirements in phases. Companies should not look only at one date. The regulation includes multiple timelines for application, recyclability, recycled content, labelling, reuse, deposit-return systems, and implementing acts.

Date / Period	Business Relevance
11 February 2025	PPWR entered into force
12 August 2026	General application date of many PPWR provisions
2026	EU work on guidance, implementation details, labelling and methodology continues
2028	Important preparation point for labelling, waste sorting, and some technical assessments
2029	Deposit and return systems become a key obligation for covered beverage packaging
2030	Major milestone for design-for-recycling, recycled content and certain reuse targets
2035	Recyclability at scale becomes a key requirement
2040	Higher recycled content and reuse targets apply to certain packaging categories

The Commission’s packaging waste page confirms the PPWR’s entry into force date and general application date, and it also references 2026 guidance and FAQs intended to support implementation.

Businesses should use 2026 as the start of operational readiness, not as the date to begin learning about the regulation. The companies that prepare early will be in a stronger position to redesign packaging, update supplier requirements, prepare documentation, and avoid last-minute compliance pressure.

Main PPWR Compliance Requirements

The PPWR covers several connected compliance areas. A company should not focus on only one topic, such as EPR or recyclability. A complete readiness plan should cover the full packaging compliance picture.

PPWR Area	What Companies Need to Prepare
Substance restrictions	Heavy metals, PFAS, Substances of Concern, microplastics, MOAH/MOSH where relevant
Recyclability	Design-for-recycling, collection, sorting, secondary material quality, recyclability at scale
Recycled content	Minimum recycled content targets for plastic packaging
Labelling	Material labels, sorting labels, QR codes, reusable packaging labels, DRS labels
Technical documentation	Packaging descriptions, drawings, standards, tests, assessments, declarations
Compostability	Required compostable packaging types and supporting evidence
Packaging minimization	Reduced weight, reduced volume, avoidance of unnecessary packaging
Empty space	Grouped, transport and e-commerce packaging empty space assessment
Reuse and refill	Reusable packaging conditions, refill information, reuse systems
Restricted formats	Certain single-use packaging formats and future bans
EPR	Producer registration, reporting, fees, representatives, PROs
DRS	Deposit and return systems for covered beverage packaging
Online sales	Marketplace checks, self-certification, registration numbers
Non-compliance	Missing documentation, incorrect labels, incomplete QR codes, unsupported claims

These areas form part of a comprehensive packaging compliance system, covering substance restrictions, recyclability, recycled content, labelling, technical documentation, compostability, packaging minimization, reusable packaging, refill systems, extended producer responsibility, deposit return schemes, online platform obligations, and the risks of non-compliance.

Substance Restrictions in Packaging

Substance compliance is one of the first PPWR readiness checks. Packaging materials may contain substances through inks, coatings, adhesives, barriers, pigments, plastic additives, recycled content, and treatments.

Several substance-related packaging concerns include:

Combined concentration limit for lead, cadmium, mercury and hexavalent chromium
PFAS phase-out direction
Minimization of Substances of Concern
Microplastics considerations
MOAH/MOSH restrictions

For many companies, a common mistake is assuming that product chemical compliance automatically covers packaging. It does not. Packaging must be assessed separately because the packaging bill of materials, suppliers, coatings, inks, adhesives, and recycled content may differ from the product itself.

Practical substance compliance checklist

Action	Why It Matters
Identify all packaging components	Labels, inks, adhesives, films, coatings and closures may create substance risks
Request supplier declarations	Packaging suppliers should provide substance and material information
Check heavy metals evidence	Pb, Cd, Hg and Cr(VI) should be reviewed for packaging materials
Assess PFAS risk	Food-contact, grease-resistant and coated packaging may require special attention
Review recycled materials	Recycled inputs may introduce unknown or variable substances
Maintain evidence	Authorities, customers or internal audits may request documentation

A strong PPWR readiness plan should include packaging-specific supplier questionnaires, declarations, test reports for high-risk materials, and a controlled way to link evidence to packaging components and products.

Packaging Recyclability Requirements

Recyclability is one of the most important PPWR topics. The regulation is designed to move companies away from vague recyclability claims and toward practical recyclability supported by design, collection, sorting, recycling infrastructure, and evidence.

The European Commission states that the PPWR aims to make all packaging on the EU market recyclable in an economically viable way by 2030. EUR-Lex also explains that all packaging must be recyclable, including being designed for material recycling and able to be collected, sorted and recycled at scale when it becomes waste, with recycled-at-scale requirements entering into force in 2035.

Packaging should be:

Designed for recycling
Efficiently collected
Properly sorted
Able to produce quality secondary materials
Recycled at scale

What companies should assess

Recyclability Factor	Practical Question
Design for recycling	Do materials, adhesives, labels, closures, coatings or colors prevent recycling?
Collection	Is the packaging collected in the relevant market?
Sorting	Can it be sorted into the correct waste stream?
Recycling output	Does recycling create usable secondary material?
At-scale recycling	Is recycling available at market scale, not only in pilot projects?
Documentation	Can the company prove the packaging assessment?

Recyclability performance grades may influence EPR fees. Packaging that is easier to recycle may generally result in lower fees, while packaging with weak recyclability may become more expensive or non-compliant over time.

Practical readiness steps

Companies should:

1- Create a full packaging inventory.

2- Identify materials and packaging components.

3- Review recyclability risks such as multilayer materials, problematic adhesives, full-body sleeves, dark pigments, mixed materials and small components.

4- Request recyclability evidence from suppliers.

5- Track recyclability grades where available.

6- Keep test reports and assessments in a technical file.

7- Start redesign planning for packaging that may not meet 2030 or 2035 requirements.

Recycled Content in Plastic Packaging

Plastic packaging is a major focus of the PPWR. Companies using plastic packaging need to understand whether minimum recycled content requirements apply to their packaging type.

The European Commission explains that the PPWR includes measures such as minimum recycled content requirements for plastic packaging. It sets recycled content targets for 2030 and 2040 across several categories, including contact-sensitive packaging, single-use plastic beverage bottles, and other types of plastic packaging.

Recycled content targets

Plastic Packaging Type	2030 Target	2040 Target
PET-based contact-sensitive packaging	30%	50% for contact-sensitive plastic packaging, except single-use beverage bottles
Contact-sensitive plastic packaging other than PET, excluding single-use beverage bottles	10%	50% for contact-sensitive plastic packaging, except single-use beverage bottles
Single-use plastic beverage bottles	30%	65%
Other plastic packaging	35%	65%

Companies should not treat recycled content as a marketing claim only. It is becoming a compliance requirement that must be backed by data and evidence.

What companies should collect

Data Point	Why It Matters
Plastic type	Determines category and target
Packaging application	Helps identify contact-sensitive uses
Recycled content percentage	Needed for target assessment
Post-consumer recycled content evidence	Supports compliance claims
Supplier declaration	Provides traceability
Verification method	Supports audit-readiness
Exemption justification	Needed where an exemption is used
Product and country mapping	Links evidence to market obligations

By 31 December 2026, the EU is expected to establish a methodology for calculating and verifying recycled content. From 2029, manufacturers will be required to apply this methodology.

Packaging Labelling and Digital Information

Packaging labelling is one of the PPWR areas most likely to affect artwork, packaging design, regulatory review, and product launch timelines.

Several key labelling requirements include:

Material composition labels
Reusability information
Recycled content labels
Biobased plastic labels
Compostability labels
Deposit and return system labels
Waste collection labels
Manufacturer information
QR codes and digital data carriers
Misleading label restrictions
Harmonized labelling requirements

The PPWR aims to improve consumer information and reduce confusion caused by different national labelling systems. The European Commission describes the new rules as including improved consumer information and more sustainable choices.

Labelling questions companies should ask

Question	Why It Matters
Does the packaging need a material composition label?	Supports sorting and consumer information
Is the packaging reusable?	Reusable packaging may need a label and digital information
Does the packaging need a QR code?	Digital carriers may be needed for reuse, collection or tracking
Is recycled content shown on the pack?	Claims must follow applicable methodology and evidence
Is the packaging compostable?	Compostability claims must be clear and supported
Is the packaging part of a DRS?	Deposit-bearing packaging may need specific labels
Are environmental claims used?	Claims must not mislead consumers
Is the packaging used in multiple EU countries?	Harmonized EU requirements may affect local label strategies

A practical PPWR labelling review should involve regulatory affairs, packaging design, marketing, sustainability, legal, and artwork teams. Labels should not be updated without checking whether the claim or label is supported by technical evidence.

Technical Documentation and Declaration of Conformity

PPWR compliance must be documented. A company may believe its packaging is compliant, but if it cannot prove it, it may still face enforcement issues.

Key elements of packaging technical documentation include:

General description of the packaging
Design and manufacturing details
List of relevant standards or specifications
Evidence of recyclability assessments
Declaration of Conformity

The declaration should be kept with the technical documentation for at least 10 years after the packaging is placed on the market.

What a packaging technical file should include

Technical File Element	Practical Content
Packaging description	Packaging type, intended use, materials, product relationship
Design details	Drawings, dimensions, components, closures, coatings and labels
Material composition	Plastic, paper, glass, metal, wood, composite materials, adhesives and inks
Standards and specifications	Harmonized standards, common specifications, internal methods
Substance evidence	Heavy metals, PFAS, restricted substances and supplier declarations
Recyclability evidence	Design-for-recycling assessment and recyclability performance information
Recycled content evidence	Recycled content percentage, calculation method and supplier data
Labelling evidence	Artwork, QR code information and DRS labels where relevant
Minimization evidence	Weight, volume and empty space assessment
Reuse/refill evidence	Reconditioning, rotations, cleaning and reuse system confirmations
Declaration of Conformity	Formal compliance statement

Technical documentation should be treated as a live file. It should be reviewed whenever packaging materials, suppliers, coatings, adhesives, labels, dimensions, artwork, or packaging formats change.

Compostable Packaging Requirements

Compostability is another area where companies need to be careful. Compostable packaging is not automatically preferred over recyclable packaging.

Certain packaging types must be compostable in industrial facilities, including tea bags, single-serve coffee pods or capsules, sticky labels attached to fruit and vegetables, and very lightweight plastic bags. Other packaging, including biodegradable plastic packaging, must be compatible with material recycling and must not interfere with the recycling of other waste materials.

Practical compostability checklist

Question	Why It Matters
Is compostability legally required for this packaging type?	Not all biodegradable packaging is automatically compliant
Is it industrially compostable?	Industrial compostability differs from home compostability
Is collection infrastructure available?	Compostability depends on proper collection and treatment
Could it contaminate recycling streams?	Compostable materials can disrupt conventional recycling
Is the claim clearly labelled?	Consumers need accurate disposal information
Is evidence available?	Technical documentation must support the claim

Companies should avoid broad claims such as “biodegradable” or “eco-friendly” unless they are specific, supported by evidence, and aligned with applicable rules.

Packaging Minimization and Empty Space Rules

Packaging minimization is one of the most practical PPWR requirements. It affects packaging size, weight, material use, shipping efficiency, e-commerce packaging, and product presentation.

Packaging must be designed to use the minimum amount of material, weight, and volume necessary to protect and contain the product. Unnecessary features, such as double walls, false bottoms, or additional layers used only to make a product appear larger, should be avoided.

A key requirement limits empty space in grouped packaging, transport packaging, and e-commerce packaging to a maximum of 50%. Filling materials such as paper cuttings, air cushions, bubble wrap, foam fillers, wood wool, polystyrene, and similar materials are included when calculating empty space.

Practical packaging minimization checklist

Question	Why It Matters
Is the packaging larger than necessary?	Oversized packaging may create compliance risk
Are fillers used because the outer box is too large?	Fillers may count as empty space
Can the product be protected with less material?	Supports minimization
Are extra layers used mainly for presentation?	May be difficult to justify
Is the packaging size justified by safety or fragility?	Evidence should be documented
Is e-commerce packaging assessed separately?	Shipping packaging may trigger specific risks
Is reusable packaging assessed with its function in mind?	Multiple rotations may justify certain design choices

Packaging minimization should be built into packaging specifications, supplier contracts, product development, and e-commerce fulfilment processes.

Reuse, Refill and Reusable Packaging Systems

The PPWR supports a shift toward reuse and refill models. However, reusable packaging must meet specific technical and operational conditions.

Reusable packaging should be designed and placed on the market for multiple uses, durable enough for multiple trips or rotations, capable of being emptied or unloaded without damage, safe to refill or reload, capable of being reconditioned where needed, safe for users, and recyclable at end of life.

Reuse system requirements

Reusable packaging often needs a structured system for reuse, such as:

Reuse System Type	Description
Closed-loop system	Packaging remains within one operator or controlled group
Open-loop system	Packaging can move between different owners or participants

Companies using reusable packaging should consider:

Collection process
Cleaning process
Inspection and reconditioning
Rotation tracking
Hygiene and safety
Product quality protection
End-user information
End-of-life recyclability
Technical documentation

For refill models, companies should inform end users about acceptable containers, hygiene standards, and health and safety responsibilities. Refill stations must comply with applicable requirements and may refuse containers that do not meet the communicated conditions.

Important 2026 update on pallet wrapping and straps

Reuse target information for transport packaging includes pallet wrapping and straps. However, companies should note that the European Commission adopted a delegated act in February 2026 exempting wrapping and straps used to secure goods on pallets during transport from the PPWR’s 100% reuse requirement. The Commission explained that the exemption responds to feasibility concerns and avoids disproportionate adaptation costs while keeping the broader reuse target approach.

This is a good example of why companies should monitor PPWR updates continuously. Some details may change through delegated acts, implementing acts, guidance, and national implementation measures.

How ComplyMarket Supports EU PPWR Compliance

PPWR compliance requires more than understanding the regulation. Companies need a system to manage packaging data, supplier evidence, regulatory obligations, technical documentation, EPR requirements and country-specific updates.

ComplyMarket supports companies with product compliance, sustainability reporting, material compliance, packaging compliance, Extended Producer Responsibility services, Digital Product Passport readiness and global market access. ComplyMarket’s capabilities include product compliance management software, sustainability reporting software, material compliance software, packaging compliance, EPR services, Digital Product Passport and global market access.

ComplyMarket’s packaging compliance service page also explains that packaging requirements can affect primary, secondary and tertiary packaging, as well as plastic, metal, paper, cardboard, glass, wood, labels, inks, coatings, adhesives and other packaging components. It also highlights that packaging compliance may include labelling, substance restrictions, recycling obligations, registration, reporting, documentation, recyclability and EPR obligations.

ComplyMarket can help companies prepare for PPWR by supporting

Identification of applicable packaging compliance requirements
Country-specific packaging obligation tracking
Packaging material and component data management
Supplier declaration and evidence collection
Substance compliance evidence for packaging materials
Recyclability and recycled content documentation
Technical documentation and conformity evidence management
EPR registration and reporting preparation
Packaging labelling and documentation control
Digital Product Passport and circular economy data readiness
Cross-functional visibility for compliance, sustainability, procurement and product teams

For companies selling across multiple EU markets, the challenge is not only knowing what the PPWR says. The real challenge is proving compliance, keeping packaging data updated, responding to customer or authority requests, and managing obligations across many suppliers, materials, products and jurisdictions.

ComplyMarket helps businesses move from fragmented packaging compliance work to a more structured, traceable and scalable compliance process.