Introduction

The EU's new Packaging and Packaging Waste Regulation (PPWR) marks a shift in how organisations manage packaging, introducing requirements around recyclability, labelling, reuse and producer responsibility. Its implications extend into sustainability performance, supply chain resilience, customer expectations and regulatory reporting. 

Many organisations assume PPWR only affects packaging manufacturers. In reality, it applies much more widely across the value chain. Businesses that import goods, sell products online, place packaged goods on the EU market or distribute products using branded packaging may all have obligations under the regulation. 

This is particularly relevant for manufacturing and life sciences organisations, where packaging plays an important role in product protection, regulatory compliance and product integrity.

Organisations will require greater visibility over packaging materials, supplier information and packaging-related data than many currently possess. Implementation is also unlikely to sit with a single function. Procurement, product development, quality, regulatory affairs, operations, sustainability and legal teams will all have a role to play. 

The first PPWR obligations apply from 12 August 2026, leaving organisations with little time to waste.

Preparing beyond compliance

PPWR introduces new expectations around how packaging is designed, documented and managed throughout its lifecycle.

Three things are worth assessing immediately, regardless of company size or sector:

  • whether existing packaging is suitable for future recyclability and reuse requirements, and whether suppliers can provide the technical information needed to show compliance
  • whether packaging data is robust enough to support labelling, reporting and regulatory requirements
  • who owns packaging governance internally, and how that ownership will be coordinated across functions

Although implementation is phased, decisions made today on packaging design, supplier engagement and data collection will shape compliance down the line.

 

Key milestones

11 February 2025

11 February 2025

PPWR entered into force

12 August 2026

12 August 2026

PPWR becomes applicable across the EU. Organisations placing packaging on the market are expected to comply with the first set of requirements from this date

12 August 2028

12 August 2028

Harmonised EU packaging labelling requirements apply.

2030

2030

Additional recyclability and recycled content requirements apply.

The cost of waiting, and the case for acting now 

PPWR is a directly applicable EU regulation, and organisations placing packaging on the EU market will be expected to comply from the relevant implementation dates.

Failure to prepare could result in increased compliance costs, challenges demonstrating conformity, supply chain disruption and, in some cases, restrictions on placing non-compliant packaging on the EU market.

However, the regulation should not be viewed solely as a compliance exercise. It also presents an opportunity to strengthen packaging governance, improve supplier engagement, enhance packaging data management and support wider circular economy efforts.

As the first obligations become effective from 12 August this year, organisations should now be focused on readiness: mapping which obligations under PPWR actually apply to them, confirming whether suppliers can provide the technical documentation needed to prove compliance, and deciding who inside the organisation owns this.  

Those that act now will be better positioned to manage regulatory change and minimise disruption.