In December 2024, the European Union adopted the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR), which replaces the former Packaging Directive (94/62/EC). The PPWR is a directly applicable EU regulation that establishes a harmonized legal framework for all packaging placed on the EU market. It aims to reduce packaging waste and promote reuse, recyclability, and supply chain transparency. In particular, the PPWR introduces obligations affecting e-commerce businesses, direct-to-consumer (D2C) brands, online marketplaces, and companies involved in manufacturing, importing, or distributing packaged goods in the European Union.
The regulation took effect 11 February 2025 and will apply after an 18-month transition period, beginning 12 August 2026. While the regulation as a whole becomes applicable from that date, several specific obligations will apply in a staggered manner, with key measures on reuse, recycled content, and digital labelling coming into force between 2027 and 2030, and some extending beyond 2030.
Scope: Who Will the PPWR Affect?
The PPWR applies to all economic operators placing any packaging—regardless of the material used—on the EU market, including manufacturers, importers, distributors, and online retailers. While many responsibilities already existed under the previous Packaging Directive, the PPWR expands and clarifies these obligations, particularly for cross-border and digital business models.
What Changes Does the PPWR Introduce?
The PPWR introduces a set of new or significantly expanded legal obligations that will take effect in stages from 2026 onward:
- Online Marketplaces: Online marketplaces are explicitly addressed as responsible actors when they handle packaging or logistics on behalf of third-party sellers, clarifying and harmonizing previous inconsistencies between Member States.
- Packaging Design & Volume Efficiency: From 12 August 2026, packaging—including e-commerce parcels—must comply with strict rules on material and space efficiency. Empty space in parcels must not exceed 40%, unless technically unavoidable.
- Digital Labelling: From 2027, packaging must carry digital identifiers (e.g., QR codes) linking to structured environmental information, including material composition, recyclability, and reuse details.
Central EU Packaging Registry:
By 2029, national packaging databases, such as Germany's LUCID, will be replaced by a single EU-level registry for producers and distributors, designed to streamline transparency and enforcement.
- Mandatory Recycled Content: From 2030, minimum recycled content thresholds will apply to various plastic packaging types, ranging between 30% and 65%, depending on the category.
- Reusable Packaging Option for E-Commerce: From 2030, online sellers must offer a reusable shipping option at checkout. This alternative must be presented clearly and not be made less attractive than single-use options.
- Non-EU Companies: Non-EU companies shipping directly to EU consumers must appoint an authorized representative within the European Union—a new obligation that increases accountability for third-country sellers.
Exceptions: Limited Relief for Certain Sectors
Under the PPWR, all companies placing packaging on the EU market, regardless of size, must comply with the regulation's core obligations, including reporting, design requirements, and registration. The PPWR does not provide a general exemption for micro or small enterprises.
However, limited exceptions apply:
- Medical and Hazardous Product Packaging: May be excluded from reuse or recyclability targets if safety or sector-specific legislation requires it.
- Business-to-Business (B2B) Packaging: May be subject to adjusted obligations, particularly regarding reuse and digital labelling, but it remains within the regulation's overall scope.
- Packaging for Export: Packaging used exclusively for products exported outside the European Union, and therefore not placed on the EU market, may be exempt from labelling and registration requirements, provided this exemption can be properly demonstrated and verified.
Possible Non-Compliance Risks
Failure to comply with the PPWR may lead to legal and commercial consequences. While the regulation itself does not prescribe EU-wide penalties, it requires all Member States to introduce effective, proportionate, and dissuasive enforcement measures.
Outcomes of non-compliance may include:
- Fines and administrative penalties under national packaging or waste legislation
- Market access restrictions or product delistings imposed by competent authorities or online platforms
- Legal liability in fulfilment or platform partnerships
- Negative ESG ratings and reputational damage due to non-compliance with environmental standards
As enforcement will remain in the hands of national authorities, companies operating across multiple EU markets should consider preparing for differences in interpretation and application between Member States. Businesses should also consider assessing their compliance with the PPWR in conjunction with related EU frameworks, including the upcoming Digital Product Passport and the Green Claims Directive.
Key Considerations for Companies
With the PPWR set to apply from 12 August 2026, companies placing packaging on the EU market have a limited window to adapt. Even though some provisions won't be implemented until 2027 or 2030, many core obligations, including packaging design rules, registration, and reporting, may require early planning.
To help ensure timely compliance and avoid disruptions, businesses should consider preparing now by:
- Reviewing packaging formats, materials, and suppliers in light of new design, minimisation, and recyclability requirements
- Assessing the technical and logistical feasibility of reusable shipping options for e-commerce
- Collecting documentation from packaging suppliers to prove recycled content ahead of future targets
- Preparing IT systems and product data workflows for digital labelling requirements starting in 2027
- Monitoring how individual Member States implement and enforce the PPWR, especially in cross-border or platform-based operations
Acting early may help support legal compliance and prepare operations in an increasingly sustainability-driven market.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
