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The European Packaging and Packaging Waste Regulation (PPWR) represents the most significant reform of packaging legislation in years. Through the PPWR, the European Union aims to drastically reduce packaging waste and accelerate the transition to a circular economy.
Although most obligations will not fully apply until 2030, companies in the food & beverage sector should not view this as a distant concern. Adapting packaging, sourcing compliant suppliers, and implementing new processes all require time. Moreover, several important compliance and administrative obligations will already enter into force on 12 August 2026.
In previous newsletters (I & II), we provided a general overview of the new European Packaging and Packaging Waste Regulation and the obligations it introduces. In this article, we focus on the practical implications of the PPWR for the food & beverage sector.
1. Who Must Comply with the PPWR?
The Regulation distinguishes between three legal categories: producer, importer, and distributor. The obligations applicable to a business depend on the role it performs with respect to a particular product.
A producer is, in many cases, the company whose name or trademark appears on the packaging, or which has had the packaging designed or manufactured under its own name.
An importer places packaging or packaged products from outside the European Union on the EU market for the first time.
A distributor makes packaged products available on the market without itself being the producer or importer.
For businesses in the food & beverage sector, it is important to note that a single company may simultaneously fulfil several of these roles, as the relevant role must be assessed on a product-by-product basis.
Determining which role or roles your business performs across its product portfolio is therefore the first step in any PPWR compliance exercise.
2. Key PPWR Obligations at a Glance
2.1 From 12 August 2026: Focus on Compliance and Food-Safe Packaging
For producers and importers, the first challenge will primarily concern compliance requirements. In most cases, they will need to complete Extended Producer Responsibility (EPR) registrations in the Member States where they sell products, maintain the required technical documentation and Declarations of Conformity, and be able to provide information to market surveillance authorities. From that date, the new restrictions on PFAS in food contact packaging will also apply.
For distributors and retailers, the focus shifts to verification and traceability. They must verify that producers and importers have fulfilled their obligations and be able to demonstrate the origin of products and packaging.
An important nuance is that the PPWR does not impose a general obligation to destroy or repackage existing stock. Packaging that was already placed on the market before 12 August 2026 may continue to be sold. Packaging manufactured before that date but not yet placed on the market generally does not need to be destroyed or relabelled either. Certain identification and traceability requirements may be met through accompanying documentation.
2.2 From February 2027: Preparing for the New Packaging Rules
Although the most far-reaching obligations will only apply from 2030, this is the moment for most businesses to review their packaging and supply chain arrangements. Packaging is expected to gradually become subject to new harmonised European labelling requirements from 2028 onwards, including harmonised waste-sorting labels. The exact timeline remains dependent on implementing acts that the European Commission still has to adopt.
From 12 February 2027, final distributors in the hospitality sector will also be affected. Restaurants, cafés, and providers of takeaway food and beverages will face additional obligations relating to refill and reuse systems. Greater emphasis will be placed on the use of customers’ own containers and on offering reusable packaging alternatives.
2.3 From 2030: Focus on the Packaging Itself
By 2030, recyclability according to harmonised European criteria, also known as design for recycling, will become the fundamental requirement for packaging. Packaging that performs poorly under the European recyclability criteria will gradually disappear from the market. Businesses will also be required to minimise packaging weight and volume to what is functionally necessary. In addition, transport packaging, grouped packaging, and e-commerce packaging may not contain more than 50% empty space.
New requirements will also apply to plastic packaging. Depending on the type of packaging, a minimum percentage of recycled plastic content will be mandatory. For food and beverage manufacturers, this means considering not only whether packaging is recyclable, but also whether sufficient recycled material that complies with food safety requirements will be available.
Certain packaging formats will gradually be phased out. For the food sector, this is particularly relevant for specific packaging used for fresh fruit and vegetables, as well as various single-use plastic packaging formats in the hospitality sector, such as individual portion packs for sauces, sugar, milk, or condiments.
3. How We Can Assist You
Although 2030 may seem a long way off, the effects of the PPWR are already being felt today. Packaging is often developed years in advance, and supplier agreements typically run for extended periods. In addition, retailers and customers are increasingly requesting information regarding recyclability, recycled content, and future compliance.
For businesses operating in the food & beverage sector, now is the right time to critically assess their packaging portfolio, review existing contractual arrangements relating to liability and compliance obligations, and identify which adjustments concerning recycling, reuse, and labelling will become necessary in the years ahead.
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.
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