The EU Packaging Regulation (PPWR): What You Actually Need to Do

In January 2025, the EU published Regulation (EU) 2025/40 - the Packaging and Packaging Waste Regulation. It's a regulation, not a directive: it applies directly across all Member States. No local transposition. [OJ L 2025/40, 22.1.2025]

It has applied since 12 August 2026. If you place packaged products on the EU market - whether you're a brand, an e-commerce seller, or a shipping operation - it applies to you.

Disclaimer: this guide is not legal advice. It's a practical walkthrough to help you understand what's required and get moving. For formal legal interpretation, consult a qualified advisor.

It comes down to two areas. The first is how you work with packaging - the systems and processes around it:

• Register - join the official registry and appoint an Authorised Representative in countries where you don't have your own entity.
• Report and pay - submit packaging data, pay EPR fees, keep documentation.

The second is about the packaging itself - what you're allowed to use and how it's designed:

• Check your packaging - meet rules on recyclability, labelling, substances, and waste reduction.

If you're a brand or e-commerce business selling packaged products into the EU - even from just one country - this is on you. You're the "producer" under the PPWR in every market you ship to. Not your packaging supplier. Not your 3PL. You.

That means you register, you report, and you pay the EPR fees. The good news: only one entity pays per packaging unit per market, which means there's no double-reporting across the supply chain.

Here's how the obligations spread:

• D2C and e-commerce brands - you're the producer in every market you sell into. If you're based in, say, Sweden and ship to 15 EU countries, you need to register and report in all 15.^[1] (Article 44)
• Brands and manufacturers - primary responsibility. Ensure your packaging meets all requirements and produce the technical documentation.^[1] (Article 15)
• Importers - if you bring packaged goods into the EU, you're responsible for verifying conformity before placing them on the market.^[1] (Article 18)
• Distributors - must verify that packaging carries the correct labels and that the producer is registered.^[1] (Article 19)
• Fulfilment service providers (3PLs) - have their own compliance obligations, including verifying producer registration.^[1] (Article 20)
• Online marketplaces - platforms like Amazon and Zalando must verify sellers have valid packaging registrations before allowing them to list products. (DSA Reg. 2022/2065 Article 30)

Don't have your own entity in a country? You need to appoint an Authorised Representative there (required since August 2026).^[1] (Article 45)

Register with the government registry in each country where you sell. Most have a 0-kg threshold - one unit triggers it. Don't have your own subsidiary or entity in a country? Then you need to appoint an Authorised Representative there (required since August 2026).^[1] (Articles 44 and 45)

Here's the clever bit: the EU isn't just relying on regulators to enforce this. Under the Digital Services Act, online marketplaces like Amazon and Zalando must verify that every seller has a valid packaging registration before they can list products. The PPWR register counts as a public register under that framework, which turns platforms into gatekeepers at scale.^[1] (Article 44, DSA Reg. 2022/2065 Article 30)

Penalties: immediate sales bans (Germany), fines up to €600,000 (Spain), up to €15 million + prison (Ireland).

Report packaging data to the registry, pay EPR fees to a PRO. Every country wants weight by material, B2C/B2B split, and SUP declarations. Beyond that, the details vary by market.

EPR fees are modulated by eco-modulation - harder-to-recycle packaging costs more. Missing or late payments trigger backdated fees (up to 3×), marketplace suspension, or product seizure.

You also need technical documentation available on request: conformity assessments, material records, substance testing.^[1] (Article 15)

The PPWR sets rules on design, labelling, and composition. Here's what you need to know:

• Recyclability - All packaging graded A/B/C. From 2030, Grade C (70%) is the floor. Below that, you can't sell in the EU.^[1] (Article 6, Annex II Table 3)
• Recycled content - Mandatory minimums for plastic: 10-35% by 2030, rising to 25-65% by 2040 (varies by type). Calculated as an average per manufacturing plant per year.^[1] (Article 7)
• Substance restrictions - PFAS limits on food-contact packaging since Aug 2026: 25 ppb targeted, 250 ppb sum, 50 ppm total fluorine. No grandfathering.^[1] (Article 5(5))
• Waste reduction & empty space - Packaging must be the minimum necessary. False bottoms, double walls, and decorative bulk are banned from 2030.^[1] (Article 10) Grouped, transport, and e-commerce packaging must not exceed 50% empty space from 2030.^[1] (Article 24)
• Labelling - Harmonised material and sorting labels mandatory from 12 August 2028 at the earliest (or 24 months after the Commission's implementing acts enter into force, whichever is later). QR codes are only required for reusable packaging, from 12 February 2029.^[1] (Article 12)
• Format bans - From 2030, certain single-use plastic formats are banned - including shrink wrap on multipacks, small fresh fruit and veg packaging, and hotel miniatures.^[1] (Article 25, Annex V)
• Green claims - Stricter rules on what you can call "recyclable", "made from recycled content", or similar. If your packaging doesn't meet the EU's new thresholds for that claim, you can't use it.^[1] (Article 14)
• Reuse targets for transport packaging - From 2030, at least 40% of transport packaging - including pallets, boxes (except cardboard), crates, pallet wrap, and straps - must be reusable within a re-use system. This includes e-commerce shipments. The target rises to 70% by 2040.^[1] (Article 29)

Note: Several 2030 requirements depend on the EU adopting implementing or delegated acts first - the actual deadline is "2030 or 24 months after those acts enter into force, whichever is latest."

Key national changes: Germany's VerpackDG replaced VerpackG on 12 Aug 2026. Sweden shifted liability from filler to brand owner the same date.

Here's the practical to-do list:

• Collect packaging data from your suppliers - material composition, weights, recycled content percentages, PFAS levels, and recyclability grades.^[1] (Article 7, Article 15)
• Build a central packaging data system - one place to manage specs across all your SKUs and markets, always up to date and audit-ready.
• Produce your Declarations of Conformity - one per packaging type you place on the market (not per unit or per SKU). Retain for 5 years (single-use) or 10 years (reusable).^[1] (Article 15, Article 39)
• Register in each market - get your registry numbers and appoint Authorised Representatives where you don't have a local entity.^[1] (Articles 44 and 45)
• Set up PRO contracts - join a Producer Responsibility Organisation in every country you sell into.
• Generate and submit your reports - tonnage, materials, and fees per country, per deadline.