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The Packaging and Packaging Waste Regulation (PPWR) introduces a new framework for packaging placed on the EU market.
Unlike the previous Packaging and Packaging Waste Directive, the PPWR is a regulation, meaning the requirements apply directly across EU Member States without national transposition.
For brands, the regulation introduces requirements related to packaging design, recyclability, labelling, documentation, and packaging-related information that may need to be maintained over time.
This article explains the main requirements introduced by the PPWR, how they relate to Extended Producer Responsibility (EPR), and what brands should start preparing today.
The Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) establishes harmonised requirements for packaging placed on the EU market.
The regulation aims to reduce packaging waste, improve recyclability, increase the use of recycled content, and create more consistent packaging requirements across Member States.
It applies across the packaging value chain and affects manufacturers, importers, distributors, and brands placing packaged products on the EU market.
The PPWR entered into force on 11 February 2025 and will generally apply from 12 August 2026.
From that date, most of the regulation's requirements become applicable across EU Member States.
The PPWR applies to packaging placed on the EU market, regardless of industry.
As a result, the regulation affects most organisations that place packaged products on the European market, including manufacturers, importers, distributors, retailers, and brand owners.
For fashion brands, this can include packaging associated with products, e-commerce shipments, retail operations, and distribution activities.
The regulation covers packaging throughout the value chain, including:
The regulation introduces requirements across four main areas.
Packaging placed on the EU market will need to comply with requirements related to:
The objective is to reduce packaging waste while improving circularity and resource efficiency.
For specific packaging categories, the regulation introduces minimum recycled content requirements.
These obligations will be phased in over time and vary depending on packaging type and material.
As a result, brands may need greater visibility into packaging composition and material sourcing.
The PPWR introduces harmonised labelling requirements intended to improve consumer understanding and waste sorting.
These requirements may include information related to:
The exact implementation details will continue to develop through delegated and implementing acts.
The regulation also introduces documentation obligations.
Depending on the packaging type, companies may need to maintain information demonstrating compliance with applicable PPWR requirements.
This can include:
Many PPWR requirements depend on information that is often distributed across suppliers, packaging manufacturers, specifications, procurement teams, and compliance documentation.
Examples include:
As a result, compliance increasingly depends not only on packaging design decisions, but also on the ability to structure, maintain, and retrieve packaging information when required.
For many organisations, this turns packaging compliance into a product and packaging data management challenge.
Many of the packaging data points required under the PPWR are also relevant for Extended Producer Responsibility (EPR) schemes.
Information such as packaging materials, composition, and weight already plays a role in EPR reporting across multiple markets.
As PPWR requirements continue to develop, many brands will need to manage packaging information that supports both regulatory frameworks.
For a detailed overview of EPR obligations, registrations, and reporting requirements, see our dedicated EPR guide.
Under the current EU framework, PPWR obligations and Digital Product Passport requirements should not be treated as interchangeable.
The PPWR governs packaging-specific requirements, including rules on packaging design, labelling, recyclability, recycled content, documentation, and conformity.
Digital Product Passports, under the ESPR framework, are designed to make product-level information digitally available according to product-group-specific requirements defined through delegated acts.
This means a DPP may support product-level transparency and compliance requirements, but it does not automatically replace packaging obligations under the PPWR.
For brands, the key point is that product compliance and packaging compliance may require separate but connected information structures. Product data and packaging data should be managed in a way that can support both frameworks without assuming that one replaces the other.
The PPWR introduces a new generation of packaging requirements that extend beyond packaging waste management alone.
For brands, compliance increasingly depends on understanding packaging composition, recyclability, documentation, labelling, and the information needed to demonstrate conformity over time.
Renoon continuously monitors packaging, Digital Product Passport, and product compliance developments across the European Union.
Get in touch to discuss how upcoming packaging requirements may affect your products, packaging systems, and compliance processes.
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