By Rachel Young    Photo：CANVA

I. What Are EPR and PPWR?

EPR (Extended Producer Responsibility) is an important part of the EU's waste-management framework. It requires companies that qualify as producers to take responsibility for waste generated after products or packaging enter the market, including the collection, sorting, recycling and treatment of packaging waste. In practical terms, companies need to think not only about how a product is sold, but also about how its packaging will enter the recovery and recycling system after use.

PPWR (Packaging and Packaging Waste Regulation) is the EU's new-generation packaging regulation. The formal legislation is Regulation (EU) 2025/40, which replaces the former Packaging and Packaging Waste Directive (PPWD).

The PPWR entered into force on 11 February 2025 and has applied since 12 August 2026. Certain labelling, recycled-content, packaging-minimisation and packaging-format restrictions will be introduced in stages in 2028, 2029 and 2030, depending on the relevant provisions.

The PPWR does more than regulate packaging waste. It creates a broader framework covering packaging design, material selection, recyclability, recycled content, packaging minimisation, labelling and reuse.

A useful way to understand the relationship is this: EPR focuses on who is responsible for packaging waste after products enter the market, while the PPWR also requires the packaging itself to meet specific rules from the design stage onward. For businesses, EPR registration alone is no longer enough. The packaging itself must also comply with the applicable PPWR requirements.

II. Scope of Application: Who Needs to Comply?

Depending on the transaction model, manufacturers, importers, distributors and cross-border sellers may qualify as a producer under the PPWR.

Here, producer does not simply mean the factory that physically manufactures the product. The key questions are who first makes the packaging or packaged product available on the relevant Member State market, and how the product is ultimately sold.

For example, an Asian exporter that sells directly to end users in an EU Member State through cross-border e-commerce or distance selling may need to complete EPR registration and fulfil other producer-responsibility obligations in that Member State.

If the goods are first sold to an EU importer and then placed on the market by that importer or a distributor, the allocation of responsibility will be different. Exporting goods to the EU therefore does not automatically make the overseas exporter the EPR producer in every market.

The PPWR covers packaging made from all materials, including:

• Sales packaging, which directly contains the product and is sold together with it;
• Grouped packaging, used to combine several sales units;
• Transport packaging, used to transport, handle and protect goods; and
• E-commerce packaging used for online-order delivery.

Certain specialised packaging is subject to additional requirements. For example, specified permeable tea and coffee bags, as well as adhesive labels attached to fruit and vegetables, must comply with the relevant industrial-composting requirements no later than 12 February 2028.

The HORECA sector is also specifically addressed by the PPWR. From 2030, certain single-use plastic food and beverage packaging used in food-service premises, specified single-portion formats, and some single-use cosmetic, hygiene and toiletry packaging supplied by accommodation businesses will be restricted. This does not amount to a blanket ban on all single-use packaging, as different uses remain subject to their own scope and exemptions.

III. Core Impacts of EPR and PPWR on Businesses

(1) Restructuring of Packaging-Related Costs

Packaging costs will increasingly involve more than the cost of cartons, plastics and cushioning materials themselves.

Packaging design, material data, technical documentation, testing and compliance management, together with country-specific EPR registration, reporting and recovery fees, can all become part of the total cost structure.

For packaging minimisation, the PPWR provides that from 1 January 2030, or three years after the relevant implementing act enters into force, whichever is later, grouped packaging, transport packaging and e-commerce packaging must not exceed a 50% empty-space ratio.

This is particularly relevant to e-commerce packaging. Companies will not be able to rely indefinitely on boxes that are clearly oversized for the product and then fill the remaining space with large amounts of cushioning material.

Plastic packaging will also face minimum recycled-content requirements. Depending on the packaging category, the minimums from 2030 include 10%, 30% and 35%, rather than one uniform percentage for all plastic packaging.

EPR fees will also increasingly reflect packaging recyclability. Actual fee schedules, reporting methods and PRO charges remain country-specific, which means the EPR cost for the same product can differ from one EU market to another.

(2) Greater Supply-Chain Management Pressure

Another major effect of the PPWR is that packaging compliance is moving further upstream in the supply chain.

In the past, companies might have waited until products were finished and ready for export before checking packaging marks or recovery requirements. Going forward, they will need to obtain material composition, recycled-content, recyclability and other necessary packaging information from suppliers much earlier.

Some requirements are already in force. Since 12 August 2026, certain PPWR provisions have applied. For example, PFAS in food-contact packaging is subject to concentration limits. For food, beverage and other companies using food-contact packaging, this is already a current compliance issue.

From 2030, the PPWR will also restrict certain single-use plastic packaging formats, including specified fresh fruit and vegetable packaging, some grouped packaging and certain HORECA packaging.

Companies that currently rely heavily on these formats can begin discussing alternatives with suppliers now instead of waiting until the compliance deadline is close.

(3) Higher Market-Access Requirements

EPR and the PPWR address different layers of compliance.

EPR focuses on whether a company acting as a producer has completed the relevant Member State registration, reporting and producer-responsibility obligations. The PPWR also requires the packaging itself to meet applicable design, material, labelling and other market requirements.

If a company fails to complete an applicable EPR registration or its packaging does not comply with the PPWR, it may face corrective action, restrictions on placing products on the market, product withdrawal or recall, and penalties under the relevant Member State rules.

For cross-border e-commerce sellers, marketplace requirements also matter. Online platforms are taking on a greater role in EPR compliance, and a seller's EPR registration information and supporting evidence may directly affect whether products can continue to be sold through the platform.

IV. How Can Packaging Compliance with EPR and PPWR Be Demonstrated?

(1) Compliance Documentation

Since 12 August 2026, packaging within the scope of the PPWR has been subject to the applicable conformity-assessment requirements. Manufacturers must prepare Technical Documentation and issue an EU Declaration of Conformity.

The purpose of the technical documentation is to demonstrate that the packaging meets the relevant requirements. Depending on the product, it should therefore contain the necessary information on packaging design, materials, technical specifications, test results and other supporting evidence.

Document-retention periods differ by packaging type:

• Single-use packaging: 5 years;
• Reusable packaging: 10 years.

Manufacturers must also provide basic traceability information, such as a type, batch number, serial number or another identifier, together with the manufacturer's name, address and relevant contact details.

For goods imported from outside the EU, the EU importer also needs to confirm that the non-EU manufacturer has completed the applicable conformity assessment and can provide the necessary technical documentation and declaration of conformity.

(2) Packaging Labelling Requirements

The PPWR will gradually introduce a harmonised EU packaging-labelling system.

From 12 August 2028, or 24 months after the relevant implementing acts enter into force, whichever is later, packaging within scope will need to carry harmonised material-composition labels so consumers can more easily sort and recycle it correctly.

Transport packaging is generally exempt from this material-composition labelling requirement, but e-commerce packaging is not covered by that transport-packaging exemption.

Reusable packaging will need to be labelled as reusable from 12 February 2029, or 30 months after the relevant implementing act enters into force, whichever is later.

Information relating to the reuse system, collection points and reuse cycles will be provided through a QR code or another standardised digital data carrier.

(3) Evidence of EPR Fulfilment

EPR registration records and PPWR packaging-conformity documents are best managed separately.

If a company qualifies as a producer in a Member State, it needs to complete the required EPR registration under that country's system and fulfil the relevant obligations directly or through a Producer Responsibility Organisation (PRO).

The records that companies may need to retain typically include:

• EPR registration numbers;
• PRO contracts or membership certificates;
• Packaging-volume declarations;
• EPR and recovery-fee payment records; and
• Other records required by the competent authority or PRO.

The EU currently does not have a single EPR registration that is valid across all Member States.

Companies should manage EPR registration and reporting according to the markets where their products are actually sold and the Member States in which they qualify as producers.

V. Registration in Major Markets and Special Requirements

(1) Registration in Major Markets

1. Germany

Germany's central packaging EPR registration system is the LUCID Packaging Register, operated by the Zentrale Stelle Verpackungsregister (ZSVR).

Companies first need to determine whether they qualify as producers and whether their packaging is subject to system participation. They can then complete the applicable LUCID registration, system-participation and packaging-volume reporting requirements.

Companies established outside Germany that sell packaging or packaged products directly to German end users also need to pay particular attention to authorised representative requirements.

2. France

Packaging EPR in France operates within the REP framework administered by ADEME.

For household packaging and graphic paper under the current system, approved eco-organismes include CITEO, ADELPHE and LEKO.

Companies should identify the applicable REP stream based on product type, packaging use and how the goods are placed on the French market, and then complete the corresponding registration, reporting and eco-contribution requirements.

3. Italy

Italy's main packaging EPR framework operates through CONAI.

Companies need to determine their responsibilities under the CONAI system and also consider how the new PPWR conformity-documentation and supply-chain role requirements applying from 12 August 2026 interact with existing Italian packaging rules.

For food packaging, the relevant EU food-contact-material rules also need to be addressed separately. Completing EPR requirements does not automatically satisfy all other food-packaging compliance obligations.

4. Spain

Spain's official packaging producer registration is administered by the Ministry for the Ecological Transition and the Demographic Challenge, MITECO, through the Registro de Productores de Producto, sección envases.

Depending on the packaging category, companies may also fulfil producer-responsibility obligations through the relevant SRAP or SCRAP. Ecoembes is one of the commonly used organisations, but it is not the official producer register itself.

Now that the PPWR applies, companies should also reassess whether the updated producer definition affects their existing registration and reporting position.

5. Other EU Member States

The PPWR is directly applicable across all 27 EU Member States, but EPR registration and implementation continue to operate through Member State systems.

A company does not need to register in all 27 countries simply because its goods are sold into the EU. Companies should complete EPR registration and reporting in the Member States where their products are sold and where they qualify as producers.

A single multi-country compliance provider can coordinate work across several markets, which may simplify administration, but the legal registrations remain country-specific.

(2) Special Territory Considerations

Norway, Iceland and Liechtenstein are closely integrated with the EU internal market through the EEA. However, as of September 2026, Regulation (EU) 2025/40 is still in the process of incorporation into the EEA Agreement.

Businesses exporting to these three markets should therefore not assume that the EU PPWR applies there in exactly the same way. The packaging and EPR rules currently in force in each market still need to be checked.

The United Kingdom operates its own packaging EPR system following Brexit and is outside the EU PPWR framework.

Businesses entering the UK market need to assess registration and reporting obligations under the UK EPR for Packaging regime. Relevant regulators include the Environment Agency in England, Natural Resources Wales, the Scottish Environment Protection Agency (SEPA), and the Northern Ireland Environment Agency (NIEA).

VI. Compliance Recommendations for Sellers

(1) Confirm Your Supply-Chain Role First

The first step is not to rush into finding a PRO. Businesses should first determine whether they act as a manufacturer, importer, distributor or producer.

For Asian exporters, cross-border e-commerce sellers and overseas brands without an EU entity, EPR responsibility cannot be determined simply by asking who manufactures the product.

Who first places the goods on the market, who imports them and who ultimately buys them can all affect how responsibility is allocated.

(2) Prioritise the Requirements Already Applying in 2026

The PPWR has applied since 12 August 2026, so companies should not focus only on the 2030 deadlines.

Current priorities include technical documentation, the EU Declaration of Conformity, packaging identification and manufacturer information, as well as the PFAS requirements for food-contact packaging.

If packaging-material suppliers cannot provide complete material composition, test results or other required documentation, PPWR compliance can still be held up by missing information even when there is no problem with the product itself.

(3) Plan Packaging Changes for 2028 to 2030 in Advance

The harmonised material labels beginning in 2028, reusable-packaging labelling in 2029, and the empty-space, recycled-content, packaging-minimisation and specific single-use plastic packaging restrictions applying from 2030 may all affect existing packaging designs.

Companies can begin by mapping current packaging types, materials, weights and suppliers, then identify which formats are likely to need changes.

(4) Manage EPR According to Actual Sales Markets

SMEs can use authorised representatives, PROs or professional compliance service providers to support multi-country EPR management.

A single service provider can manage EPR compliance across multiple countries, but each country still has its own EPR registration system and registration number.

Companies should maintain a market list showing where products are actually sold, where they qualify as producers, which EPR system applies, and the relevant annual reporting and payment deadlines.

It is also advisable to maintain a structured packaging database covering materials, weights, supplier information, technical documentation, EPR registration numbers, PRO records and historical declarations.

Note: the practical application dates of certain PPWR obligations may still depend on subsequent delegated acts, implementing acts and Member State EPR implementation rules. Businesses should continue to check requirements based on their actual markets and supply-chain roles.

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