New packaging obligations affect businesses placing packaging or packaged products on the market. The Packaging and Packaging Waste Regulation (PPWR) introduces changes to packaging design, labelling and recycling requirements, as well as extended producer responsibility (EPR) rules. We explain who is affected and the key dates businesses should keep in mind.<\/p>\n\n\n\n
Not all requirements apply from the same date. Some provisions already apply, while others will be introduced in stages. Businesses must also continue to meet their obligations under national extended producer responsibility schemes.<\/p>\n\n\n\n
EPR<\/strong>, or extended producer responsibility, means financial responsibility, or both financial and organisational responsibility, for managing waste generated from products. For packaging, this includes contributing to the costs of collecting and treating packaging waste.<\/p>\n\n\n\n PPWR<\/strong> is Regulation (EU) 2025\/40 of the European Parliament and of the Council on packaging and packaging waste. It covers a broader range of issues: packaging composition and design, labelling, recyclability, reuse and producer responsibility.<\/p>\n\n\n\n EPR is therefore not a new obligation introduced solely by the PPWR. The Regulation changes and harmonises the framework governing EPR for packaging.<\/p>\n\n\n\n The requirements may apply to manufacturers, importers, distributors and online retailers. A business\u2019s actual role in the supply chain determines which obligations apply.<\/p>\n\n\n\n The party responsible for EPR is not always the company that physically manufactured the packaging. Identifying the responsible party requires checking who first makes the packaging or packaged product available in a particular Member State, and how.<\/p>\n\n\n\n For cross-border sales, businesses must also consider the recipient, the type of packaging and whether the goods are supplied for resale or directly to an end user. Shipping a product abroad is not, on its own, enough to determine all applicable obligations.<\/p>\n\n\n\n New packaging obligations cover two related areas: compliance of the packaging itself and fulfilment of EPR obligations.<\/p>\n\n\n\n The first is packaging compliance.<\/strong>Depending on the packaging type and the applicable date, relevant requirements may include restrictions on substances, conformity documentation, labelling, recyclability and recycled content.<\/p>\n\n\n\n The second is fulfilment of EPR obligations.<\/strong>This may require registration, reporting packaging data, paying EPR fees and working with a producer responsibility organisation or an authorised representative.<\/p>\n\n\n\n Meeting requirements concerning packaging materials does not replace registration and reporting obligations.<\/p>\n\n\n\n 12 August 2026 is not a single deadline for all new obligations.<\/strong>Businesses need to establish the timetable for each relevant requirement and packaging type.<\/p>\n\n\n\n The PPWR provides for harmonised registration and reporting rules. However, businesses should not assume that a single registration will automatically cover sales in every EU Member State.<\/p>\n\n\n\n The European Commission states that businesses must continue to comply with existing national EPR registration rules. Registers will be adapted to the new arrangements according to the timetable established by the implementing provisions.<\/p>\n\n\n\n Reporting deadlines, data submission procedures and payment arrangements must therefore be checked for each market. Registration in Poland\u2019s BDO register does not replace this assessment.<\/p>\n\n\n\n Low sales volumes do not automatically mean a complete exemption from EPR. Certain simplifications are available to smaller businesses, but the applicable conditions must be checked.<\/p>\n\n\n\n The threshold of 10 tonnes of packaging per year should not be treated as a general exemption from all obligations. Simplified reporting or preferential arrangements do not necessarily remove registration requirements or fees.<\/p>\n\n\n\n To prepare for new packaging obligations, businesses should combine a documentation review with an assessment of their sales markets and packaging.<\/p>\n\n\n\n A useful starting point is to:<\/p>\n\n\n\n The changes may require cooperation between purchasing, sales, logistics and environmental compliance teams. An early review helps businesses plan their actions before the next reporting deadline or before ordering a new batch of packaging.<\/p>\n\n\n\n If your business sells products internationally, explore MASAD\u2019s support with EPR packaging obligations in international markets.<\/a>.<\/p>\n\n\n\nWho may be subject to packaging obligations?<\/h2>\n\n\n\n
Which new packaging obligations should businesses check?<\/code><\/h2>\n\n\n\nKey PPWR dates<\/h2>\n\n\n\n
Date<\/th> What it means for businesses<\/th><\/tr> 11 February 2025<\/strong><\/td> The PPWR entered into force.<\/td><\/tr> 12 August 2026<\/strong><\/td> The general application date of the Regulation. Individual requirements nevertheless have separate deadlines.<\/td><\/tr> No earlier than 12 August 2028<\/strong><\/td> The envisaged start date for harmonised labelling identifying packaging material composition. The date also depends on the entry into force of the relevant implementing acts.<\/td><\/tr> From 2030<\/strong><\/td> Further requirements concerning recyclability, recycled content in plastic packaging, the reduction of unnecessary packaging and reuse, subject to exemptions and specific application dates.<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n Will there be one common EPR report for the entire EU?<\/h2>\n\n\n\n
Are small businesses exempt?<\/h2>\n\n\n\n
How can businesses prepare for the changes?<\/h2>\n\n\n\n
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