As of 12 August 2026, most of the requirements under the EU Packaging and Packaging Waste Regulation (PPWR) will become legally binding. This regulation introduces stricter obligations for packaging recyclability, reuse targets and waste reduction across the European market.
Companies will need to demonstrate that their packaging solutions are compliant and circular — from material selection and design to end-of-life management. Although 2026 may seem distant, the compliance deadline is closer than it appears. The development, redesign and testing of sustainable packaging solutions can take months, particularly for complex materials or packaging with specific barrier properties.
Organizations that delay action risk higher compliance costs, supply chain disruptions and rushed, less optimal packaging solutions.
What does the PPWR require?
The PPWR replaces the former PPWD directive and significantly strengthens packaging sustainability requirements across the European Union. Under the new regulation, circular packaging is no longer voluntary but a legal compliance obligation.
From August 2026 onwards, manufacturers must provide a declaration of conformity, often referred to as a packaging passport. This document specifies which materials are used, whether hazardous substances are present and to what extent the packaging meets EU recyclability criteria. In addition, harmonised EU disposal labels will be introduced to ensure that consumers across all Member States receive consistent instructions on how to sort and dispose of packaging correctly.
Meeting these requirements demands accurate material data, transparent reporting and consistent, compliance-ready packaging design.
How prepared are companies for the PPWR?
Large multinational organizations with advanced sustainability strategies have already embedded circularity into their long-term business models. Companies such as Unilever, Rituals and Grolsch are investing in packaging redesign, supply chain collaboration and data-driven decision-making to meet upcoming PPWR compliance requirements.
For many small and medium-sized enterprises (SMEs), the transition is more complex. They often face logistical and technical barriers, including identifying suppliers that meet new recycled content and recyclability standards, adapting packaging formats, and modifying internal processes and production equipment.
Technically, there are several challenges in applying recycled plastic, including contamination with rPET and recycled PP, odor and taste abnormalities with food contact, lower strength with higher recycling rates, and color variations affecting product quality. Materials such as EPS remain difficult to recycle due to the amount of air in the material.
Exceptions to the use of recycled content exist for packaging in the food and pharmaceutical sectors, provided it can be properly substantiated that food safety or product quality will be compromised. Those who start too late risk higher costs and disruptions in the supply chain.
Data as the foundation for PPWR compliance
One of the biggest bottlenecks in meeting PPWR compliance requirements is the collection and management of reliable packaging data. Accurate data is essential not only for regulatory reporting and declarations of conformity, but also for strategic decisions in packaging design, procurement and supplier selection.
Many organizations still rely on fragmented data systems, spreadsheets and disconnected databases. This increases the risk of reporting errors, delays and inefficiencies — particularly as EU packaging legislation becomes more complex and data-driven.
Solutions such as GS1 PAC enable companies to centrally capture packaging specifications and securely share standardized data across the value chain. This reduces duplication, lowers administrative burden and improves readiness for evolving compliance obligations. For organizations like Superunie, structured packaging data management has proven that compliance is not just a regulatory necessity but also a financial opportunity. Better data transparency can lead to measurable cost savings, including reduced waste management fees and improved supply chain efficiency.
European differences increase complexity
For multinational companies and non-EU companies entering the European market, an additional layer of complexity is added. European legislation is applied differently nationally, with varying requirements around labeling, recycled content, taxation, ecodesign and producer responsibility.
In Germany, research shows that only 10 percent of companies currently meet the basic requirements of the PPWR. Lack of time, lack of clarity and cost are the biggest bottlenecks.
Belgium, especially Flanders, takes a different approach. Initiatives such as Value4Pack support companies in knowledge sharing, collaboration and digitalization around packaging. This gives companies quicker insight into their packaging flows and necessary adjustments.
In France, companies already have experience with national labeling requirements such as Triman. Practical examples show that producers are willing to become more sustainable, but come up against technical and logistical limits in improving recyclability.
Italy and Spain also have their own environmental labeling rules. For now, companies must comply with both national obligations and the upcoming PPWR, which requires additional coordination within international chains.
What can companies do now?
Companies that start now create space to make informed choices. Start with packaging with the shortest compliance deadlines and focus on large volumes where the impact is greatest. Start with relatively simple steps such as material simplification and plan more complex redesigns for the longer term.
Looking ahead:Turning compliance into competitive advantage
The PPWR is not a tick-box law, but a structural change in how Europe approaches packaging sustainability, circular design and resource efficiency. Companies that take charge now are leveraging the PPWR as an accelerator of their circular strategy. Designing packaging smarter, putting data in order and working together in the chain creates not only compliance, but also value.
According to Milgro, circularity starts with overview and grip. Do not wait until rules force, but already steer on reduce, reuse and recycle. Thus, the PPWR is not an end point, but a logical intermediate station towards a future-proof business.
Need help preparing for the PPWR?
During our webinar you will be given practical tools to get your organization ready. Afterwards, you will know how to effectively apply the principles of reduce, reuse and recycle. Watch it here
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