The PPWR, or Packaging and Packaging Waste Regulation, is the European Union’s new regulation on packaging and packaging waste. Regulation (EU) 2025/40 entered into force on 11 February 2025 and, as a general rule, will apply from 12 August 2026. The legislation may affect any business that places packaged products on the EU market or manufactures, imports, uses, distributes or handles packaging as part of its logistics processes.
The PPWR aims to reduce unnecessary packaging and the amount of packaging waste while introducing harmonised EU requirements concerning packaging recyclability, reusability, material composition, labelling, documentation and demonstration of conformity. Businesses should already be assessing the types of packaging they use, the documentation available from their suppliers and how they will be able to demonstrate compliance with the PPWR.
What is the PPWR, and why is it important for businesses?
From 12 August 2026, the provisions of the European Union’s Packaging and Packaging Waste Regulation, commonly referred to as the PPWR, which entered into force in February 2025, will become directly applicable in every EU Member State.
The Packaging and Packaging Waste Regulation is far more than an update of the EU’s previous directive-based framework for packaging. The PPWR establishes a new, directly applicable EU regulatory framework that also introduces a new approach to corporate compliance obligations relating to packaging and packaging waste in Hungary.
The Regulation aims to reduce the environmental impact of packaging throughout its entire life cycle, promote reuse, refill and recycling, and harmonise the applicable rules across EU Member States. For businesses, this means that packaging is no longer merely a procurement, logistics or marketing issue, but also a compliance, documentation and supply-chain risk.
Who is affected by the PPWR?
Almost every business should become familiar with the abbreviation PPWR.
In practice, the Regulation may affect any business that currently has extended producer responsibility, or EPR, obligations in relation to the packaging of the products it sells. In other words, PPWR obligations may apply to any business placing packaged products on the EU market, regardless of whether it manufactures or imports those products. The obligations relate to the packaging itself, rather than to the product contained within it.
The following businesses may be particularly affected:
- manufacturers
- importers
- distributors
- wholesalers
- e-commerce businesses
- companies selling private-label products
- FMCG and retail companies
- businesses operating in the food and hospitality sectors
- logistics service providers
- packaging manufacturers and suppliers
- companies selling packaged products in multiple countries.
PPWR is particularly important for companies that use a wide variety of packaging types, work with multiple suppliers, sell products across several countries, import goods or operate complex logistics processes,” emphasised István Falcsik, Head of Customs, Excise and Waste Management Advisory at RSM Hungary.
PPWR complance and preparation support from RSM
What new requirements does the PPWR introduce?
The PPWR introduces new or more detailed requirements for packaging in several areas. Businesses will need to assess not only whether packaging adequately protects the product, but also whether it complies with EU sustainability, recyclability, material-composition and documentation requirements.
Key areas covered by the PPWR:
Packaging minimisation
Packaging must be designed so that its weight and volume are reduced to the minimum necessary while maintaining its functionality. Oversized or unnecessarily large packaging, as well as packaging designed to artificially increase the perceived volume of a product, may create increased compliance risks in the future.
This may be particularly relevant for e-commerce, grouped, transport and consumer packaging, where the empty-space ratio, the number of packaging layers and the amount of material used must also be assessed.
Recyclability requirements
One of the central elements of the PPWR is that packaging must be designed to be recyclable. This is not merely a general principle: when designing packaging and determining its material composition and labelling, as well as when considering its treatment once it becomes waste, businesses must ensure that the packaging can be collected, sorted and recycled.
From 2030, the Regulation will introduce recyclability performance grades, with further tightening of the requirements expected at a later stage. Businesses preparing for compliance in 2026 should therefore also take longer-term compliance requirements into account.
Recycled plastic content
For plastic packaging, one of the key requirements will be a minimum recycled content derived from post-consumer plastic waste. This obligation will not apply to all types of packaging in the same way or from the same date. Businesses must therefore assess separately which of their packaging types are affected.
Material composition and heavy-metal restrictions
The PPWR places particular emphasis on minimising substances of concern in packaging. With regard to restrictions on heavy metals in packaging materials, the legally defined aggregate concentration limits for lead, cadmium, mercury and hexavalent chromium may be particularly relevant.
Businesses should therefore assess whether they have access to supplier declarations, material-composition data, technical data sheets or laboratory test reports that substantiate the compliance of their packaging materials.
Labelling and consumer information
The PPWR also introduces new packaging-labelling requirements. These rules are intended to provide consumers and waste-management operators with clearer information about the material composition, handling, reusability and recyclability of packaging.
Compliance documentation and the EU declaration of conformity
One of the most important practical consequences of the PPWR is that packaging conformity must also be demonstrated through documentation. The information contained in the declaration of conformity must be supported by comprehensive technical documentation.
Manufacturers, importers and distributors should therefore use the preparation period to review whether the required data and supporting documents are available. Where packaging materials or packaged products originate from a third country, the importer may have a particularly important responsibility to obtain the appropriate declarations and technical documentation.
The documentation may be requested by the competent authorities. Establishing an appropriate documentation system and ensuring traceability are therefore key aspects of PPWR compliance.
PPWR deadline: 12 August – why is it not enough to address the PPWR at the last minute?
As with the CBAM, EPR, DRS and EUDR rules that have affected manufacturers, importers and traders in recent years, the PPWR raises numerous practical questions for which there may not always be an immediate or unambiguous answer.
The information required for compliance is often not held by a single organisational unit. Packaging data may be held by procurement, logistics, quality assurance, product development, environmental or EPR teams, or by external suppliers. Preparation therefore requires cooperation between several business functions.
Among other matters, businesses will need to answer the following questions:
- What types of packaging does the company use?
- Which packaging is placed on the EU market?
- Which packaging is associated with imported products?
- What material-composition data is available?
- Are supplier declarations of conformity available?
- Are technical data sheets and testing documentation available?
- Is the packaging subject to recyclability, reusability or recycled-content requirements?
- Who is responsible for collecting and retaining the documentation?
- How does the PPWR relate to the company’s existing EPR processes?
István Falcsik emphasised: Businesses should not wait until August 2026 to start answering these questions. Obtaining supplier documentation, completing missing data, reviewing packaging and developing an action plan may all be time-consuming processes.
How should businesses begin preparing for the PPWR?
The first step in preparing for the PPWR is to assess whether and to what extent the company is affected, as well as its current level of compliance. As part of this assessment, businesses should review:
- the types of packaging currently used;
- the material composition of packaging materials;
- the recyclability of the packaging;
- compliance with packaging-minimisation requirements;
- the availability and adequacy of supplier documentation;
- documentation relating to imported packaging;
- internal responsibilities and data flows;
- the interfaces with EPR and waste-management processes.
Based on the findings, a gap analysis can be prepared to identify discrepancies between current practices and the PPWR requirements. This should be followed by an action plan setting out how identified shortcomings will be addressed, supplier documentation will be obtained, internal processes will be modified and the necessary compliance documentation will be compiled.
How can RSM Hungary’s PPWR compliance services help?
As part of our services, we map the packaging used by the company, review the relevant business processes, identify the applicable PPWR compliance requirements and conduct a gap analysis to identify differences between current operations and the regulatory requirements.
The project may cover, in particular, the following areas:
- reviewing the packaging and packaging materials used by the company;
- collecting relevant product and packaging data;
- identifying the business processes and organisational units concerned;
- mapping supply-chain participants and the flow of supplier information;
- assessing compliance with packaging-minimisation requirements;
- conducting a preliminary assessment of recyclability requirements;
- reviewing the requirements concerning recycled plastic content;
- assessing material-composition and labelling requirements;
- reviewing documentation relating to heavy-metal restrictions;
- determining which documents need to be requested from suppliers;
- preparing a PPWR gap analysis and action plan;
- supporting the preparation of technical documentation and the declaration of conformity.
As a result of the project, the company may receive a clear management report, a gap analysis, a list of supplier-documentation requirements, a compliance action plan, and templates for PPWR documentation and the declaration of conformity.
PPWR: a new compliance obligation that should be incorporated into business processes in good time
The PPWR is not merely another environmental regulatory obligation. The Regulation may affect multiple areas of a company’s operations, from packaging design and procurement to imports, distribution, logistics, labelling and document management.
Businesses that start preparing in good time can not only reduce regulatory risks but also make their packaging and supplier-management processes more transparent. This may be particularly important for companies working with multiple packaging-material suppliers, imported products, high packaging volumes or sales across several EU markets.
Prepare for the PPWR requirements in good time
With the application date of 12 August 2026 approaching, businesses should assess as soon as possible whether their packaging, supplier documentation and internal processes comply with the requirements of the new EU packaging regulation.
RSM Hungary’s experts provide support in assessing the company’s exposure to the PPWR, identifying compliance gaps, determining supplier-documentation requirements and developing the necessary action plan.an.
Contact our experts and start preparing for the new PPWR obligations in good time.
