From 12 August 2026, the European Union’s new rules on packaging and packaging waste will start to apply. The Packaging and Packaging Waste Regulation (PPWR) introduces a harmonised set of requirements across the EU for the design, composition, recyclability, reusability, labelling and documentation of packaging.
Regulation (EU) 2025/40 of the European Parliament and of the Council, the Packaging and Packaging Waste Regulation – PPWR, does not only affect packaging manufacturers.
The regulation may create obligations for any company that places packaged products on the European Union market, uses packaging, imports or distributes packaged goods, handles packaging in logistics processes, or is involved in packaging compliance through its supply chain. Hungarian companies may therefore also be affected even if they are not packaging manufacturers themselves.
Preparing for PPWR compliance requires the timely collection and structuring of packaging data, supplier declarations, technical documentation and internal processes.
Why does PPWR create a business risk?
Under the PPWR, only packaging that complies with the requirements of the regulation may be placed on the EU market. A general supplier declaration will not be sufficient to demonstrate compliance. Companies need to understand whether the packaging they use or place on the market complies with requirements relating, among others, to material composition, heavy metal restrictions, recyclability, packaging minimisation, recycled content and documentation.
Companies that may be particularly affected include:
- manufacturing companies,
- importers,
- wholesalers and distributors,
- e-commerce businesses,
- FMCG and retail companies,
- food industry and hospitality businesses,
- logistics and packaging service providers,
- companies placing private label products on the market,
- companies that are already subject to EPR obligations in Hungary due to packaging.
Failure to comply with PPWR requirements may not only create regulatory risks, but also supplier, sales and operational risks. Non-compliant packaging, incomplete documentation or missing supplier data may disrupt the uninterrupted market presence of products.
PPWR compliance – how can RSM help?
RSM Hungary supports its clients with comprehensive PPWR compliance review and advisory services, helping companies prepare for the new EU packaging regulation and understand the practical implications of the rules in Hungary.
Our experts map the packaging types used by the company, review the relevant business processes, identify the applicable PPWR compliance requirements, and perform a GAP analysis to reveal the differences between the current operation and the regulatory expectations.
As a result of the review, the company receives a clear overview of which packaging types, documentation, supplier data and internal processes need to be modified or supplemented in order to achieve PPWR compliance.
I am interested in the PPWR complaince service
Main elements of our PPWR compliance service
PPWR impact and packaging assessment
As the first step of the project, we review the packaging and packaging materials used by the company, the relevant product and packaging data, the affected business processes, and the parties involved in the supply chain.
The purpose of the assessment is to identify precisely which packaging types, organisational units, suppliers and processes are affected by the PPWR requirements.
PPWR compliance review
During the review, we assess the main PPWR requirements applicable to packaging, with particular regard to:
- packaging minimisation,
- recyclability requirements,
- requirements relating to recycled plastic content,
- material composition and labelling,
- heavy metal restrictions,
- documentation required to demonstrate compliance,
- obligations of manufacturers, importers, distributors and suppliers.
Review of heavy metal restrictions and material composition requirements
The PPWR places significant emphasis on reducing harmful substances in packaging. During the review, we examine whether the information and documents are available for the packaging materials that support compliance with the statutory limit values for lead, cadmium, mercury and hexavalent chromium.
Determining supplier documentation requirements
One of the most important practical questions of PPWR compliance is what documents the company can obtain from packaging material manufacturers, suppliers or third-country partners.
PPWR GAP analysis and risk classification
We present the differences between the company’s current practice and the PPWR requirements in a structured GAP analysis. As a result of the review, a compliance matrix is prepared, identifying deficiencies, areas for improvement and the risk classification of each compliance element.
PPWR compliance action plan
Based on the identified deficiencies, we prepare an action plan to support the company in scheduling and prioritising the preparation process. The action plan may include recommendations for the necessary documentation, supplier-related, process-related and organisational steps.
Support for technical documentation and declarations of conformity
Under the PPWR, technical documentation and the EU declaration of conformity play a key role in demonstrating compliance. RSM provides professional support in developing the required documentation framework, preparing declarations of conformity and meeting traceability requirements.
Why RSM Hungary?
Preparing for PPWR compliance requires a combined understanding of regulatory, tax, environmental product fee, EPR, supply chain and corporate process considerations. RSM Hungary’s experts support clients with a practical approach, helping them treat the new packaging requirements not as a retrospective compliance risk, but as a structured and manageable compliance project.
Our experts help assess the company’s exposure, identify gaps, determine supplier documentation needs and prepare the necessary compliance steps, with a clear focus on the obligations and practical reporting expectations affecting Hungarian companies.
Prepare in time for the PPWR requirements
As the 12 August 2026 application date approaches, companies should review as soon as possible whether their packaging, supplier documentation and internal processes comply with the new EU regulation.
FAQ – PPWR compliance
What is PPWR?
PPWR, the Packaging and Packaging Waste Regulation, is the European Union’s new regulation on packaging and packaging waste. It introduces harmonised EU requirements for the sustainability, recyclability, reusability, labelling and documentation of packaging.
From when must the PPWR regulation be applied?
The PPWR entered into force on 11 February 2025 and, as a general rule, will apply from 12 August 2026. Certain obligations may be subject to different transitional deadlines.
Who is affected by PPWR obligations?
Manufacturers, importers, distributors, e-commerce businesses, logistics service providers, packaging material suppliers and any company placing packaged products on the EU market may be affected.
How does PPWR differ from EPR obligations?
EPR primarily refers to record-keeping, reporting and fee payment obligations related to the extended producer responsibility system. In Hungary, this means specific Hungarian EPR registration, data reporting and fee payment obligations.
PPWR, by contrast, lays down EU-level requirements for the design, composition, compliance, recyclability, documentation and placing on the market of packaging. The two areas are connected, but they are not the same.
