In this Article

• What is the EU Packaging and Packaging Waste Regulation?
• Does PPWR apply to UK businesses?
• Which businesses could be affected by PPWR?
• What are the main PPWR requirements?
• What is the difference between PPWR and UK EPR?
• Are all PPWR requirements in place now?
• What should UK businesses do now?
• How can Flame UK help?

What Is the EU Packaging and Packaging Waste Regulation?

The Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40, replaces the EU’s previous Packaging and Packaging Waste Directive.

PPWR takes a broader approach to the entire packaging lifecycle. It aims to reduce unnecessary packaging, improve recyclability, increase the use of recycled materials and encourage greater reuse.

The regulation covers packaging of all types and materials placed on the EU market, including primary, secondary, tertiary and service packaging.

For businesses in scope, PPWR can therefore influence decisions much earlier in the packaging process, from design and material selection to sourcing, documentation and how products are eventually placed on the market.

What Does PPWR for UK Businesses Mean?

PPWR is an EU Regulation, but businesses based in the UK cannot automatically disregard it.

If a UK business sells packaged goods into the EU, it will need to understand the PPWR requirements that apply to those goods and its role in the supply chain.

This could make PPWR particularly relevant for UK manufacturers, exporters and e-commerce businesses selling products to customers within the EU.

Businesses operating in Northern Ireland should also be aware that the position is different due to the Windsor Framework and should review specific guidance to understand how PPWR applies.

For businesses in Great Britain, the key question is:

“Do we place packaging or packaged products on the EU market?”

If the answer is yes, further assessment may be required.

Which Businesses Could Be Affected by PPWR?

PPWR places obligations on different economic operators depending on their role within the packaging supply chain.

This can include:

• Manufacturers
• Importers
• Distributors
• Retailers
• Online and e-commerce sellers
• Fulfilment service providers
• Businesses supplying products under their own name or trademark

The exact responsibilities vary.

A business manufacturing packaging, for example, will not necessarily have the same responsibilities as a distributor selling a packaged product or a UK business exporting directly to customers in an EU Member State.

Businesses should therefore establish their role under PPWR rather than assuming the same requirements apply to everyone involved in the supply chain.

What Are the Main PPWR Requirements?

PPWR introduces a wide range of measures intended to reduce the environmental impact of packaging across the EU.

The requirements that apply will depend on factors including the type of packaging, the business’s role and the relevant implementation date.

Packaging Minimisation

Packaging will need to be designed so that its weight and volume are reduced to the minimum necessary while maintaining its functionality.

Businesses may therefore need to review whether packaging contains unnecessary material or excessive empty space.

Recyclability

PPWR introduces requirements intended to ensure packaging placed on the EU market is recyclable.

These requirements become progressively more significant over the coming years, making packaging design and material choices increasingly important.

Recycled Content

Certain plastic packaging will be subject to minimum recycled content requirements from 2030, with further targets applying from 2040.

Businesses using plastic packaging should begin understanding its composition and what information is available from suppliers.

Reuse and Refill

PPWR introduces reuse and refill requirements for certain types of packaging and activities.

Requirements vary depending on the packaging format and activity, so businesses should establish whether specific reuse requirements apply to them.

Restricted Substances and Packaging Formats

The regulation introduces restrictions affecting certain substances and packaging formats, making accurate information about packaging materials increasingly important.

Labelling and Consumer Information

New harmonised labelling requirements are being introduced to help consumers understand packaging materials and how packaging should be disposed of.

Businesses should consider the relevant implementation dates when planning future packaging and labelling changes.

Technical Documentation and Conformity

For businesses with manufacturer obligations, PPWR introduces conformity assessment requirements, including technical documentation and an EU Declaration of Conformity.

This is an important consideration for businesses that may previously have treated packaging compliance primarily as a waste or reporting issue.

PPWR vs UK EPR: What’s the Difference?

Businesses already familiar with the UK’s Extended Producer Responsibility for packaging may wonder whether complying with EPR means they are already prepared for PPWR.

They are separate regulatory frameworks.

UK packaging EPR focuses on producer responsibility for packaging placed on the UK market, including packaging data reporting and the costs associated with managing household packaging waste.

PPWR applies to packaging placed on the EU market and covers a broader range of requirements, including:

• Packaging design and minimisation
• Recyclability
• Recycled content
• Reuse and refill
• Labelling
• Technical documentation
• Conformity requirements

A UK business could therefore meet its domestic packaging obligations while still having additional responsibilities for products supplied into the EU.

Businesses operating across both markets should consider the requirements separately rather than assuming compliance with one automatically satisfies the other.

Are All PPWR Requirements in Place Now?

PPWR generally applies from 12 August 2026, but this does not mean every requirement takes effect at the same time.

The regulation has a phased implementation timetable, with significant requirements taking effect over the coming years.

The European Commission has published FAQs and guidance to help businesses and Member States understand the Regulation. However, additional implementing acts, delegated acts, standards and technical measures are still required in a number of areas.

Businesses therefore need to distinguish between requirements that apply now, those with future implementation dates and areas where further technical detail is still being developed.

PPWR compliance should be treated as an ongoing process rather than a single deadline.

What Should UK Businesses Do Now?

For businesses placing packaging or packaged products on the EU market, preparation should begin with understanding what packaging you use, where it goes and what information you already hold.

1. Establish Whether You Are in Scope

Review where your products are sold and identify whether packaging or packaged goods are being placed on the EU market.

You should also determine your role within the supply chain, as this can affect which obligations apply.

2. Build a Packaging Inventory

Create a clear record of the packaging associated with your products. Useful information may include:

• Packaging type and material
• Weight and composition
• Supplier
• Recycled content
• Recyclability
• Intended market

Having this information in one place can make it easier to identify gaps in your packaging data.

3. Speak to Your Packaging Suppliers

Engage with suppliers to understand what packaging data, specifications and supporting documentation they can provide.

Businesses may need more detailed packaging information than they have historically collected, so beginning these conversations early can help identify missing information.

4. Review Packaging Design

Consider whether your packaging could be affected by requirements around minimisation, recyclability, recycled content, restricted formats or reuse.

Changes to packaging can take time to develop, test and introduce, so future requirements should be considered before their relevant deadlines.

5. Review Your Documentation

Identify which technical documentation, declarations and records your business may be responsible for maintaining.

Existing UK packaging documentation should not automatically be assumed to satisfy EU requirements.

6. Assign Responsibility

PPWR can involve packaging, procurement, sustainability, compliance, legal, operations and supply chain teams.

Assigning clear internal responsibility can help ensure requirements are monitored and appropriate action is taken.

7. Monitor Further Developments

Further technical measures, standards and guidance will continue to shape PPWR implementation.

Businesses in scope should monitor these developments and review their compliance plans when necessary.

Preparing Your Business for PPWR

PPWR represents a significant change in how packaging is regulated within the EU.

For UK businesses trading with EU customers, understanding your packaging, supply chain and responsibilities now can help identify potential gaps and prepare for future requirements.

Flame UK has produced two resources to help businesses get started:

PPWR Compliance Guide for Producers

An overview of the Regulation, who it applies to, key compliance obligations, important implementation dates and actions businesses should be considering.

PPWR: A Practical Checklist for Producers

A practical checklist covering areas including assessing whether your business is in scope, creating a packaging inventory, engaging suppliers, reviewing packaging design, preparing documentation and assigning internal responsibilities.

As PPWR implementation continues, businesses should keep their packaging strategy and compliance processes under review.

How Can Flame UK Help?

While PPWR introduces new responsibilities for businesses placing packaging on the EU market, effective packaging waste management remains an important part of improving resource efficiency.

Flame UK works with businesses across the UK to review waste management arrangements, improve visibility of waste data and identify opportunities to reduce waste and increase recycling.

Our team can support your business with:

• Packaging waste management: Identifying appropriate collection and recycling solutions for different packaging waste streams.
• Waste data and reporting: Improving visibility of waste volumes, recycling performance and waste management activity.
• Waste reviews: Identifying opportunities to reduce unnecessary waste, improve segregation and increase recycling.
• Supplier management: Providing a single point of contact for waste services across multiple sites and waste streams.
• Waste reduction: Identifying practical opportunities to move waste further up the waste hierarchy.

While PPWR introduces specific regulatory responsibilities for businesses placing packaging on the EU market, improving visibility of packaging waste and wider waste management processes can support your overall approach to resource efficiency.

Want to take a closer look at how your business manages packaging and waste? Contact Flame UK today to speak to our team.

📧 businessdevelopment@flameuk.co.uk
📞 0115 896 5460