How to prepare for PPWR: a practical guide

New EU packaging rules are reshaping how packaging will be designed, manufactured and managed over the coming years, affecting all businesses across the packaging value chain. While some of the most significant requirements will not apply until later in the decade, the first obligations take effect from 12 August 2026.

Known as the Packaging and Packaging Waste Regulation (PPWR), the legislation replaces the previous Packaging and Packaging Waste Directive with a single set of rules that apply across all 27 EU member states. Its aim is to reduce packaging waste, increase recyclability and recycled content, reduce the use of virgin raw materials, and support the transition to a more circular economy.

This guide explains the practical steps plastics packaging companies can take now to prepare for the new requirements and begin planning for the changes still to come.

1. UNDERSTAND WHAT PPWR MEANS FOR YOUR BUSINESS

The regulation applies to all packaging placed on the EU market, regardless of material or origin, and covers the full packaging lifecycle, from design and material selection through to waste management and recycling.

The regulation will introduce new requirements affecting areas including recyclability, recycled content, reuse, packaging minimisation, restrictions on certain substances, labelling and compliance documentation. The specific obligations will depend on a variety of factors including the type of packaging, its intended use and the activities a company carries out.

The European Commission provides a detailed overview of the regulation, including its objectives, implementation timeline and supporting guidance for businesses and other stakeholders.

Understanding where your business sits within these requirements is an important first step in identifying the changes that may be needed.

Which packaging formats are affected?

PPWR covers most primary, secondary and tertiary packaging placed on the EU market, although specific requirements and exemptions vary depending on the packaging type and use. For plastics packaging companies, this means a wide range of products may be affected, from consumer packaging through to industrial and transport packaging.

Relevant formats may include rigid and flexible plastics packaging, food and beverage packaging, trays, containers, films, pouches, crates, pallets, drums and other industrial packaging formats.

What role does your company have?

Responsibilities under PPWR will vary depending on where a business sits in the packaging value chain.

Packaging manufacturers, converters, material suppliers and importers will have an important role in supporting compliance because they provide the packaging products and technical information needed by other businesses in the supply chain. Customers are likely to require more detailed information about areas such as material composition, recycled content and recyclability.

Manufacturers will also need to meet specific compliance obligations, including preparing technical documentation, completing conformity assessment procedures and issuing an EU Declaration of Conformity where required.

Companies should, therefore, understand not only the requirements affecting their own products, but also the information and evidence they may need to provide to customers and other supply chain partners.

Who needs to be involved internally?

PPWR should not be treated as an issue for the packaging team alone. Meeting the requirements will involve different parts of the business because packaging decisions affect materials, suppliers, product design, documentation and customer communication.

Teams that may need to be involved include:

• Packaging design and product development, which may need to review materials, structures and future design changes.
• Procurement, which may need to collect information from suppliers and assess alternative materials or components.
• Quality and compliance teams, which may need to manage technical documentation and conformity requirements.
• Sustainability teams, which may need to support recyclability assessments, recycled content information and sustainability reporting.
• Commercial teams, which may need to respond to customer requests for packaging information.

Assigning responsibility early will help ensure that packaging data, technical information and compliance activities are managed across the organisation.

What are the main areas to prepare for?

Companies will need to review several areas of their packaging operations, including:

• Recyclability – packaging will need to meet future recyclability requirements, with design-for-recycling criteria becoming increasingly important.
• Recycled content – certain plastics packaging formats will need to include minimum levels of recycled material.
• Reuse – some packaging categories will face new reuse targets and requirements.
• Packaging minimisation – companies will need to consider whether packaging uses more material than necessary.
• Restrictions and substances of concern – businesses should review whether their packaging contains substances of concern regulated under existing EU chemicals legislation, such as REACH, and understand any PPWR requirements affecting them, including restrictions on per- and polyfluoroalkyl substances in food-contact packaging. The European Commission is also due to publish a report by the end of 2026 assessing substances of concern in packaging and may identify additional substances requiring further action.
• Data and documentation – companies will need reliable information and evidence to demonstrate compliance.

2. AUDIT YOUR EXISTING PLASTICS PACKAGING PORTFOLIO

Before making changes to packaging designs or materials, companies need a clear understanding of what they currently produce or supply. A detailed review of existing plastics packaging will help identify which formats are affected, what information is available and where further action may be required.

This assessment should provide a complete picture of the packaging portfolio, including the materials used, how packaging is designed and whether it may meet future PPWR requirements.

Create an inventory of your packaging formats

The first step is to create a complete inventory of the plastics packaging formats your business manufactures or supplies.

This should include all relevant packaging types, including primary, secondary and tertiary packaging, as well as different versions or variants supplied to customers.

The inventory should identify:

• Packaging format and application.
• Materials used, including whether packaging contains multiple materials or components.
• Packaging weight and dimensions.
• Whether packaging is designed for single use or reuse.
• Where the packaging is supplied and whether it is placed on the EU market.

Creating this overview will help companies identify which packaging formats require further assessment.

Gather technical information about each packaging format

Once packaging formats have been identified, companies need to collect the technical information required to assess them against future PPWR requirements.

This includes information such as:

• Packaging materials and structure, including polymers, layers and components.
• Packaging weight, dimensions and design specifications.
• The intended application and performance requirements of each format.
• Whether packaging contains features that may affect future redesign options, such as additional components or complex structures.

Much of this information may already exist within a business, but it may be held across different departments or systems. Companies may also need to work more closely with suppliers to obtain information on materials, additives and other components used in packaging, particularly where this information is needed to assess regulatory requirements.

Building a reliable source of packaging data will provide the foundation for later assessments of packaging performance and compliance requirements.

Assess current compliance gaps

After gathering information about existing packaging, companies can begin identifying where further work may be required.

This assessment should help identify:

• Which packaging formats may require redesign or material changes.
• Where additional supplier information or technical data is needed.
• Which packaging formats may require further assessment against upcoming PPWR requirements.
• Which changes are likely to require the most time, investment or supply chain coordination.

The purpose of this review is not simply to identify non-compliant packaging, but to establish priorities. Some formats may require redesign, some may need additional supplier information and others may already meet future requirements.

A clear understanding of the current packaging portfolio will provide the foundation for the next stages of preparation, including reviewing packaging design, materials and compliance documentation.

3. REVIEW PACKAGING DESIGN AND RECYCLABILITY

One of the biggest changes introduced by PPWR is the move towards packaging that is designed for recyclability. Plastics packaging companies will need to review existing designs and identify where changes may be needed to meet future recyclability requirements.

This means looking beyond the polymer used in the main packaging component. Factors such as additional layers, coatings, additives, closures, labels, inks and other components can all affect whether packaging can be effectively recycled.

Companies should begin reviewing their current designs now to understand which formats may require changes and where improvements can be made.

Assess current packaging designs

Companies should assess whether existing packaging designs are likely to meet future recyclability requirements and identify any features that may create challenges.

Areas to review include:

• Whether the packaging structure uses compatible materials and avoids unnecessary complexity.
• Whether layers, coatings, additives, inks, labels or other components could affect recyclability.
• Whether different components can be effectively separated within existing recycling systems.
• Whether the packaging design supports recovery and recycling at scale.

This assessment should identify which packaging formats are likely to meet future requirements and which may need redesign.

A detailed review at this stage will also help businesses understand where further information is needed from suppliers, recyclers or testing partners.

Identify opportunities to improve recyclability

Where packaging designs present challenges, companies should consider how changes to materials, structures or components could improve recyclability while maintaining the required performance of the packaging.

Potential improvements may include:

• Simplifying packaging structures where possible.
• Reducing unnecessary components or materials.
• Moving towards designs that are easier to sort and recycle.
• Reviewing whether current coatings, additives, inks, labels or other features are necessary or could be changed.
• Working with suppliers and recyclers to identify practical design improvements.

Changes should be considered alongside the packaging’s function. Plastics packaging must continue to protect products, but companies may need to review whether current designs use more materials or components than necessary.

Working with packaging suppliers, material providers and recyclers can help identify practical design changes and ensure that new formats are suitable for recycling systems.

Prepare for future recyclability requirements

PPWR introduces a staged approach to recyclability requirements, with more detailed criteria and assessment methods expected to be established over time.

Companies must consider recyclability as an ongoing design consideration rather than a one-off review. Packaging formats may need to be reassessed as new technical criteria and guidance become available.

Starting this process early will give businesses more time to evaluate higher-risk packaging formats, plan redesign projects and test potential changes before future requirements apply.

4. PREPARE FOR RECYCLED CONTENT AND REUSE REQUIREMENTS

PPWR introduces new requirements for recycled content and reuse. Businesses should assess which recycled content and reuse requirements apply to their packaging formats, identify their current position and determine where changes may be needed.

For many companies, meeting these requirements will depend on having accurate information about existing packaging, working closely with suppliers and considering how materials and packaging systems may need to change.

Review recycled content requirements

The regulation mandates minimum recycled content requirements for certain plastics packaging formats. Companies should assess which of their products fall within scope, establish current recycled content levels and identify where changes may be needed to meet future targets.

From 2030, plastics parts of certain packaging formats will need to contain minimum levels of recycled content. For example, plastics parts of non-PET contact-sensitive packaging will need to contain at least 10 per cent recycled content, increasing to 25 per cent by 2040, while other plastics packaging formats will need to contain at least 35 per cent recycled content by 2030, increasing to 65 per cent by 2040.

Recycled content calculations will be based on an average across each manufacturing site over a year. This means companies will need reliable data on the amount of recycled material used across their production operations.

To prepare, businesses should:

• Identify which packaging formats are subject to recycled content requirements.
• Establish current recycled content levels across their product portfolio.
• Collect information from suppliers on recycled material content and availability.
• Assess whether current materials and production processes can meet future targets.
• Consider whether packaging designs or material choices may need to change.

Meeting recycled content requirements may also require closer collaboration across the supply chain. Packaging manufacturers, converters and material suppliers will need to understand future material availability, quality requirements and any technical challenges associated with using higher levels of recycled content.

Assess where reuse requirements may apply

PPWR establishes reuse targets for certain packaging categories. Companies should assess whether any of their packaging formats fall within scope and whether existing systems could support greater levels of reuse.

Meeting reuse requirements may involve changes beyond packaging design. Businesses may need to consider:

• Which packaging formats are currently designed for single use.
• Whether packaging can be redesigned for reuse while maintaining product protection and performance.
• Whether collection, return and cleaning systems are practical.
• How reuse could affect logistics, storage and supply chain operations.

The suitability of reuse will depend on factors such as the type of packaging, how it is used and whether systems are available to support repeated cycles. Companies should assess where reuse may be technically and commercially feasible within their own operations.

Plan changes to materials and supply chains

Meeting future packaging requirements may require changes to materials, suppliers and production processes. Companies should consider how these changes could affect availability, cost, technical performance and manufacturing operations.

Actions to consider include:

• Working with material suppliers to understand the availability and suitability of recycled polymers.
• Discussing future requirements with customers and supply chain partners.
• Assessing whether existing packaging specifications will need to change.
• Identifying potential impacts on cost, performance and production processes.

Starting this work as early as possible will give businesses more time to test alternative materials, adjust designs and develop solutions that meet PPWR requirements while maintaining the performance expected from plastics packaging.

5. BUILD THE DATA, DOCUMENTATION AND COMPLIANCE PROCESSES NEEDED FOR PPWR

Meeting PPWR requirements will depend on more than making changes to packaging design or materials. Companies will also need reliable information and supporting evidence to demonstrate that their packaging meets the applicable requirements.

For plastics packaging businesses, this means developing processes to collect, manage and maintain packaging data, technical information and compliance documentation.

Establish the information needed to demonstrate compliance

The information gathered during the packaging portfolio review will form the basis of the evidence needed to demonstrate compliance with PPWR. Companies should now consider how this information will be managed, verified and maintained over time, ensuring that it is accurate, traceable and linked to specific packaging formats.

Important information to maintain includes:

• Technical specifications linked to individual packaging formats.
• Supplier information supporting material composition, recycled content and other relevant claims.
• Evidence used to support recyclability assessments.
• Documentation relating to substances of concern and applicable restrictions.
• Records showing how packaging designs and materials have been assessed against relevant requirements.

Companies should establish reliable processes for collecting, organising and controlling this information as part of their compliance activities. They should also ensure that supplier information is obtained and verified, particularly where material composition, recycled content or chemical restrictions are concerned.

Accurate and traceable data will support a range of PPWR requirements, including recycled content calculations, recyclability assessments, customer requests and compliance documentation.

Prepare technical documentation and conformity assessments

PPWR introduces new requirements for demonstrating compliance with applicable packaging requirements. Manufacturers responsible for placing applicable packaging on the EU market will need to complete conformity assessment procedures and prepare an EU Declaration of Conformity where required under the regulation.

Technical documentation will need to provide evidence that the packaging meets the applicable requirements and support the EU Declaration of Conformity where required. Depending on the packaging format, this may include information such as:

• Product descriptions and specifications.
• Material composition and design details.
• Evidence supporting recycled content claims.
• Information demonstrating recyclability.
• Supporting evidence relating to applicable restrictions.

The exact information required will depend on the packaging format and the obligations that apply. Companies should ensure that documentation is linked to individual packaging designs and updated whenever materials, specifications or designs change.

Create processes to maintain compliance information

Compliance information should be actively managed, with processes in place to review and update records as packaging designs, materials or requirements change. Companies should establish procedures to review and update records when changes affect packaging or the evidence needed to demonstrate compliance.

Processes should be established to review and update information when:

• Packaging designs or materials change.
• New suppliers are introduced.
• Recycled content levels change.
• New technical requirements come into force.
• Customer or regulatory information requests are received.

Maintaining accurate and up-to-date information will help companies respond to customer requests, regulatory checks and future changes to their packaging portfolio.

6. CREATE A PPWR ACTION PLAN

PPWR introduces a series of requirements that will come into force over several years. Companies do not need to address every area at the same time, but they should establish a clear plan that identifies priorities, responsibilities and timelines.

Taking action early will give businesses more time to assess packaging formats, work with suppliers, make design changes and prepare the information needed to demonstrate compliance.

Prioritise changes based on risk and deadlines

After reviewing their packaging portfolio and identifying potential gaps, companies should prioritise the areas where action is most urgent or where changes are likely to require the most time and resources.

Priority should be given to packaging formats that:

• May not meet future recyclability requirements.
• Will be affected by recycled content targets.
• Could require significant redesign or material changes.
• Depend on supplier information that is not currently available.
• Are affected by earlier compliance deadlines.

Companies should also consider the practical challenges associated with making changes, including technical performance, production processes, supply chain availability and customer requirements.

A prioritised action plan will help businesses allocate resources effectively, coordinate changes across teams and address the areas with the greatest compliance risk.

Continue monitoring regulatory developments

Compliance with PPWR will be an ongoing process rather than a single deadline, with new obligations taking effect over the coming years, and further technical details and guidance developed as the regulation is implemented.

Companies should establish processes to monitor developments and review their preparation plans as new information becomes available.

This may include:

• Reviewing updates from European authorities, industry bodies and relevant standards organisations.
• Checking whether new guidance affects existing packaging assessments.
• Updating technical documentation when packaging designs or requirements change.
• Revisiting plans as future deadlines approach.

Preparing for PPWR will require companies to remain adaptable as new requirements, technical details and guidance emerge. Companies that build flexibility into their approach will be better positioned to adapt as requirements develop.

EU packaging policy timeline

20 December 1994: Packaging Directive enters into force
29 April 2015: Packaging Directive amended to reduce the consumption of lightweight plastics carrier bags
30 May 2018: Packaging Directive amended to reinforce prevention and to promote reuse and recycling of packaging waste
September 2020 – January 2021: Open public consultation on the review of requirements for packaging and other measures to prevent packaging waste
30 November 2022: European Commission adopted revision of EU rules on Packaging and Packaging Waste
11 February 2025: PPWR enters into force
12 August 2026: General application date of PPWR provisions

Sources for additional reading:

• European Commission – Packaging and Packaging Waste Regulation (PPWR)
• European Commission – Frequently Asked Questions: Packaging and Packaging Waste Regulation (PPWR)
• EUR-Lex – Regulation (EU) 2025/40 on packaging and packaging waste
• Packaging Europe – Guidance document answers important questions about the PPWR
• Trioworld – PPWR Roles Made Simple: Who is responsible under the EU packaging regulation?
• Plastic Ingenuity – PPWR Toolkit
• Carbon Trust – PPWR unpacked: What the EU Packaging and Packaging Waste Regulation means for business and how to prepare
• Beyondly – EU Packaging and Packaging Waste Regulation (PPWR) comes into effect
• Food and Drink Federation – PPWR Business Guidance
• PPWR Consulting – PPWR recycled content targets