The new EU law replaces the previous Packaging Waste Directive (PWD).

The EU Packaging and Waste Directive set packaging and waste goals for EU member states to achieve but allowed each state the flexibility in how the directive was implemented. Implementation of this regulation makes the action obligatory.

In broad terms, the PPWR aims to ensure that:

• packaging is recyclable, minimally wasteful, and clearly labelled
• published recycled content targets for plastic packaging are achieved by the 2030 and 2040 regulatory deadlines
• reuse or refill options must be offered for given products
• unnecessary packaging and harmful substances should be avoided

Considerations for UK Exporters

UK exporters will need to comply with the implemented packaging and packaging waste regulation when placing packaged goods into the EU market.  This includes all aspects of packaging, including labelling, recyclability and the ability for reuse.

UK deliveries that are set to cross the border where the regulation requirements have not been met could result in goods being rejected at EU borders.  

It is therefore vital to the UK – EU flow of trade that UK exporters review the new regulation to ensure that their consignments are compliant if they are due for import into the EU on or after 12^th August this year.

Who needs to evidence compliance?

The regulation applies to all UK businesses placing packaging on the EU market. This will include;

•  Manufacturers
•  Importers
•  Distributors
• Retailers

All packaging types will be captured, including primary, secondary, tertiary, and service packaging.

Micro-enterprises will be subject to lighter controls but will still need to meet core obligations.

UK exporters and EU EPR obligations

UK exporters may also need to consider whether EU Extended Producer Responsibility (EPR) obligations apply when selling packaged goods into the EU. This will depend on the structure of the supply chain and the role the UK business, EU customer, importer or other intermediary takes under the PPWR.

Extended Producer Responsibility – Definition

Extended Producer Responsibility is a policy approach under which those placing products or packaging on the market may be required to take financial, and in some cases organisational, responsibility for the waste stage of that product’s life cycle.

For UK businesses exporting to the EU, the key point is to identify who is responsible for the packaging in the EU market of sale.

Where the UK business falls within scope, it may need to register with the relevant national authority or EPR scheme and provide packaging data.

This data may include packaging type, material, weight, recyclability and recycled content. Requirements will vary by EU Member State, so exporters should ensure that the rules in the destination market are checked as part of their export compliance process.

The practical steps below should help businesses begin reviewing their position, with more detailed guidance on putting the regulation into working practice to follow in next week’s article.

PPWR in Northern Ireland

Much of PPWR will apply in Northern Ireland under the Windsor Framework.  An EU Commission notice has been published giving the regulatory definition of specific parts of the regulation that will not apply to Northern Ireland

A link to the Commission Notice is provided below

C_202500946EN.000101.fmx.xml

Suggested Action checklist

UK exporting businesses should consider the following practical steps when preparing to place packaged goods on the EU market:

1. Understand business obligations: Review the PPWR requirements and confirm which role the business, and any EU-based customer or intermediary, may occupy in the supply chain. This should include considering whether any national EPR obligations, thresholds, fees or local representation requirements apply in the EU market of sale.
   
   
2. Assess packaging:  Check whether the packaging used for the goods meets the relevant PPWR requirements, including recyclability, labelling, packaging minimisation and any recycled content obligations. Businesses should also consider whether the destination Member State has specific national reporting or EPR requirements.
   
   
3. Register with any appropriate EPR schemes:  Where the business falls within the scope of a national EPR scheme, it may need to register, submit packaging data and pay any relevant fees. Where there is no EU establishment, businesses should also consider whether an authorised representative or local service provider is needed to manage obligations in the Member State concerned.
   
   
4. Data collection and reporting: Put processes in place to collect packaging data in good time, including packaging type, material, weight, recyclability and recycled content where required. Compliance records should be kept to evidence the steps taken, as these may be requested by authorities or scheme operators.

Useful links are included below:

Department for Business and Trade PPWR link is below:

EU PPWR – Packaging and Packaging Waste Regulation

A link to the EU information page is provided below:

Packaging & Packaging Waste Regulation - European Commission

A link to the full text of the EU regulation can be found here:

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC (Text with EEA relevance)

The EU guidance document can be found here:

eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=PI_COM:C(2026)3702

A link to the EU FAQ document can be found at the link below:

FAQ on Packaging and Packaging Waste Regulation (PPWR) - Environment