The Packaging Regulation is the EU product rule with the widest reach, because almost everything sold is packaged. It moves the question from the waste end to the design end: the packaging has to be designed so it can be recycled, it has to contain a share of recycled material, it may not be larger than the contents require, and it has to be labelled so whoever throws it away knows where it goes. The requirements step up over time, and anyone redesigning packaging today is designing for the step that is coming.
Requirements on the packaging itself
- Recyclability, assessed in performance grades — and what happens to packaging that lands in too low a grade.
- Recycled content: which targets apply to which material, how the share is calculated and what counts as evidence.
- Minimisation and empty space: the packaging should be no larger or heavier than the function requires, which hits e-commerce boxes hard.
- Labelling: harmonised symbols for material and sorting, on the packaging and where applicable on the receptacle.
- Prohibited formats and substances, where certain single-use packaging disappears altogether.
Requirements on you as an organisation
- Which role you hold — manufacturer, importer, distributor or the party filling the packaging — because obligations follow the role and most companies hold more than one.
- Extended producer responsibility: registration, fees and the reporting they are based on.
- Targets for reuse and collection, and the deposit systems that come with them.
- Checks and penalties, and what market surveillance can ask you to produce.
- How the work is introduced without stalling in an investigation: who owns the packaging data, and where in product development the requirement belongs.
The packaging is a product with requirements of its own
What separates the regulation from the directive before it is that the packaging is assessed in its own right, against requirements that have to be met when it is placed on the market. That makes packaging choices a design question with a documentation duty, and moves them from buying packaging materials to product development.
Questions about PPWR
- We do not manufacture packaging. Does it still apply to us?
- Yes, if you fill, import or sell packaged products. The regulation places obligations on several roles in the chain, and whoever packs their own product in a bought box carries a responsibility for that box. The course starts by sorting out which role or roles you hold.
- What about transport packaging and industrial packaging?
- They are in scope too. The regulation distinguishes between sales, grouped and transport packaging, and the requirements differ, but pallet wrap, dunnage and crates do not fall outside. For manufacturing industry that is often where the largest volume sits.
- Is this the same as the producer responsibility we already have?
- National producer responsibility remains and is built into the regulation's system, but PPWR adds requirements on how the packaging is designed — recyclability, recycled content, empty space and labelling. Reporting you already do is part of the work, then, not all of it.
- What do we need to do first?
- Know which packaging you actually place on the market and what it is made of. Almost everything else — classification, calculating recycled content, fees, labelling — is built on that list, and in most companies it is not collected anywhere.
Training in PPWR
An online course at your own pace, for packaging managers, product development, purchasing and sustainability.
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