Food and drink businesses selling into the European Union need to prepare for significant changes to packaging regulation, with the EU’s Packaging and Packaging Waste Regulation generally applying from 12 August 2026.

Known as the PPWR, Regulation (EU) 2025/40 replaces the Packaging and Packaging Waste Directive. It introduces measures intended to reduce packaging waste, improve recyclability, increase the use of recycled materials and create more consistent rules across the EU.

The regulation applies to packaging placed on the EU market, meaning UK exporters will need to comply where relevant. Non-compliance could prevent products from being lawfully placed on the market and lead to enforcement action or disruption to shipments.

Many of the PPWR’s detailed obligations will be introduced in stages, but food and drink businesses should begin reviewing their packaging, supply chains and reporting processes now.

Which businesses are affected?

The PPWR covers businesses placing packaging or packaged products on the EU market, including manufacturers, importers, distributors and retailers.

For food and drink brands, its scope extends beyond the packaging immediately surrounding a product. It can include:

• Primary packaging, such as bottles, cans, jars, pouches and wrappers
• Secondary packaging, including multipacks, trays and display boxes
• Tertiary or transport packaging, such as cases, pallets and protective materials
• Service packaging used when products are supplied or served

Micro-enterprises may benefit from exemptions or lighter obligations under certain provisions, but they are not excluded from the regulation altogether.

UK exporters also need to establish which business is legally responsible for placing a product on the EU market. This may depend on the commercial arrangements between the brand, importer, distributor and retailer, so responsibilities should be clearly defined in contracts rather than assumed.

Start with a packaging audit

A detailed packaging audit is one of the most useful first steps a business can take.

Brands should document every packaging component used across their ranges, including less visible materials such as labels, adhesives, closures, coatings, sleeves and internal protection. Secondary and transport packaging should be included alongside consumer-facing packs.

For each component, businesses should consider recording:

• Material composition
• Packaging weight
• Recycled content
• Available evidence about recyclability
• Supplier and country of origin
• Food-contact status
• Coatings, inks and chemical treatments
• The markets in which the packaging is placed on sale

Not every item on this list is a specific PPWR reporting requirement, but maintaining detailed information will help brands identify knowledge gaps, assess risks and respond to requests from importers, customers and national packaging schemes.

Packaging suppliers should be asked to provide evidence supporting claims about composition, recycled content and recyclability. General assurances that packaging is “sustainable” or “widely recyclable” may not provide the technical information needed to demonstrate compliance.

Design packaging for recyclability

The PPWR aims to make all packaging placed on the EU market recyclable in an economically viable way by 2030.

Design-for-recycling requirements are due to apply from 2030, while requirements relating to packaging being recycled at scale will follow from 2035. The European Commission is developing further criteria and assessment methods to support implementation.

For manufacturers, this makes packaging design a compliance issue as well as a sustainability and marketing consideration. Complex combinations of materials, difficult-to-separate components and certain coatings, labels or adhesives could affect the recyclability of a pack.

Businesses developing new products should involve packaging and compliance specialists early in the process. Launching a product in packaging that will soon need to be redesigned could create unnecessary expense, write-offs and disruption.

Brands should assess whether packaging is likely to meet the applicable EU design-for-recycling and recyclability-at-scale requirements, rather than relying solely on whether its individual materials are technically capable of being recycled.

Prepare for recycled-content requirements

The regulation introduces minimum recycled-content targets for certain plastic packaging from 2030, followed by higher targets from 2040. The applicable requirements will depend on the packaging format, material and intended use, with exemptions applying in some circumstances.

Food and drink manufacturers will need to consider these targets alongside existing requirements governing food-contact materials, product safety, shelf life and hygiene.

Businesses using plastic packaging should speak to suppliers about the future availability of compliant recycled material. Demand may increase as the deadlines approach, potentially affecting costs, lead times and availability.

Any claims about recycled content should be supported by appropriate documentation and supply-chain traceability.

Eliminate unnecessary packaging

The PPWR includes measures intended to reduce packaging weight, volume and empty space. It also restricts certain avoidable packaging formats and requires businesses to consider whether the same function could be achieved with less material.

Food and drink brands should examine:

• Oversized boxes or containers
• Unnecessary secondary packaging
• Excessive empty space
• Decorative layers with no protective function
• Single-use packaging that could be removed or replaced
• Transport packaging that could be reused

Reducing packaging can lower material, storage and transport costs, but changes should be tested properly. A lighter pack that results in greater product damage, contamination or food waste may not deliver an environmental or commercial benefit.

The PPWR also introduces restrictions on certain single-use packaging formats. The precise effect will depend on the packaging, product, setting and any applicable exemptions, so businesses should assess individual formats against the regulation rather than assume that all single-use packaging is prohibited.

Review food-contact packaging for PFAS

The regulation introduces limits on certain per- and polyfluoroalkyl substances, commonly known as PFAS, in food-contact packaging from 12 August 2026.

These substances can be used to provide resistance to grease, oil or moisture, making the restrictions particularly relevant to some papers, boards, wrappers, takeaway containers and other food-contact materials.

Manufacturers should ask suppliers to confirm whether relevant materials comply with the new limits and request supporting declarations or test results where appropriate.

Businesses should not assume that packaging described as paper-based, compostable or environmentally friendly is automatically free from restricted substances.

Prepare for future labelling requirements

The PPWR will introduce harmonised labelling intended to help consumers identify packaging materials and dispose of packaging correctly. Reusable packaging will also need to provide relevant information.

However, not every labelling obligation takes effect on 12 August 2026. Some technical formats, symbols and implementation details depend on further EU measures and later application dates.

Brands should monitor the timetable closely but avoid committing to major artwork changes before the relevant specifications have been confirmed. Where possible, planned redesigns should leave sufficient space and flexibility for future mandatory information.

Businesses should also remember that PPWR labelling will sit alongside existing food information, language, deposit-return and national requirements.

Understand Extended Producer Responsibility

UK businesses exporting packaged goods to the EU may also need to comply with Extended Producer Responsibility, or EPR, requirements in the countries where their products are sold.

Depending on the country and the business’s role in the supply chain, these systems may require a company to:

• Register with a national authority or approved scheme
• Report the types and weights of packaging placed on the market
• Supply information about packaging materials
• Pay packaging-related fees
• Appoint an authorised representative in the relevant country

Although the PPWR seeks to harmonise packaging requirements across the EU, EPR registration, administration, reporting and fees can still operate at national level. Compliance in one member state should not be assumed to cover sales in another.

Brands selling through distributors, online marketplaces or direct-to-consumer channels should establish who is responsible for registration, reporting and fees in every destination market.

Build packaging data into product development

PPWR compliance is unlikely to sit solely with a sustainability manager or packaging technologist. It may require input from product development, procurement, quality assurance, regulatory affairs, logistics, finance and sales.

Creating a central system for packaging data can help businesses retain evidence, monitor changes and provide information to customers, importers and EPR schemes.

For each new product, teams should ask:

• Is every packaging component necessary?
• Is the packaging likely to meet the applicable EU recyclability requirements?
• Will it need to contain a minimum proportion of recycled material?
• Do food-contact materials comply with the relevant substance restrictions?
• Can suppliers substantiate their claims?
• What information will eventually need to appear on the label?
• Who will manage EPR registration, reporting and fees?
• Could a reusable or refillable format be appropriate?

Building these questions into product development is likely to be more efficient than assessing compliance immediately before launch.

An action plan for food and drink brands

Businesses selling or planning to sell packaged products in the EU should:

• Map the EU countries in which their products are or will be placed on the market.
• Audit all primary, secondary and transport packaging.
• Request detailed composition and compliance information from packaging suppliers.
• Identify packaging that may present recyclability, recycled-content, minimisation or PFAS risks.
• Review product-development plans against the PPWR’s phased deadlines.
• Investigate EPR registration and reporting requirements in each destination country.
• Confirm responsibilities with importers, distributors, retailers and marketplace operators.
• Retain technical files, supplier declarations and supporting packaging data.
• Monitor further EU implementing measures and official guidance.
• Obtain specialist legal or regulatory advice where responsibilities remain unclear.

The move towards lighter, more recyclable and better-documented packaging will affect businesses throughout the food and drink supply chain. Acting early will give brands more time to test alternatives, negotiate with suppliers and incorporate changes into planned packaging updates.

The PPWR is complex, and its requirements will be phased in over several years. Businesses should consult the full text of Regulation (EU) 2025/40 while obtaining independent advice based on their products, packaging and target markets. Read guidance from the Food & Drink Federation, the UK government and the European Commission.  

This article provides general information and should not be treated as legal or compliance advice.