The regulation PPWR (Packaging and Packaging Waste Regulation) is a new European law applicable to companies placing all types of packaging on the market. Its aim is to increase the circularity of the economy.
As its applicability date approaches, the PPWR is starting to mobilize relevant stakeholders and raise questions among companies that haven't yet prepared. This article explains where this regulation comes from, how to know if it will impact you, and how to prepare for it.
What is the PPWR?
Where does PPWR come from?
The PPWR regulation is part of the European Green Deal, the EU's strategic plan for transforming its economy for a sustainable future, positioning Europe as a leading continent for sustainability.
To guide economic actors in their transformation, the EU has defined a legislative framework that is currently being implemented, which includes the CSRD, and now the PPWR, enacted in February 2025 and applicable from August 2026.
What are the main objectives of the PPWR regulation?
The main objective of the PPWR regulation is to reduce the quantities of packaging and packaging waste in Europe, and reduce the quantities of raw materials needed to boost the transition towards a circular and sustainable economy.
To achieve this, the PPWR has several intermediate objectives:
- Increase in recycled plastic for plastic packaging
- 100% recyclable packaging on the European market by 2030
- Reduction in the use of virgin materials in packaging.
Which companies are affected by PPWR?
The PPWR regulation does not define its scope at the company level, but at the packaging level. Specifically, all companies (B2B and B2C) placing packaging and packaging waste on the European market are affected by the PPWR.
However, certain sensitive packaging types are excluded from the scope: these include medical packaging, packaging for baby and child food, packaging for the transport of dangerous goods, and certain low-impact materials (light wood, textiles, rubber, ceramics, etc.).
How do I know if I am affected by PPWR? If you place packaged products on the market, you are affected by PPWR. However, your obligations vary depending on your position in the production chain, and more specifically on your "role" as defined by PPWR:
- Does your name or brand appear on the packaging? Have you defined specific specifications for the packaging? Then you have a Manufacturer role, and are responsible for the packaging's compliance with the rules defined by PPWR.
- Do you supply packaging for another company? Then you have a Supplier role, and must provide compliance information (technical description of the packaging) to your customers.
- Do you bring packaging into the EU from a third country without affixing your brand? Then you have an Importer role, and must collect compliance information from the supplier.
- Are you the last step before the consumer? Then you have a Distributor role, you simply need to ensure with your supplier that the packaging is compliant.
In all the preceding cases, you are considered a producer within the meaning of PPWR. This means: you are a producer if you are a manufacturer, supplier, importer, or distributor.
What are the PPWR requirements?
The PPWR regulation defines numerous objectives to be achieved, phased and progressive, both regarding the choice of materials and the design of packaging.
What are the PPWR obligations?
The PPWR has a phased implementation to achieve its overall targets by 2030.
As of August 12, 2026, manufacturers must possess the declarations of conformity for all their packaging. Furthermore, PFAS are prohibited in packaging in contact with food from this date.
As of February 2027, food retailers must allow customers to use their own containers and make this information visible.
As of August 2028, all packaging must use the harmonized PPWR labeling.
As of 2030, many requirements will apply:
- Recyclability : packaging must be classified (A, B, C, and +) according to its recyclability percentage. By 2030, only packaging with recyclability class A, B, or C will be allowed on the European market.
- Recycled content : by 2030, all plastic packaging must contain a percentage of recycled content. Minimum percentages are defined based on the type of plastic and the packaging's function.
- Minimization : manufacturers and importers must prove from 2030 that packaging is designed to minimize its weight and volume, supported by a technical file.
After 2030, the criteria for requirements will increase year after year.
What is the link between PPWR and EPR for Professional Packaging?
In France, the regulation PPWR echoes the Extended Producer Responsibility (EPR), which requires companies to pay an eco-tax to manage the end-of-life of products and packaging placed on the market.
Although both aim to boost the circularity of the economy, the two regulations are quite different in their content : EPR schemes impose a tax on companies to encourage them to reduce the volume of products and packaging, while PPWR directly imposes circularity requirements on packaging.
The two regulations align on the definitions of "roles": the "producers" under EPR are the same producers as under PPWR. In fact, if you are a producer of professional or household packaging under PPWR, there's a high chance you are also a producer under EPR schemes and will have to pay the corresponding tax.
How to comply with PPWR?
With implementation starting in August 2026, it's high time to prepare for the arrival of PPWR. To do so, you can follow these 3 steps:
- Identify your roles under PPWR
- Prepare compliance documents
- Collect information from your suppliers
Step 1: Identify your roles under PPWR
To understand your obligations, you need to know your role(s) under PPWR. Depending on the packaging you use for your products, you may hold multiple roles. To determine if you are a manufacturer, importer, or distributor, you can use the decision tree in Part 1 of this article.
Your PPWR role and obligations depend not only on your position in the production chain but also on the types of packaging. The 3 types of PPWR packaging are:
- sales packaging, serving as a unit at the point of sale
- grouped packaging, used to group sales units for logistics
- transport packaging, such as pallets and stretch film.
Step 2: Prepare the documents of compliance
If you have a manufacturer role for some of your packaging, you must produce a document of compliance proving that your packaging meets the PPWR requirements for PFAS, recyclability, and recycled content.
This document, whose format is outlined in Annex VII of the PPWR regulation, must be stored for a minimum of 5 years to be shared upon request by your customers or competent authorities.
If your packaging does not comply with PPWR, you must work on its entire lifecycle from design to remedy this and keep it on the market.
Step 3: Collect information from your suppliers
Finally, if you are an importer or distributor, you must ensure that the packaging used is compliant: it is your responsibility to collect compliance documents from your suppliers.
You must store these documents for 5 years and be able to present them upon request.
Conclusion
The PPWR regulation is not a disruption but rather a natural continuation towards an increasingly sustainable and circular economy. Rooted in the European Green Deal, its objectives are ambitious but made accessible through year-by-year milestones.
Companies can prepare by identifying their packaging and their role in the production chain, and by rethinking their packaging from the design stage today.
Sources
https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
https://eur-lex.europa.eu/legal-content/FR/TXT/HTML/?uri=OJ:L_202500040
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FAQs
Find answers to common questions about CSRD and Kiosk
The CSRD or Corporate Sustainability Reporting Directive is the new European directive which aims to impose and better regulate corporate sustainability reports.
It makes companies more transparent, with standardized ESG reporting standards called ESRS (European Sustainability Reporting Standards)
The application of the Corporate Sustainability Reporting Directive is progressive. Here is a summary table.
| Effective year | Businesses impacted | Standard |
|---|---|---|
| 2025 (over the financial year 2024) | Listed companies with more than 500 employees | ESRS |
| 2026 (sur l’exercice 2025) | Autres grandes entreprises de plus de 1000 salariés | ESRS |
| 2026 (over the financial year 2025) | Businesses that meet two out of three criteria: | VSME |
| 2027 (over the year 2026) | SMEs listed on the stock exchange | VSME |
| 2029 (over the fiscal year 2028) | Non-European companies with at least €150M in turnover on the European market | ESRS |
Want to know when your business is impacted? Use our regulatory monitoring tool to find out.
The "omnibus" bill is a recent initiative by the European Commission aimed at reducing the scope of the CSRD directive. It proposes, in particular, to raise the application thresholds: only companies with more than 1,000 employees would be affected, compared to 250 previously.
It promotes the adoption of the VSME framework to reduce the reporting burden on SMEs and mid-cap companies.
The VSME (Voluntary Sustainability Reporting Standard) is a voluntary European standard designed to help unlisted small and medium-sized enterprises (SMEs) structure and communicate their sustainability initiatives. Developed by EFRAG, this standard offers a lighter framework compared to ESRS standards, covering ESG aspects. It allows in particular to:
- Harmonizing sustainable reporting practices in Europe
- Facilitate the response to the expectations of business partners
- Improving access to responsible financing
It aims to harmonize sustainable reporting practices, facilitate meeting the expectations of business partners, and improve access to responsible financing. Although not mandatory, adopting VSME allows SMEs to demonstrate their commitment to sustainability and anticipate future regulatory developments.
- Complete the preliminary steps for the CSRD
These steps are dual materiality analysis and gap analysis. They will help you understand the material issues, impacts, risks, and opportunities for your business. They will also allow you to create a roadmap based on what you have already achieved.
Check out our article on double materiality here.
- Compile your data and produce your indicators
Centralizing sustainability data is essential for your compliance, particularly to facilitate understanding and consistency when producing quantitative indicators.
- Produce your detailed report in XHTML format with XBRL tags
Thanks to its tagging and visualization technologies, Kiosk guarantees a very high level of consistency.
Find our article on XBRL tagging here .
- Audit your data
At the end of these steps, your sustainability report is ready to be audited by an Independent Third Party Organization (ITO).
Kiosk supports your compliance journey throughout this process. For more information on these steps, we invite you to contact our team.
CSRD compliance requires companies to:
- understanding the 12 ESRS and 82 disclosure requirements
- the collection of more than 1,000 data points
- the calculation of 50-147 quantitative indicators
- tagging 4,000 items in the final report
Kiosk is a software that allows companies to save 5 months on the preparation of their CSRD report by automating the most time-consuming steps.
- First of all, the security of your data is our priority.
- All data is stored in France, in Paris, via our French hosting provider.
- During transit, your data is encrypted in SSL/TLS from the user's browser to our servers guaranteeing the security of communications.
- Data is also encrypted at rest, both on the database and on file storage, protecting the data in the event of a leak or attempted theft.
- Kiosk's technical teams are the only ones who can access your data.
- Kiosk is in the process of ISO27001 certification.
- Our technical support is available 24/7.