The important point is that 12 August marked the start of the new regulatory framework, not the date on which every future target arrived at once. Some detailed requirements and performance targets are phased in later, while further technical rules will continue to be developed. Exporters should therefore avoid two opposite mistakes: assuming nothing changes until 2030, or treating every long-term target as an immediate legal obligation.
What the regulation covers
The Packaging and Packaging Waste Regulation, usually shortened to PPWR, replaces the previous EU Packaging and Packaging Waste Directive. It covers all packaging placed on the EU market, including the primary packaging that touches or contains a product, the secondary packaging used to group products, and the transport packaging used during storage and distribution.
For a food exporter, that can include bottles, jars, trays, films, cartons, sleeves, labels, closures, cases, pallets and protective materials. It also means that a product cannot be reviewed in isolation from the way it is packed for transport or presented for sale.
The regulation is intended to reduce packaging waste, improve recyclability and increase the use of recycled materials. It also introduces a more harmonised framework across EU member states. That should eventually reduce some national variation, although exporters will still need to manage local extended producer responsibility registrations and reporting requirements.
Why UK businesses are affected
A UK business may be outside the EU, but its packaging still enters the EU market when it exports products there. The practical responsibility may sit with the exporter, importer, distributor, authorised representative or another economic operator, depending on the supply arrangement and the way the product is placed on the market.
This makes contractual clarity essential. A business should not assume that its EU customer is handling every packaging obligation. The commercial agreement should identify who is responsible for registration, declarations, technical documentation, labelling, data submission and any producer responsibility payments.
Start with a complete packaging audit
The most useful first step is to create a packaging inventory for every product sold into the EU. This should cover each packaging component, not merely the outer carton or consumer pack.
For each item, record the material, weight, supplier, function, food-contact status, recycled content where known, and whether the component can be separated by the user. The audit should also distinguish between packaging used for the product itself and packaging used only for transport.
This exercise can expose gaps that are otherwise easy to miss. A bottle may be recyclable, while its sleeve, cap or adhesive creates a problem. A carton may contain an unnecessary insert. A transport format may vary between customers without being documented consistently.
Do not rely on packaging appearance alone. A material can look simple while having a coating, laminate or barrier layer that affects recyclability. Supplier declarations and technical specifications should support the record.
Recyclability and packaging reduction
The PPWR introduces design-for-recycling requirements and a future recyclability performance framework. The detailed scoring and deadlines develop over time, but the direction is clear: packaging that cannot be effectively collected, sorted and recycled will face increasing commercial and regulatory pressure.
Food businesses have a particular challenge because packaging also needs to protect safety, shelf life and product quality. Removing material without understanding the product can increase damage or food waste, which would undermine the environmental purpose of the change.
A sensible review therefore asks whether packaging is necessary, whether the same function can be achieved with less material, whether complex combinations can be simplified, and whether components can be separated more easily. Any redesign should still be validated for food contact, seal integrity, transport performance and shelf life.
Recycled content and supplier evidence
The regulation introduces recycled-content requirements for certain plastic packaging, with targets applying in future stages. Even where a target is not yet due, businesses should begin asking suppliers what evidence they can provide.
A packaging specification should identify the material composition, recycled content, source of data, test or certification method, and any limitations caused by food-contact rules. Statements such as “fully recyclable” or “contains recycled plastic” should not be used without evidence that supports the exact packaging format and market.
Long supplier lead times make early engagement important. A change to resin, film, adhesive, ink or barrier material may require technical trials, migration testing, line testing and customer approval before it can be introduced safely.
Labelling and consumer information
The PPWR creates new harmonised labelling requirements, but detailed formats and implementation dates are subject to supporting EU rules. Businesses should avoid redesigning every label based on an incomplete interpretation.
The correct approach is to maintain a regulatory watch, obtain advice for the relevant market and keep enough packaging flexibility to introduce the required information when the specifications are settled. This is especially important for multilingual labels and small packs, where space is already limited.
Packaging claims also need care. Environmental statements should be specific, supportable and not likely to mislead. The fact that one component is recyclable does not necessarily mean the whole pack can be described in the same way.
Extended producer responsibility in each market
The regulation provides an EU-wide framework, but producer registration and reporting can still involve national systems. A business selling into several EU countries may need to identify the relevant scheme in each market, appoint a representative where required and submit packaging data in the correct format.
The information required for these systems often depends on packaging weight and material. That is another reason to build a reliable component-level inventory rather than estimating totals at the end of the year.
Finance and commercial teams should also understand the potential cost. Packaging choices can affect producer responsibility fees, redesign costs, supplier contracts and product margins. Compliance should therefore be included in commercial planning rather than left solely with technical or sustainability teams.
What UK exporters should do now
UK food and drink exporters should now confirm which products and markets are affected, identify the responsible economic operator and complete a packaging audit. Supplier evidence should be collected in a consistent format, and gaps in material composition, weight or recycled-content data should be resolved.
Businesses should also review contracts with importers and distributors, check national producer responsibility obligations, and establish an internal owner for ongoing regulatory updates. Packaging changes should be prioritised by risk, volume, redesign lead time and commercial importance.
The objective is not to redesign everything immediately. It is to know what packaging is in use, what evidence exists, where the main risks sit and who is responsible for each action.
A practical transition rather than a last-minute reaction
The PPWR will affect packaging decisions for years rather than weeks. Businesses that treat it as a single August deadline may either do too little or spend money on changes that are not yet required.
A controlled approach is more effective: map the packaging, verify supplier data, confirm responsibilities, monitor the supporting rules and test changes before they reach production. For food and drink exporters, that creates a route to compliance without losing sight of product safety, shelf life, customer requirements and cost.
This article provides general information and does not constitute legal advice. Businesses should obtain specialist advice for their products, packaging formats and EU markets.
REFERENCES
1. European Union. Regulation (EU) 2025/40 on packaging and packaging waste. https://eur-lex.europa.eu/eli/reg/2025/40/oj
2. European Commission. Commission notice on the application of Regulation (EU) 2025/40. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026XC03084
3. UK Department for Business and Trade. EU Packaging and Packaging Waste Regulation. https://www.business.gov.uk/campaign/europe/european-union-eu-regulations/eu-packaging-and-packaging-waste-regulation-eu-ppwr/
4. GOV.UK. Food labelling and packaging. https://www.gov.uk/food-labelling-and-packaging
