The new regulation entered into force on 11 February 2025, and most of it has applied since 12 August 2026. Its scope is wide: packaging placed on the EU market and packaging waste from industry, commerce and households.
PPWR extends far beyond companies that manufacture or supply empty packaging. It also applies to the packaging accompanying products placed on the EU market, bringing a wide range of businesses within its scope.
This means packaging is no longer just a logistics or purchasing topic. It is becoming part of product compliance, supplier data and supply-chain governance.
What changes under PPWR?
The goals of PPWR are simple to state. It aims to:
reduce packaging waste;
make packaging easier to recycle;
support a more circular use of materials; and
create more consistent packaging rules across the EU.
To achieve these objectives, PPWR introduces a broad set of requirements that touch almost every aspect of packaging.
These range from packaging minimisation and recyclability to recycled content, substances of concern, reuse and refill systems, labelling, technical documentation, conformity assessment, and extended producer responsibility.
As a result, businesses should look beyond the simple question of whether they are PPWR compliant. A more practical and strategic question is:
“Which requirements apply to this packaging, to our role in the supply chain, and at this point in time?”
Who is responsible?
PPWR splits responsibilities across the supply chain.
The manufacturer has the main responsibility for compliance, including the conformity assessment, technical documentation and EU declaration of conformity. Packaging and material suppliers must give the manufacturer the information and documents needed to show compliance.
For goods or packaging from outside the EU, the importer must check that the manufacturer has done the conformity assessment and prepared the technical documentation. Distributors must act with due care before making packaging available on the market.
The producer for extended producer responsibility (EPR) is a separate role and is not always the manufacturer. Depending on the supply chain and the Member State, it could be an importer, distributor, distance seller or another business.
Roles can also shift. An importer or distributor that sells packaging under its own name or brand, or changes it in a way that may affect compliance, may be treated as the manufacturer. Private-label products, repacking and rebranding therefore need extra attention.
Key dates businesses should understand
PPWR does not introduce a single deadline. Instead, its requirements are being phased in over time, with some obligations only taking effect once additional EU implementing or delegated acts have been adopted.
12 August 2026: Most of PPWR started to apply, including the restrictions on PFAS in food-contact packaging.
12 August 2028 (at the earliest): Harmonised packaging labelling rules apply from this date, or 24 months after the relevant implementing acts, whichever is later.
From 2030: Bigger changes arrive, including design-for-recycling requirements, minimum recycled content for certain plastic packaging, restrictions on some packaging formats, empty-space limits for grouped, transport and e-commerce packaging, and re-use obligations.
From 2035: Packaging will also need to be recycled at scale in practice.
From 2040: Higher recycled-content and re-use targets apply.
The message is clear: waiting until 2030 is not an option. Building a solid understanding of your packaging, responsibilities, supplier data and supporting documentation takes time, and businesses should begin that process now.
The real PPWR challenge: Data
For many businesses, the hardest part of PPWR will not be understanding the rules. It will be getting reliable data about their packaging.
Customs and product master data usually focus on the imported product itself: tariff classification, origin, customs value, quantity and weight. PPWR asks businesses to look at the packaging as well.
Depending on the packaging and the requirement, companies may need to know:
what the packaging is made of;
how much it weighs;
the share of plastic and recycled content;
any coatings or barrier layers;
whether it is single-use or reusable;
who made it; and
which business is responsible for its compliance.
This is especially difficult for packaged goods. A customs declaration may classify an electronic device, a machine, a food product or a piece of clothing. But that classification usually tells you very little about the cardboard, plastic film, foam, pallets or other packaging that comes with the goods.
This is why you cannot reliably judge PPWR exposure from a CN code alone.
For businesses with thousands of SKUs and suppliers, this quickly turns into a product master data and supplier management task.
Documents matter just as much. A general statement from a supplier saying that packaging is "sustainable", "recyclable", "PFAS-free" or "PPWR compliant" may not be enough. Businesses need to be able to link the right evidence to the actual packaging they place on the market.
The role of ALS Customs Services
PPWR is not customs law, and the two should not be confused.
As a customs broker, ALS does not assume the role of manufacturer, importer, distributor or producer responsible for PPWR compliance simply because it prepares or submits a customs declaration.
Our role is to support the business that holds responsibility. Working closely with packaging compliance specialists such as Dubrink, we help clients identify the relevant import flows, determine which packaging is affected and who is responsible for it, and spot data or documentation gaps before the goods arrive.
By combining ALS's customs expertise with Dubrink's specialist knowledge of packaging compliance, we provide clients with more comprehensive and practical support as they prepare for PPWR requirements.
Where businesses should focus first
Preparing for PPWR is not just about understanding the regulation. It is about understanding your packaging, your role in the supply chain, the data needed to assess compliance, and the documentation required to support it.
Five practical steps to get started:
Map packaging flows – both packaging imported as a product and packaging that comes with imported goods.
Determine responsibilities – who acts as manufacturer, importer, distributor and EPR producer.
Build a packaging inventory – list packaging types, materials and components.
Identify data and documentation gaps – check what supplier information is missing and link it to the right packaging.
Integrate PPWR into existing processes – connect it with procurement, supplier onboarding, master data, logistics, customs and compliance.
From packaging compliance to supply-chain governance
PPWR is another example of the wider EU regulatory shift towards greater product traceability, technical evidence and supply-chain accountability.
Over the coming months, ALS Customs Services and Dubrink will share practical insights and guidance focusing on topics such as data collection, supplier documentation, importer responsibilities, and the operational impact of the new requirements.
Follow our LinkedIn page for future insights, and practical guidance.