The Packaging and Packaging Waste Regulation (PPWR) is one of the most significant pieces of packaging legislation introduced by the European Union in recent years.

From 12 August 2026, new requirements will begin to apply to packaging placed on the EU and EU associated market countries, with further measures being introduced gradually through to 2040 and beyond . For businesses selling products into Europe, understanding these changes and preparing early will be essential.

What is PPWR?

PPWR (Regulation (EU) 2025/40) aims to reduce packaging waste across Europe by creating harmonised rules around packaging design, sustainability, labelling, recyclability and recycled content requirements.

The regulation has been introduced to:

• Reduce unnecessary packaging
• Improve recyclability and recycling rates
• Increase the use of recycled materials
• Standardise packaging requirements across EU member states
• Support the transition towards a more circular economy

Unlike previous directives, PPWR is a regulation, meaning its requirements apply directly across all EU member states, creating greater consistency for businesses trading across borders.

What Happens on 12 August 2026?

From 12 August 2026, manufacturers placing packaging on the EU market will need to undertake the applicable conformity assessment, prepare the required technical documentation and, where conformity has been demonstrated, draw up an EU declaration of conformity in accordance with Article 39

However, it is important to note that many of the detailed technical requirements relating to recyclability criteria, harmonised labelling and recycled content methodologies are still being developed by the European Commission and are expected to be clarified over the coming years.

This means that while the direction of travel is clear, some aspects of compliance will continue to evolve between now and 240 and beyond.

Who will be Responsible for PPWR Compliance?

One of the biggest questions surrounding PPWR is: who is responsible?

In most cases, responsibility for ensuring compliance will sit with the economic operator placing the packaged product on the EU market. This is typically the brand owner, packer/filler, importer or distributor, depending on the supply chain structure.

As a packaging supplier, Origin’s role is to support our customers by providing relevant product information and documentation where applicable. However, the final responsibility for assessing compliance of the finished packaging configuration will remain with the organisation placing that packaging onto the market.

This is because compliance assessments are expected to require knowledge of:

• The final packaging format
• Product contents
• Labelling and artwork
• Combined packaging components
• Intended end use and market

These factors can only be fully assessed once the final packaged product is known.

How Could PPWR Affect Your Business?

The impact will vary depending on your products and the markets you sell into. Here are the anticipated effects:

• Increased Documentation Requirements: Businesses may increasingly request technical information and supporting documentation from their packaging suppliers to assist with their own compliance assessments.
• Packaging Design Reviews: Businesses may need to review packaging specifications to ensure they align with future requirements around recyclability, minimisation and recycled content targets.
• Future Recyclability and PCR Requirements: Certain packaging categories, particularly plastic packaging, are expected to face increasing requirements around recyclability performance and minimum levels of post-consumer recycled (PCR) content from 2030 onwards.
• PFAS and Material Requirements: From 12 August 2026, initial focus areas are expected to include requirements relating to certain substances, including PFAS restrictions and heavy metal limits.

What About Pharmaceutical Packaging?

The regulation recognises the particular safety, quality and efficacy requirements associated with pharmaceutical packaging.

Specific derogations from certain recyclability and recycled-content requirements apply to immediate packaging of medicinal products. Certain outer packaging may also benefit from a derogation where it is necessary to comply with requirements intended to preserve the quality of the medicinal product.

Other pharmaceutical, secondary and transport packaging will generally remain subject to the wider PPWR requirements unless a specific derogation applies.

How Origin Can Support You

At Origin, we are actively monitoring PPWR developments and working closely with our supply chain partners to understand evolving requirements.

From 12 August 2026, we will be able to start providing supporting product information and documentation, where applicable, to help our customers with their own internal assessments and compliance activities.

This may include information relating to:

• Product specifications and intended use
• Material composition data where available
• Relevant compliance statements and supporting documentation
• Information received from our manufacturing partners

As guidance and secondary legislation continue to develop, we will continue to review our processes and communicate relevant updates to our customers.

Preparing for the Future

Although some technical details are still being finalised, businesses selling into the EU should begin considering:

• Which products are placed on the EU market
• Whether internal compliance responsibilities are clearly defined
• What information may be required from packaging suppliers
• Future packaging design and sustainability objectives

Early engagement can help reduce future disruption and ensure your packaging strategy remains aligned with upcoming regulatory requirements.

Need More Information?

As PPWR requirements continue to develop, businesses may wish to refer to official sources and seek independent advice where necessary. Useful resources may include:

• European Commission – Packaging and Packaging Waste: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
• EUR-Lex – Regulation (EU) 2025/40: https://eur-lex.europa.eu/
• EUROPEN: https://www.europen-packaging.eu/
• European Plastics Converters (EuPC): https://www.plasticsconverters.eu/

If you have questions regarding packaging supplied by Origin and require supporting documentation relating to PPWR, please speak to your Account Manager or contact our Quality Team at origin-qa@originltd.com.

Disclaimer: This information is based on our understanding of PPWR at the time of publication and may change as further guidance and legislation are introduced. Origin will continue to monitor developments and update this information where appropriate. While we are happy to support customers with available documentation and information, responsibility for determining applicability and ensuring compliance with PPWR ultimately remains with the organisation placing the packaged product on the EU market.