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The new Packaging and Packaging Waste Regulation (PPWR): in force from 12 August 2026

​​​​​​​​​​From 12 August 2026, an entirely new and directly applicable European regime for packaging and packaging waste takes effect, setting one rulebook for every Member State of the European Union. It is Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste, better known by its initials, PPWR (Packaging and Packaging Waste Regulation) (the “PPWR”). 


What the PPWR brings​

The PPWR sets new requirements for packaging and packaging waste, focused above all on environmental sustainability and labelling. Those requirements run across the entire life cycle of packaging, and meeting them is a precondition for placing packaging on the market. The Regulation builds on three further pillars: extended producer responsibility; the prevention of packaging waste, including cutting unnecessary packaging and enabling reuse and refill; and the collection and treatment of packaging waste, recycling included.

The aim is to make the internal market work better. By harmonising national rules on packaging and packaging waste, the PPWR removes barriers to trade and prevents competition from being distorted or restricted across the Union. It does so while securing a high level of environmental protection and heading off the harm that packaging and packaging waste can cause to the environment and to human health.

In practical terms, the PPWR is a genuine watershed, for two reasons above all. It defines packaging far more broadly than before, and it draws a wide range of economic operators into responsibility for the packaging life cycle.

The reach is deliberately wide. The PPWR applies to all packaging, whatever the material, and whether it is used in industry, other manufacturing, retail, distribution, offices, services or households. It applies, too, to all packaging waste, whatever its source.
 

Obligations phase in over time

One point deserves emphasis. Although the PPWR becomes applicable on 12 August 2026, many obligations will arrive in stages, and chiefly after 1 January 2028. The reason is straightforward: much of the detail behind the packaging and packaging-waste requirements depends on European Commission implementing acts, which will be adopted step by step.   


Compliance under PPWR 

For every economic operator with a hand in the packaging life cycle, the pivotal compliance rule is Article 4(1) of the PPWR: packaging may be placed on the market only if it complies with the Regulation.

From that single baseline flow not only the individual packaging requirements, but, above all, the specific duties that attach to placing packaging on the EU market and to the later stages of its life cycle.



Packaging and packaging waste, redefined

As noted, one of the most consequential changes the new EU “packaging law” brings is a fresh, deliberately broad definition of “packaging.” Packaging now means any item, whatever the materials it is made from, that an economic operator uses to contain, protect, deliver or present products to another economic operator or to the end user, or to handle products, and that can be classified by packaging format according to its function, material and design.

The PPWR then layers further “special” categories on top, among them primary production packaging, sales packaging and transport packaging.

The companion concept, “packaging waste,” is drawn just as broadly: any packaging or packaging material that is waste, save for production residues


Who is caught: economic operators and their PPWR duties

A further point of real significance is just how wide the circle of obligated parties is, and this follows directly from how the PPWR defines and positions economic operators.

Under the PPWR, an economic operator is not only a producer but also a supplier, an importer, a distributor, an authorised representative, a final distributor or a fulfilment service provider.

What each party must do turns primarily on which category it falls into, which in turn depends on its place and role in the distribution or value chain. The heaviest load of obligations falls, unsurprisingly, on the “producer”: under the broad definition, any natural or legal person that manufactures packaging or a packaged product, subject to certain exceptions.

With the clock now running, the practical question for every business is a simple one: which role do you occupy, and what does it require of you?

Join our dedicated RÖDL webinar on the PPWR, on 17 June 2026

Want to know what the PPWR means for your business in concrete terms? Join our dedicated webinar on 17 June 2026, where we will take you through it step by step. For tailored guidance, our team is ready to advise you directly. Talk to us, and let us map the way forward together.


Kontakt

Contact Person Picture

JUDr. Pavel Koukal

Attorney at Law (Czechia)

Associate Partner

+420 236 163 710

Send inquiry

Contact Person Picture

JUDr. Michal Gola, LL.M.

Attorney at Law (Czechia)

Senior Associate

+420 236 163 257

Send inquiry

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