UK exporters face final countdown before strict EU packaging rules apply

While the new EU regulation on packaging and packaging waste (PPWR) entered into force in February 2025, compliance obligations do not take effect until 12 August 2026, following which sustainability and waste prevention rules will be tightened across the bloc’s member states.

For packaging producers that operate in both the UK and EU markets, or export from the UK into the EU, a clear understanding of the differences between the UK’s extended producer responsibility for packaging (pEPR) regime and the PPWR in the EU is fundamental.

What the new rules include

The new regulation replaces the previous PPWR Directive and applies unified, mandatory rules across all the EU member states. Oversight for registration, reporting and fees remain with each state’s national regulators or appointed administrators.

The aim of the PPWR is to create a harmonised approach to packaging across all EU member states as part of a drive to make all packaging across the EU recyclable in an economically viable way by the start of the next decade.

The PPWR harmonises requirements in relation to the environmental sustainability and labelling of packaging for its entire life cycle for items entering the European market. It also extends producer responsibility for packaging to producers, shifting the burden of managing packaging waste back to them.

The PPWR also introduces a ban on using polyfluoroalkyl substances – PFAS, sometimes known as forever chemicals - above certain thresholds in packaging which come into contact with food; imposes requirements to ensure packaging can be collected, sorted and recycled; and establishes refill and reuse targets for packaging across Europe.

Packaging must therefore pass new European design test criteria and labelling requirements for PPWR before products can be sold on the EU market.

Once packaging has entered the EU market, the extended producer responsibility for packaging (pEPR) regime kicks in as the system covering the cost of collecting and recycling the waste material. The PPWR expands and strengthens the existing pEPR; for example, eco-modulation criteria will need to be implemented by all EU member states by 2030. Eco-modulation being a mechanism within pEPR that adjusts the fees paid by producers based on the recyclability and environmental impact of their packaging.

Key deadline date

The key upcoming deadline for UK exporters to the EU market is 12 August 2026. Once that deadline has passed, every unique packaging type placed on the EU market will need a signed Declaration of Conformity, backed by technical documentation. Products without one will not be legally allowed onto the EU market.

Companies should however note that the 12 August 2026 requirements are not the only obligations contained in the PPWR. Other requirements will come into force progressively between 2026 and 2030 and in some cases up to 2040.

What does this mean for UK producers?

Compliance with the PPWR is a precondition for packaging to be placed on the EU market, regardless of where the product or packaging was manufactured. This means companies based in the UK and either operating in the EU or exporting to Europe risk having goods being rejected at EU borders if packaging is non-compliant.

There are differences between how the UK and EU regimes operate, so material that would be legal under the UK’s packaging requirements may not meet the requirements of the PPWR. Companies and manufacturers must be aware and prepared now if they want to continue with smooth exports to EU markets.

Companies should also consider how the PPWR will apply in Northern Ireland, where most of the new regime is being implemented under the Windsor Agreement.

There are some minor rule relaxations and exemptions around reuse requirements for smaller companies defined as microenterprises under the EU rules, which should also be taken note of.

What should UK companies do now?

To mitigate non-compliance risks, firms who produce, supply, manufacture, import or distribute packaging on the EU market - including products in packaging - should conduct a packaging inventory audit to map their products and supply chains. Thereafter, it will be necessary to consider these products and supply chains against the requirements of the PPWR and pEPR to determine what their obligations are under the different regimes.

Manufacturers should stress-test their current packaging specifications against the new labelling, recyclability, recycled content and minimisation thresholds set out in the PPWR, and compliance teams should use the time before the 12 August deadline to verify their technical documentation and align their reporting with European Commission guidance.

The PPWR regime is a transformative overhaul of packaging supply chains, and compliance is a requirement for European market access. Transitioning to suitable, recyclable design is no longer a corporate social responsibility target, but a compliance requirement.