The New EU Packaging Regulation (PPWR), Effective August 2026

A Guide to Retail and E-Commerce

Retailers will soon have to adapt to new regulations: On August 12, 2026, the new EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, or PPWR for short) will take effect. It replaces the previous Packaging Directive 94/62/EC and, as a regulation, applies directly in all 27 EU member states without the need for national adaptations. For retailers—whether brick-and-mortar, online, or Fulfillment customers—this will bring about significant changes. To shed some light on this admittedly extensive and convoluted regulation, we’ll address the most important points in this article.

As a retailer, am I even affected?

The PPWR distinguishes between several roles with different responsibilities throughout the supply chain.

Note: You can fulfill multiple roles at the same time. An online retailer who has products packaged under their own brand and sells them directly to end customers is simultaneously a producer, manufacturer, and end distributor.

When do I, as a retailer, become a “producer” myself?

This is one of the points that most often leads to confusion. According to Article 21 of the PPWR:

If, as a distributor or importer, you place packaging on the market under your own name or brand, or modify packaging that has already been placed on the market in a way that could affect its conformity, you are legally considered a manufacturer —with all the associated obligations (see Section 4).

Explained: As soon as you sell white-label products under your own name, assemble, repackage, or apply your own branding to the packaging, you assume full manufacturer liability—not just the limited obligations of a distributor.

Special Case for Microenterprises: If the person who has the packaging developed or manufactured under their own brand is a microenterprise (as defined in Recommendation 2003/361/EC, as of February 11, 2025), and the packaging supplier is established in the same Member State, the supplier is instead considered the producer (Art. 3(1)(13)(b) and Art. 15(12)).

As a retailer, what do I need to check?

Under Article 19 of the PPWR, as a distributor, you must exercise due diligence to ensure the following before placing packaging on the market:

1. Check registration: Is the responsible manufacturer listed in the national manufacturer registry (Art. 44)?
2. Check labeling: Is the packaging labeled in accordance with Article 12?
3. Check the manufacturer’s information: Have the producer and importer provided the required information (name, address, contact information)?

If there is any doubt: You must not provide the packaging until compliance has been established.

Additional responsibilities:

• Storage and transport conditions must not affect conformity.
• You may use information disclosed by the manufacturer solely for compliance verification purposes.
• If there is reasonable suspicion of nonconformity, you must immediately take corrective action and notify the market surveillance authority (Art. 19, para. 5).
• Upon a reasonable request from a government agency, you must submit all relevant documents.
• You must be able to provide proof, for a period of five years (single-use packaging) or ten years (reusable packaging), of who you purchased the packaging from and to whom you delivered it (Art. 22 – Traceability).

Mandatory Disclosure: Who Must Provide What Contact Information, and Where?

This primarily applies to the manufacturer and the importer— not necessarily the packaging manufacturer in the technical sense, but rather the party that develops or has the packaging or the packaged product manufactured under its own name.

Mandatory as of August 12, 2026:

• A model, lot, or serial number to identify the package (or, alternatively, this information may be included in the accompanying documentation if space does not permit).
• Name, registered trade name, or registered trademark; mailing address; and, if applicable, electronic contact information—either directly on the packaging, via a QR code or data carrier, or in accompanying documentation. The mailing address must specify a central, accessible point of contact.

Starting in 2028, no earlier than August 12, 2028, additional harmonized pictogram labeling indicating material composition in accordance with Article 12 will be introduced to make waste sorting easier for consumers. The goal is also to make waste sorting easier for people who cannot read.

For you as a distributor, this means: Check with all your suppliers to see if this information is already available, because otherwise you will no longer be allowed to simply offer the goods as of August 12, 2026.

Registration Requirements and Extended Producer Responsibility (EPR)

If you are considered a “manufacturer” as defined by the regulation (see definition above—this applies, for example, to many private-label and direct-sales retailers), you must register:

• You are required to register in every Member State where you place packaging or packaged products on the market.
• You may not provide any packaging without registering.
• Annual reporting requirement for packaging volumes by June 1 for the preceding calendar year.
• Threshold for minor cases: Simplified reporting requirements apply for quantities of packaging material totaling less than 10 metric tons per year.

In addition, as a manufacturer, you are subject to extended producer responsibility (EPR) under Article 45. You pay fees that cover, among other things, the costs of labeling waste containers and conducting composition surveys. You may fulfill these obligations on your own or delegate them to an authorized producer responsibility organization (Art. 46) to avoid being overwhelmed by red tape.

Important for online marketplaces and Fulfillment: If you offer packaging or packaged products to consumers in the EU via an online marketplace, you must provide the marketplace operator with your registration number and a self-certification of EPR compliance (Art. 45(4)). If you use a fulfillment service provider, the same obligation to provide information applies to that provider. If you fail to comply, the fulfillment service provider must suspend its services for you.

Unnecessary Packaging: The Empty Space Ratio

Effective January 1, 2030 (or 3 years after the relevant implementing act enters into force, whichever is later) , a maximum void space ratio of 50% will apply to retail, transport, and e-commerce packaging . This applies to everyone who fills such packaging, particularly online retailers and Fulfillment providers.

Starting February 12, 2028, a stricter requirement will apply to sales packaging: Empty space must be limited to the minimum necessary for product protection and functionality. There is no more specific requirement.

Filler material such as air cushions, foam, or paper padding also counts as empty space. Exceptions include outer packaging made entirely of cardboard and reusable packaging within a reuse system.

Prohibited Packaging Formats Starting in 2030

As of January 1, 2030, certain single-use plastic packaging may no longer be placed on the market.

• Single-use plastic outer packaging for bundling bottles, cans, etc., at the point of sale (e.g., shrink wrap), unless absolutely necessary for handling.
• Single-use plastic packaging for unprocessed fruits and vegetables weighing less than 1.5 kg (nets, bags, trays), with exceptions, such as for organic produce, to prevent cross-contamination.
• Single-use plastic packaging for food and beverages consumed on-site in the hospitality industry (trays, cups, disposable plates). This also applies to outdoor areas with tables and chairs.
• Single-use, single-serving packages for condiments, spreads, coffee creamer, sugar, etc., in the hospitality industry —except for takeout intended for immediate consumption or for medical hygiene purposes.
• Single-use cosmetic and hygiene product packaging in the lodging industry (shampoo bottles, etc.), provided they are intended for use during a single stay.
• Very lightweight plastic carrier bags (less than 15 microns), except for loose food items for hygiene reasons.

Reuse and Refill

This section contains most of the detailed regulations. If you use packaging in this category, we recommend that you read this part of the law thoroughly. Here is an overview of the obligations relevant to retailers, effective January 1, 2030:

Beverages for Sale: Retailers that offer alcoholic and non-alcoholic beverages in retail packaging to end customers/consumers must make at least 10% of these products available in reusable packaging within a reuse system (starting in 2040: at least 40%, as a best-efforts requirement).

Exceptions to this quota: highly perishable beverages, milk and milk products, certain wine products, flavored wine products, and spirits.

Exemptions:

• Retail space ≤ 100 m² in the respective calendar year,
• Located on an island with fewer than 2,000 residents,
• Located in a municipality with fewer than 54 inhabitants per square kilometer (except in settlements with more than 5,000 inhabitants).

Obligation to Accept Returns: If you meet this quota, you must accept all reusable packaging of the same type, shape, and size free of charge at the point of delivery (or in the immediate vicinity) and refund the deposit.

Pooling is permitted: Member States may allow up to 5 end distributors (with a maximum market share of 40% in the beverage category) to form a pool to achieve their targets jointly.

Transport and outer packaging (Art. 29, paras. 1–5): Companies that use pallets, crates, plastic containers, barrels, etc., must ensure that at least 40% of them are reusable starting in 2030 (as of 2040: 70%, best-efforts obligation). For transport between the company’s own locations or affiliated companies, as well as between companies within the same country, a 100% requirement even applies.

De minimis threshold for all reuse targets: Any entity that provides no more than 1,000 kg of packaging per year in a Member State and meets the definition of a microenterprise is exempt from the targets.

Refills (Art. 28): If you offer products for refill, you must inform end consumers about approved containers, hygiene standards, and their responsibilities—and update this information regularly. Starting January 1, 2030, retailers with a sales area exceeding 400 m² should aim to allocate 10% of that area to refill stations (for food and non-food items). This is formulated as a best-efforts obligation, not a strict quota.

Substance Restrictions – Effective Immediately

• Heavy metals: The total concentration of lead, cadmium, mercury, and hexavalent chromium in packaging and packaging components must not exceed 100 mg/kg.
• PFAS in food packaging: Limits will take effect on August 12, 2026 (25 ppb per individual substance, 250 ppb total, 50 ppm total PFAS)—this is particularly relevant if you operate a food business or food Fulfillment service.

What happens in the event of violations?

Member States must introduce effective, proportionate, and dissuasive penalties by February 12, 2027 (Art. 68(1)). In the event of violations of the reuse and prevention provisions (Art. 24–29), fines must be included in the range of penalties. Specific penalties and consequences have not yet been announced.

Deadline Overview at a Glance

Your Checklist as a Retailer

1. Clarify your role: Are you purely a distributor, or do you become a producer through your own brand or repackaging?
2. Supplier Audit: Require all suppliers to provide proof of labeling and registration.
3. Checking Registration: Do you need to register as a manufacturer—and in which member states?
4. Calculating EPR Fees: Individually or Through an Organization for Producer Responsibility?
5. Review Your Packaging Design: Will Your Packaging Meet the Recyclability and Minimization Criteria Starting in 2030?
6. Optimizing e-commerce packaging: Keep an eye on the void space ratio, especially for shipping.
7. Develop a reuse strategy: If you sell beverages or use transport packaging on a large scale, set up or join a reuse system.
8. Mark the deadlines on your calendar: August 12, 2026, and January 1, 2030, in particular, are firm deadlines.

Are you unsure how the PPWR will specifically affect your products, your packaging, or your Fulfillment processes? With over 30 years of experience in Fulfillment, kitting, and food packaging, the IDEAL GROUP can help you adapt your processes to the new requirements early on. Please contact us.

Note: This article is intended for general informational purposes only and does not constitute legal advice in specific cases. IDEAL GROUP assumes no liability for the completeness or timeliness of the deadlines and obligations described herein.