Packaging and Packaging Waste Regulation (PPWR) – Business Guidance
Topics
The EU Packaging and Packaging Waste Regulation (PPWR) introduces a comprehensive reform of how packaging must be designed, labelled, reused and recycled across the EU. It aims to reduce packaging waste, increase the use of recycled materials and promote circularity in packaging systems.
For UK food and drink manufacturers, the PPWR will be relevant to any business exporting to the EU or supplying the Northern Ireland market. Under the Windsor Framework, most PPWR provisions apply in Northern Ireland, creating a dual regulatory landscape for UK producers operating across different markets.
Members' Notice: Specific PPWR Requirements Applicable from 12 August 2026
Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40) has applied generally to all packaging placed on the EU market; many of the provisions also apply to packaging placed on the NI market. While many of the Regulation’s requirements are being phased in over several years corresponding with the development of secondary legislation, members’ attention is drawn to those detailed below which have applied since 12 August 2026:
- Conformity Assessment Procedure and EU Declaration of Conformity (Articles 38 and 39)
Before packaging can be placed on the EU market, it is the responsibility of the manufacturer to:
- Assess the conformance of the packaging against the applicable requirements under Articles 5–12 following the procedure set out in Annex VII of PPWR. From 12 August 2026, the requirements covered by the conformity assessment procedure and Declaration of Conformity are Article 5(4) on heavy metals, Article 5(5) on PFAS in food-contact packaging and, where applicable, Article 11(1) on reusable packaging. Additional Articles will fall within scope as the corresponding provisions become applicable (e.g. Article 10 on packaging minimisation is due to apply from January 2030). The EC has clarified that the manufacturer retains legal responsibility for compliance, including where elements of the CAP are carried out by third parties.
- Complete an EU Declaration of Conformity confirming compliance with the applicable requirements, in accordance with Article 39 and using the model structure set out in Annex VIII.
- Retain the technical documentation and EU Declaration of Conformity and make them available to regulators on request:
- For at least 5 years from the date the packaging is placed on the market (single-use packaging)
- For at least 10 years from the date the packaging is placed on the market (reusable packaging)
The joint Defra, DAERA and FSA FAQs state that a pragmatic initial enforcement approach will be adopted in NI for the Declaration of Conformity requirements under Articles 5(4), 5(5) and 11(1). This does not remove the underlying legal obligations.
- Heavy Metal Concentration Limits (Article 5)
Packaging must not exceed a combined total concentration of 100 mg/kg of:
- Lead
- Cadmium
- Mercury
- Hexavalent chromium
- PFAS Restrictions (Article 5)
Food-contact packaging must contain PFAS below the following concentration limits:
- 25 ppb for any PFAS measured using targeted PFAS analysis, excluding polymeric PFAS from the quantification
- 250 ppb for the sum of PFAS measured using targeted PFAS analysis, where appropriate following degradation of precursors, excluding polymeric PFAS from the quantification
- 50 ppm for PFAS, including polymeric PFAS
Where total fluorine exceeds 50 mg/kg, the relevant manufacturer, importer or downstream user must, upon request, provide evidence showing the amount of fluorine attributable to PFAS and non-PFAS substances so that the required technical documentation can be prepared.
The European Commission has confirmed that these limits apply to the packaging unit as a whole, including inks, coatings, adhesives and other components, and apply irrespective of whether PFAS are intentionally added or unintentionally present. Manufacturers must ensure compliance with the applicable PFAS thresholds set out in Article 5(5).
Since 12 August 2026, food-contact packaging containing PFAS at or above any of these limits may not be placed on the EU market. In general, sales and grouped food-contact packaging are placed on the market when they are filled, whereas transport and service packaging are placed on the market empty.
The Commission has clarified that the PPWR provides no general stock-exhaustion period for food-contact packaging containing PFAS. Packaging placed on the EU or NI market before 12 August 2026 may remain on the market and does not have to be withdrawn, but packaging first placed on the market on or after that date must comply. Producers should not therefore assume that all unfilled sales or grouped packaging held before the deadline can simply be run down: the Commission states that these formats are generally placed on the market when they are filled, so manufacture or physical possession of empty packaging before the deadline does not by itself establish that it was already placed on the market. However, the Commission also states that empty or filled food-contact packaging can be placed on the market through an offer or agreement transferring ownership, possession or another property right once manufacture is complete. Whether particular empty stock was placed on the market before 12 August 2026 is therefore fact-specific and should be supported by clear evidence of the first qualifying transfer. Transport and service packaging are generally placed on the market empty.
There is currently no single fully harmonised EU testing standard applicable across all food-contact packaging materials and matrices. However, the Commission’s June 2026 guidance recommends an interim stepwise analytical approach to support verification and enforcement:
- Quantification of total fluorine. If total fluorine is below 50 mg/kg, the sample may be considered compliant.
- Where total fluorine exceeds 50 mg/kg, methods such as pyrolysis-GC/MS may be used to determine whether the fluorine is organic or inorganic. If organic fluorine is below 50 mg/kg, the sample may be considered compliant.
- Direct total oxidisable precursor analysis is recommended to assess compliance with the 25 μg/kg and 250 μg/kg limits.
Manufacturers should retain sufficient technical documentation to demonstrate compliance, which may include supplier information, declarations and analytical evidence. Where testing is undertaken, the joint UK FAQs recommend using a suitably accredited laboratory and indicate that ISO/IEC 17025 accreditation is appropriate. No fixed testing frequency has been prescribed. As a practical compliance measure, businesses should maintain evidence for each relevant packaging type and review it when materials, suppliers or manufacturing processes change.
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Feature |
EU PPWR – Article 5(5) |
UK pEPR – RAM 2027 |
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PFAS thresholds |
Food-contact packaging must not contain: ≥25 ppb of any individual PFAS measured through targeted analysis; ≥250 ppb for the sum of targeted PFAS; or ≥50 ppm total PFAS, including polymeric PFAS. |
Packaging receives an automatic Red rating if an item or component contains >1 ppm total PFAS, whether individually or in sum. For food packaging, the stricter threshold is >25 ppb for any individual or total PFAS. |
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Packaging within scope |
Applies only to food-contact packaging. It does not generally include pet-food packaging because pet food is legally classified as feed rather than food. |
Applies to household packaging, packaging commonly ending up in public bins and household glass drinks containers. This can include primary and secondary packaging, including pet-food packaging, where it falls within the household-packaging definition. |
What UK Producers need to do
UK producers placing packaging on the EU or N Ireland market from 12 August 2026 will need to ensure that they understand the above provisions and take appropriate steps to be able to demonstrate compliance. The EC has now published guidance on the interpretation of PPWR requirements, including the CAP. This guidance is intended to support implementation but does not amend the legal obligations set out in the Regulation. Further clarification may be provided over time as additional implementing and delegated acts are developed.
Purpose of the Guidance
This guidance has been prepared to help UK manufacturers understand the implications of the PPWR and how it interacts with existing UK packaging legislation, including:
- Plastic Packaging Tax (PPT)
It provides a comparison between PPWR and UK regulations, highlighting areas of alignment and difference across implementation timelines, obligations, and compliance requirements. The aim is to support members in assessing potential impacts on packaging, operations, and supply chains. This guidance includes dedicated sections on:
Why PPWR Matters
Businesses placing food and drink products on the EU market must comply with the Packaging and Packaging Waste Regulation (PPWR), which sets requirements covering packaging design, recyclability, recycled content, labelling and reuse. The PPWR entered into force on 11 February 2025, and its general application date is 12 August 2026. However certain provisions will apply later.
Due to the Windsor Framework, most of these requirements also apply to packaging placed on the NI market as outlined in the Commission’s explanatory memorandum accompanying Regulation (EU) 2025/40. This includes rules on substances of concern, recyclability, recycled content, compostability, packaging minimisation, labelling and restrictions on certain packaging formats.
Under PPWR, “placing on the market” refers to the first time packaging or a packaged product is made available on the EU market in the course of a commercial activity, which triggers the relevant regulatory requirements. The Commission guidance indicates that the point at which this occurs will depend on the type of packaging: for sales and grouped packaging, this will typically be when the packaging is filled and supplied with a product, whereas for transport and service packaging, this may occur when the empty packaging is first supplied. Members should therefore consider the specific packaging format and supply chain when determining the point at which obligations apply.
By contrast, most of the system and infrastructure obligations laid down in PPWR do not apply in NI. This includes the Article 29 reuse targets and wider national waste collection and management system measures. The refill obligations in Article 28 are not excluded by the Commission Notice and therefore apply in NI. As such, NI will remain in scope of the UK’s packaging extended producer responsibility (pEPR) scheme.
This guidance outlines the core provisions of PPWR and compares these with equivalent requirements under UK packaging legislation, notably Extended Producer Responsibility (EPR), Essential Requirements Regulations and the Plastic Packaging Tax (PPT). However for many of the provisions within PPWR further detail will be elaborated within future secondary legislation, otherwise known as implementing and delegated acts.
Requirements for Substances of Concern (PPWR Article 5)
From 12 August 2026, manufacturers placing packaging on the EU market must ensure that packaging complies with the following specific substance requirements set out in Article 5. Manufacturers must carry out the applicable conformity assessment and prepare and retain supporting technical documentation and an EU Declaration of Conformity. Importers must verify that the manufacturer has completed these requirements before placing imported packaging on the EU market:
- Lead, cadmium, mercury, and hexavalent chromium: Under PPWR, the combined concentration of these heavy metals in packaging must not exceed 100 mg/kg, equivalent to 100 ppm. In Great Britain (GB), the same limit is established under the Packaging (Essential Requirements) Regulations 2015 (SI 2015 No. 1640).
- PFAS: Under PPWR, food-contact packaging placed on the EU market must comply with the following concentration limits for per- and polyfluoroalkyl substances (PFAS):
- below 25 ppb for any individual PFAS measured using targeted analysis, excluding polymeric PFAS from quantification;
- below 250 ppb for the sum of PFAS measured using targeted analysis, where applicable following degradation of precursors, excluding polymeric PFAS from quantification; and
- below 50 ppm for total PFAS, including polymeric PFAS. Where total fluorine exceeds 50 mg/kg, evidence may be required to demonstrate how much of the fluorine arises from PFAS or non-PFAS sources.
These limits apply irrespective of whether PFAS are intentionally added and apply to the packaging unit as a whole, including associated inks, coatings, varnishes and adhesives. In practice, food-contact packaging containing PFAS at or above any of the defined thresholds must not be placed on the EU market from 12 August 2026. The Commission has clarified that packaging placed on the market before that date may remain on the market, but there is no general stock-exhaustion period. Unfilled sales or grouped packaging is not automatically exempt merely because it was manufactured or held before the deadline: these formats are generally placed on the market when filled. The guidance nevertheless recognises that a qualifying offer or agreement transferring ownership or possession of completed empty packaging can amount to placing it on the market. Businesses relying on a pre-deadline placing on the market should retain clear evidence of that first transfer.
In GB, certain PFAS are controlled under UK REACH and assimilated persistent organic pollutants legislation. The UK PFAS Plan includes further testing of food packaging to support possible future regulatory action, but it does not establish or commit to PPWR-equivalent packaging-specific market restrictions. Separately, under RAM 2027, packaging must automatically be rated red if it contains more than 1 ppm total PFAS, whether as an individual PFAS or in sum, or if food packaging exceeds 25 ppb for any individual or total PFAS. These RAM thresholds affect the packaging’s EPR recyclability rating and potentially its disposal fees; they do not prohibit the packaging from being placed on the UK market. PPWR requirements, including its PFAS market restriction, apply to packaging placed on the NI market.
Producer Obligations (PPWR Article 5 to 12)
Manufacturers may only place packaging on the EU market if it complies with the requirements outlined in Articles 5 to 12 of PPWR, as the relevant requirements become applicable. Under PPWR, the manufacturer is responsible for demonstrating compliance, including completing the applicable conformity assessment, preparing technical documentation and drawing up an EU Declaration of Conformity. Producer obligations relating to waste management apply separately in each Member State. The terms “manufacturer” and “producer” are therefore not interchangeable under PPWR. The Commission has clarified that, for sales and grouped packaging, the manufacturer will normally be the filler, which will often also be the product brand owner, rather than necessarily the business that physically produced the packaging. Manufacturers must also retain the technical documentation and EU Declaration of Conformity demonstrating compliance for five years after placing single-use packaging on the market, and for ten years in the case of reusable packaging.
In the UK, the Packaging (Essential Requirements) Regulations 2015 require that the responsible person ensure all packaging placed on the market is of a minimum volume and weight and is the minimum amount necessary to maintain the required levels of safety, hygiene and acceptance for the packed product and for the consumer. Packaging must also meet essential requirements for safety and functionality and be manufactured to permit its reuse or recovery, as well as meet heavy metal limits. The responsible person must retain documentation demonstrating compliance for four years from the date the packaging is placed on the market.
Recyclable Packaging (PPWR Article 6)
- The general requirement that packaging placed on the EU market must be recyclable applies from 12 August 2026. However, the detailed design-for-recycling requirements will apply from 1 January 2030, or 24 months after the relevant delegated acts enter into force, whichever is later. From that date, packaging will need to achieve recyclability performance grade A, B or C, subject to limited exemptions (e.g. certain medical or safety-critical applications).
- Recyclability will be assessed through a harmonised grading system (A, B or C) based on design-for-recycling performance. The detailed criteria underpinning this system will be established through delegated acts to be adopted no later than 1 January 2028 (PPWR Art. 6.4). These measures will define how packaging design features affect recyclability performance.
- From 18 months after the relevant delegated acts enter into force, Extended Producer Responsibility (EPR) fees must be modulated according to the recyclability grade of packaging (PPWR Art. 6.8). July 2029 is therefore an indicative rather than a fixed date, as it assumes that the delegated acts enter into force by 1 January 2028. Alongside the design-for-recycling criteria, the European Commission will adopt harmonised eco-modulation criteria to ensure a consistent framework across Member States, while Member States retain discretion over fee levels.
- Eco-modulation may also take into account additional factors such as the use of recycled content and the presence of hazardous substances.
- From 1 January 2035, or five years after the relevant implementing acts enter into force, whichever is later, packaging must not only be recyclable in theory but also recycled at scale. This means that sufficient collection, sorting, and recycling infrastructure must be in place across the EU for that type of packaging.
- From 1 January 2038, only packaging with a recyclability grade of A or B will be allowed on the EU market. Packaging graded as C will no longer be permitted.
Under PPWR, recyclability will initially be assessed based on design-for-recycling performance criteria. The later recycled-at-scale requirement will also take account of whether the necessary collection, sorting and recycling infrastructure is operating in practice.
Comparing both the EU and the UK EPR schemes, there are notable differences in their approaches to recyclability assessment and fee modulation. The PPWR will use a grading system to assess recyclability based on a “design for recycling” approach (2030) eventually only permitting grades A and B on the market (2038). The UK’s EPR system assesses recyclability using the Recyclability Assessment Methodology (RAM) tool which assesses performance throughout the recycling process based on current infrastructure provision. Unlike the EU, the UK does not plan to ban any specific packaging formats based on recyclability. However, producers using harder-to-recycle packaging are expected to face significantly higher EPR fees.
Minimum Recycled Content in Plastic Packaging (PPWR, Article 7)
Subject to specific exemptions, from 1 January 2030, or three years from the date on which the relevant Article 7 implementing act enters into force, whichever is later, any plastic part of packaging placed on the EU market must contain a minimum percentage of recycled content derived from post-consumer plastic waste. These minimum requirements are set by packaging type and format, with binding targets for 2030 and 2040 (see Table 2 below). Recycled content will be calculated as an average per manufacturing plant and calendar year for each packaging type and format.
The principal exemptions relevant to food and drink packaging are:
- Food-contact plastic packaging, where the inclusion of recycled content would pose a risk to human health and cause the packaged product not to comply with Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food.
- The Commission has clarified that this exemption applies directly, without prior approval from the Commission or a national authority, but must be substantiated in the manufacturer’s technical documentation. For each plastic part representing 5% or more of the packaging unit’s total weight, the documentation must identify the polymer and demonstrate that no suitable authorised recycling technology is listed under Regulation (EU) 2022/1616 and that no suitable technology is available at industrial scale.
- Compostable plastic packaging.
- Contact-sensitive plastic packaging used for:
- Infant formula and follow-on formula,
- Processed cereal-based food,
- Baby food,
- Food for special medical purposes.
- Any plastic part that represents less than 5% of the total weight of the packaging unit.
Other Article 7 exemptions apply to specified pharmaceutical, medical-device and dangerous-goods packaging.
The Commission must adopt implementing acts by 31 December 2026 to establish harmonised methodologies for calculating and verifying recycled content from post-consumer plastic waste, including the assessment, verification and certification of the equivalence of rules applying to post-consumer plastic waste collected or recycled outside the EU.
From 1 January 2029, or 24 months from the date on which the relevant Article 7 implementing act enters into force, whichever is later, the calculation and verification of recycled content for affected plastic packaging must comply with the adopted methodology.
In contrast, the UK Plastic Packaging Tax (PPT) imposes a flat-rate tax on taxable plastic packaging components that contain less than 30% recycled content, subject to PPT’s own exemptions and registration threshold. Unlike PPWR, PPT does not set escalating future targets or ban packaging containing less than 30% recycled content. It also does not provide a general exemption solely because food-contact rules prevent the use of recycled plastic: the packaging component may remain taxable, although HMRC states that recycled plastic should be used only where permitted by other regulations and food-safety standards. While both frameworks aim to increase recycled plastic use, the EU uses a regulatory compliance model, whereas the UK takes a fiscal approach to drive change.
Compostable Packaging (PPWR Article 9)
By 12 February 2026, the European Commission was required to request the European standardisation organisations to prepare or update harmonised standards for compostable and home-compostable packaging. The Commission’s current implementation information continues to describe the development of these standards as forthcoming, and the updated standards have not yet been adopted. In the interim, the existing EN 13432 standard may be used as guidance for industrial compostability, but it does not provide a presumption of conformity with PPWR. From 12 February 2028, specific packaging types, including permeable tea, coffee or other beverage bags; soft after-use system single-serve units containing tea, coffee or another beverage; and sticky labels affixed to fruit and vegetables, including PLU labels, must comply with standards for industrial composting and, where required by the relevant Member State, home-composting standards.
Until 12 August 2026, Member States could require packaging formats additional to those listed in Article 9(1) and Article 9(2)(a) to be industrially compostable. Member States may also require certain formats listed in Article 9(2)(a)—including non-metal, non-permeable beverage-system single-serve units and very lightweight or lightweight plastic carrier bags—to be compostable where appropriate bio-waste collection and treatment infrastructure is available. However, unless compostability is explicitly required under PPWR or through a national requirement permitted under Article 9(2), by 12 February 2028 packaging must be designed for material recycling and must not hinder the recyclability of other waste streams, even if it is made from biodegradable or compostable materials.
In contrast, the UK EPR scheme currently does not mandate compostability for any packaging type. Under the current Recyclability Assessment Methodology (RAM), compostable plastic packaging will normally receive a red rating and therefore be subject to higher modulated disposal fees where it is within scope. Packaging made from other compostable materials must be assessed against the relevant RAM material criteria and is not automatically red solely because it is compostable. Under UK EPR legislation, tea bags and beverage-system coffee capsules and filter-paper coffee pods that are disposed of together with the used coffee product are not considered packaging.
Excessive Packaging & Minimisation (PPWR Article 10 & 24)
By 1 January 2030, manufacturers and importers must ensure that packaging placed on the EU market is designed so that its weight and volume are limited to the minimum necessary to ensure its functionality, including protection, hygiene, safety, characteristics of reusable packaging and provision of information to consumers. Packaging features aimed solely at increasing the perceived volume of a product, such as double walls, false bottoms or unnecessary layers, will also be prohibited. Limited exemptions apply to certain packaging designs or trademarks protected before 11 February 2025 and to packaging for products covered by specified EU geographical indications or quality schemes. By 12 February 2027, the Commission must request the European standardisation organisations to prepare harmonised standards and assessment methodologies for packaging minimisation to ensure consistent enforcement across Member States.
By 1 January 2030, or three years after the relevant Article 24 implementing acts enter into force—whichever is later—economic operators filling grouped, transport and e-commerce packaging must ensure that it contains no more than 50% empty space. Void-fill materials, including paper cuttings, air cushions, bubble wrap, foam and polystyrene chips, count as empty space. By 12 February 2028, the Commission will define the calculation method, taking into account safety, product protection and legal requirements. From 12 February 2028, economic operators filling sales packaging must also minimise empty space while maintaining functionality. For products that settle during transport or require headspace, compliance is assessed at the time of filling; air between or within packed food and protective gases is not treated as empty space. The 50% limit does not apply where sales packaging is used directly as e-commerce packaging or to reusable packaging used within a reuse system, although those formats must still comply with Article 10. By 12 February 2032, the Commission will review the 50% limit and exemptions and consider setting specific empty-space ratios for sales packaging, particularly toys, cosmetics, DIY kits and electronic products.
In GB, the Packaging (Essential Requirements) Regulations 2015 contain a similar general requirement that packaging be limited to the minimum volume and weight necessary to maintain the required levels of safety, hygiene and consumer acceptance for the packed product. For in-scope household packaging, UK packaging EPR disposal fees are charged according to packaging weight and material category. Consequently, unnecessary packaging weight increases a producer’s total fee liability; the applicable rate is also affected by the packaging’s recyclability assessment.
Reusable Packaging & Refill (PPWR Articles 11, 28 & 29)
PPWR sets out specific conditions under which packaging may be classified as reusable. To qualify, packaging must be conceived, designed and placed on the market with the objective of being reused multiple times and must meet further requirements concerning rotations, reconditioning, safety, hygiene and recyclability at the end of its life. By 12 February 2027, the EC must establish the minimum number of rotations required for packaging formats most frequently used in reuse to be considered reusable. PPWR sets binding reuse targets for certain packaging types from 2030, requiring the relevant economic operators, rather than producers generally, to meet minimum percentages of reusable packaging. The corresponding 2040 figures are not binding targets; operators must instead endeavour to achieve them.
Commission Delegated Decision (EU) 2026/429 exempts economic operators using pallet wrappings and straps from the 100% reuse requirements under Article 29(2) and (3). For the uses covered by that exemption, recital 2 states that the Article 29(1) reuse quotas do not apply; pallet wrappings and straps used in other Article 29(1) transport operations remain within the overall 40% calculation.
Additionally, Article 28(5) provides that, from 1 January 2030, final distributors with a sales area exceeding 400 m² must endeavour to allocate at least 10% of their sales area to refill stations covering both food and non-food products. This is therefore an indicative objective rather than a binding requirement. The reuse targets in Article 29 do not apply in NI. The refill obligations in Article 28 are not excluded by the Commission Notice and therefore apply.
For now, the UK EPR system does not include binding reuse targets or minimum rotation requirements. Current UK EPR guidance nevertheless requires reusable packaging to be reported when it is first supplied and recorded both under the relevant packaging activity and as reusable packaging. The previously anticipated Defra call for evidence focusing initially on glass has not been published, so no firm timetable for such a call should now be stated.
Labelling Requirements (PPWR Article 12)
By 12 August 2026, the European Commission was required to adopt implementing acts establishing harmonised packaging labels, based on pictograms, and detailed labelling specifications. However, the implementing acts were not adopted by the statutory deadline; EUROPEN reports that they are now due in Q4 2026. This system is intended to help consumers correctly sort packaging waste by linking packaging labels with corresponding labels on waste collection receptacles. The labelling requirement will apply from 12 August 2028 or 24 months after the relevant implementing act enters into force, whichever is later. Transport packaging will be exempt, except for e-commerce packaging.
In June 2025, the Commission’s Joint Research Centre (JRC) conducted a targeted consultation on a proposed system of Waste Sorting Labels (WSL). Building on this consultation, the JRC published a technical proposal in January 2026 outlining a potential harmonised EU labelling system, including standardised pictograms and guidance on how packaging labels may correspond with waste collection receptacles across Member States. The proposal is intended to inform the Commission’s implementing acts but is not legally binding, and the final labels and specifications may differ from the JRC proposal.
In contrast, mandatory waste-sorting labelling has not yet been introduced under the UK EPR scheme. The governments of England, Scotland and Wales have said that they will review the PPWR implementing act once published and explore the potential for consistency between the UK and EU approaches, with the aim of reducing costs and complexity for businesses operating across multiple markets. The PPWR labelling requirements will apply directly to packaging placed on the NI market. The joint UK FAQs state that a formal UK Government consultation on regulatory consistency across the UK is planned for early 2027; no decision has yet been taken on alignment in GB.
Restrictions on certain Packaging Formats (PPWR Article 25)
From 1 January 2030, economic operators will be prohibited from placing certain packaging formats on the EU market, including the following food- and drink-related formats:
- Single-use plastic grouped packaging (e.g., collation films or shrink wraps) used at the point of sale to bundle bottles, cans, tins, pots, tubs, or packets intended as convenience packaging to encourage or enable consumers to purchase multiple products. This restriction does not apply to grouped packaging necessary to facilitate handling. The Commission has also clarified that the restriction does not cover B2B situations.
- Single-use plastic packaging for pre-packed unprocessed fresh fruit and vegetables weighing less than 1.5 kg. Member States may exempt such packaging where there is a demonstrated need to avoid water or turgidity loss, microbiological hazards, physical shocks or oxidation, or where no proportionate alternative is available to prevent the commingling of organic and non-organic produce.
- Single-use plastic packaging, such as sachets, used in the HORECA sector and containing individual portions or servings of condiments, preserves, sauces, coffee creamer, sugar, and seasoning. The restriction does not apply where the packaging accompanies takeaway ready-prepared food intended for immediate consumption without further preparation, or where it is required for safety and hygiene in establishments providing medically required individualised care.
For the purposes of these restrictions, the Commission interprets “single-use plastic packaging” as also covering composite packaging, including paper-based packaging, where plastic represents more than 5% of the total mass of the packaging unit.
No equivalent prohibitions covering these three formats have currently been legislated in GB. These PPWR restrictions will, however, apply to packaging placed on the NI market under the Windsor Framework. Under the UK Packaging Pact, launched in April 2026 to succeed the UK Plastics Pact, participating businesses have voluntary goals to reduce single-use packaging and remove problematic and unnecessary packaging; these may cover some of the formats listed above.
Prevention of Packaging waste (PPWR Article 43)
PPWR requires each Member State to reduce per capita packaging waste compared to 2018 levels by at least 5% by 2030, 10% by 2035, and 15% by 2040. By 12 February 2027, the Commission must establish a correction factor to account for increases or decreases in tourism. Member States were able, until 31 December 2025, to request an alternative base year if justified by reporting changes rather than consumption trends. By 12 February 2032, the Commission will review the targets and consider introducing material-specific targets, accompanied, where appropriate, by a legislative proposal. In meeting the targets, Member States must also endeavour to reduce the amount of plastic packaging waste generated.
Member States are required to implement additional waste-prevention measures, such as incentives provided through extended producer responsibility schemes or requirements for producers or producer responsibility organisations to adopt waste-prevention plans, provided they are proportionate, non-discriminatory, and do not distort trade. These measures must not lead to a shift towards lighter packaging materials simply to meet the packaging-waste reduction targets. Member States may also introduce prevention measures that exceed the minimum targets, provided they remain consistent with PPWR. They must also incentivise restaurants, canteens, bars, cafés and catering services to provide tap water in reusable or refillable formats for free or for a low service fee.
No equivalent packaging-specific prevention targets are currently established under UK legislation. The Article 43 targets do not apply in NI under the Windsor Framework. Separately, the UK Packaging Pact includes voluntary packaging-reduction goals, but these are not statutory targets.
Separate Collections (PPWR Article 48 & 49)
PPWR requires Member States to set up systems for the return and separate collection of all packaging waste. These systems must support reuse and enable high-quality recycling. From 1 January 2030, packaging that complies with the design-for-recycling criteria established under Article 6 must be collected for recycling and cannot be sent to landfill or incineration, except for waste resulting from subsequent treatment operations on separately collected packaging waste where recycling is not feasible or does not deliver the best environmental outcome. Packaging formats and materials that are exempt from the design-for-recycling criteria are also exempt from this landfill and incineration restriction.
Member States must ensure nationwide collection and sorting systems that preserve the quality of recycled materials. In limited cases, mixed collection may be allowed provided that it does not affect the capacity of the packaging waste to undergo preparation for reuse, recycling or other recovery operations, and produces output of comparable quality to that obtained through separate collection. Even where this derogation is used, the landfill and incineration restriction continues to apply to packaging that meets the design-for-recycling criteria. Member States may require packaging waste that is not separately collected to be sorted before disposal or energy recovery to remove packaging designed for recycling.
These systems must cover all packaging types and provide accessible facilities in public, commercial, and residential areas. They must be open to all operators and authorities, treat imported products fairly, and avoid distorting trade. Member States are also required to promote recycling that meets quality standards. From 1 January 2029, Member States must set mandatory collection objectives aligned with PPWR recycling targets and the mandatory recycled-content targets in Article 7. The collection-system obligations in Article 48 do not apply in NI under the Windsor Framework, while Article 49 is an obligation addressed to EU Member States. NI therefore remains subject to the relevant UK waste-collection and packaging EPR arrangements.
By contrast, the UK’s consistent collections policy is being taken forward separately in each of the four nations. There is no single UK-wide collection timetable. In England, the core workplace recycling requirements have applied since 31 March 2025, except for micro-firms, which have until 31 March 2027. Household collection requirements took effect on 31 March 2026, subject to agreed transitional arrangements for some local authorities. In July 2026, the Government announced its intention to defer mandatory collection of plastic films and flexible packaging from households and workplaces from 31 March 2027 to 1 April 2030. The relevant regulations are expected to be amended to give effect to this change.
In England, under a policy branded ‘Simpler Recycling’, plastic, metal and glass may be co-collected, while paper and card must normally be collected separately unless a written co-collection assessment demonstrates that this is either not technically or economically practicable or has no significant environmental benefit. Simpler Recycling does not itself impose an equivalent to PPWR’s specific prohibition on landfilling or incinerating packaging that complies with the design-for-recycling criteria. In addition, since October 2024, permitted waste facilities in England that qualify as “materials facilities” have been required to follow rules for sampling, measuring, and reporting the types and amounts of waste they handle. These requirements aim to improve the quality of recyclable materials and ensure better data for recycling systems. Relevant materials facilities must notify the Environment Agency, carry out regular sampling, and submit their waste data in the specified format.
Table 5 update: the 31 March 2027 date shown for England’s plastic films and flexibles collection has been superseded by the July 2026 deferral announcement; the intended date is 1 April 2030, subject to amendment of the regulations.
Recycling Targets (PPWR Article 52)
PPWR sets binding recycling targets for packaging waste. By 31st December 2025, Member States must take measures to achieve the below recycling rates in table 6.
Member States may postpone the material-specific targets by up to five years, provided that:
- Any derogation from the target may not exceed 15% when applied to a single target or divided between two targets.
- Recycling rates for any material must not fall below 30% after 31 December 2025.
- Recycling rates for glass, paper, and cardboard must not fall below 60% after 31 December 2025, or 70% after 31 December 2030.
- The derogation must be supported by an implementation plan submitted to the Commission no later than two years before the relevant deadline.
By 12 February 2032, the Commission will review the 2030 targets with a view to increasing them or setting additional goals.
PPWR useful links
