Two and a half months before going into effect, Toxintelligence’s Ena Iglebaek Herceglija says that the EU’s coming packaging waste regulation should be seen as something that requires a long-term, strategic approach. Here’s how.

PPWR is the EU’s new regulation on packaging and packaging waste. It becomes applicable from 12 August 2026, although many obligations will be phased in over several years. The regulation applies to all packaging placed on the EU market within all sectors, including sales packaging, such as containers, labels, lids, and cartons, e-commerce packaging used to deliver products to end consumers, and transport packaging used in logistics.

– It introduces harmonised requirements across the EU related to packaging design, material use, recyclability, labelling, documentation, and waste management, says Ena Iglebaek Herceglija, Senior Consultant within regulatory compliance at Toxintelligence.

– PPWR, she continues, represents a fundamental shift in the EU’s approach to packaging and sustainability. From a regulatory perspective, packaging has traditionally been addressed mainly in terms of stability, compatibility, and waste, often as part of the requirements applicable to the product it contains. Under PPWR, however, packaging is treated as a regulated product in its own right.

– Consequently, this shift also introduces a new level of accountability. Companies must be able to demonstrate that their packaging complies with PPWR, for example, through technical documentation and declarations of conformity. For this reason, PPWR should be seen as something that requires a long-term, strategic approach.

Does it affect the entire value chain, or certain parts of it?

– Legally, the main responsibility lies with the manufacturer of the packaging. Under PPWR, this is often the brand owner that has a packaging or a packaged product designed or manufactured under its own name or trademark, rather than the physical producer. 

– In practice, however, compliance is never limited to a single actor. It will affect the entire value chain. Packaging suppliers must provide reliable documentation to the manufacturer, designers, and physical producers must ensure that packaging meets recyclability requirements, and raw material suppliers must ensure that material composition complies with substance restrictions under PPWR.

– All of this information ultimately flows to the manufacturer, or the brand owner, who remains responsible for demonstrating compliance.

You work with supporting companies in identifying and fulfilling their regulatory obligations within the EU across a range of product areas, including cosmetics. What can you help brands with regarding PPWR?

– We support companies at different stages of their PPWR journey. For many organisations, particularly small and medium-sized companies, the regulation can feel overwhelming due to its scope and level of detail. Our work typically focuses on three key areas.

– Strategic compliance: Since PPWR is still relatively new and will be implemented in phases, many companies are still trying to understand how it will impact their business and what it means in practice. We support companies in translating the regulation into concrete actions, such as what needs to be done, by whom, and when. In many cases, this involves an implementation roadmap aligned with upcoming regulatory deadlines.

– Alignment between brand owners and packaging suppliers: Once a strategy is in place, the focus shifts to collecting the data needed to demonstrate compliance. This requires close alignment between the brand owner and packaging suppliers. We help companies in setting clear expectations and data requirements, ensuring that the necessary documentation is provided in a structured and usable way, for example, through supplier guidelines.

– Packaging assessment. Once documentation about the packaging has been received, it must be reviewed and assessed. We support in evaluating both the completeness of the documentation and whether the packaging meets PPWR requirements.

What’s the most common question you get regarding PPWR?

– ‘Are we really responsible for this, or is it the packaging supplier?’ The answer is that if you place packaging or packaged products on the market under your own brand, you are most likely considered the manufacturer under PPWR and therefore legally responsible. That said, packaging suppliers also have clear obligations. They are required to provide the information and documentation necessary for the manufacturer to demonstrate compliance.

Can it also be beneficial for companies, with PPWR?

– Yes! The regulation introduces requirements on design for recyclability, as well as packaging minimisation—so, no double walls, or false bottoms—and limiting unnecessary empty space. In practice, this can reduce material use, lower packaging, transport, and extended producer responsibility (EPR) costs, and provide a more considered packaging design overall.

– At the same time, the need to collect and manage information on packaging will improve internal decision-making because companies will get better visibility into materials and design choices. 

What other EU legislation should brands look at? And why?

– In addition to PPWR, brands should monitor the Ecodesign for Sustainable Products Regulation (ESPR), also referred to as the Ecodesign Regulation. ESPR acts as a framework regulation, meaning that its requirements will be introduced gradually across different product categories over time. It introduces broader sustainability requirements at the product level, including increased transparency and information obligations throughout the entire product lifecycle. One of the key developments is the introduction of a digital product passport, which will require companies to manage and provide structured data on aspects such as materials, environmental performance, and compliance via a QR code.

What else do you look at now?

– Several different things:

– Packaging is becoming regulated like a product. It’s no longer secondary but regulated with the same level of detail as the packaged product itself.

– Documentation is a compliance currency. If PPWR compliance cannot be demonstrated through documentation, it will not be considered fulfilled. 

– Packaging design will impact market access. Packaging that does not meet PPWR requirements may simply not be allowed on the EU market. Design choices are therefore becoming compliance decisions.

– Lastly, the transition takes time. Many requirements will be introduced gradually, but the transition required by PPWR can take several years. Companies need to start early and work with structured, long-term implementation plans.