Does PPWR apply to UK companies?
Yes, it can. UK manufacturers selling packaged goods into the EU, supplying EU distributors or placing packaging on the EU market through an importer may need to comply with PPWR.
The first step is to understand your role in the supply chain. The relevant manufacturer may be the packaging supplier, brand owner, importer or distributor, depending on how the packaging is marketed and supplied.
Six practical areas to review
1. Identify who is responsible
The business that physically manufactures the packaging is not always the PPWR manufacturer. Responsibility may depend on whose name or trademark appears on the packaging, who places it on the EU market and whether it has been modified.
For each EU-bound packaging specification, record:
- packaging or product code.
- customer and destination.
- brand or trademark.
- manufacturer, importer, and distributor.
- who holds the technical evidence.
- who signs any required declaration.
2. Maintain traceability records
PPWR requires packaging to be identifiable through a type, batch, serial number or equivalent identifier. Manufacturer information may be provided on the packaging, through a data carrier or in accompanying documentation, depending on the circumstances.
Use a controlled packaging specification code linked to:
- material information.
- supplier and order details.
- batch or production records.
- declarations and certificates.
- revision history
3. Build a technical evidence file
Applicable packaging may require conformity assessment and an EU Declaration of Conformity. Any declaration should be supported by reliable evidence rather than a general supplier statement.
Keep records covering:
- packaging description and material breakdown.
- unit weight.
- recycled content and recyclability evidence.
- food-contact status.
- PFAS or substance declarations where relevant.
- supplier declarations and test reports.
- specification revision date.
- customer and market supplied.
4. Check PFAS in food-contact packaging
From 12 August 2026, food-contact packaging must not be placed on the EU market if it contains PFAS at or above the limits set by PPWR.
This is particularly relevant to coated, grease-resistant, moisture-resistant and barrier packaging.
Request evidence covering the substrate, coatings, barriers, inks, adhesives and treatments. Avoid broad “PFAS-free” claims unless the evidence clearly supports them.
6. Plan for future labelling requirements
PPWR will introduce harmonised labelling, but not all requirements apply immediately. The general material-composition label applies from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.
Rather than redesigning packaging based on assumptions:
- keep artwork flexible.
- allow space for future labels.
- consider QR codes or other data carriers.
- maintain artwork revision control.
- monitor final EU guidance.
6. Prepare for recycled content and recyclability rules
Minimum recycled-content targets are a major future PPWR requirement, and the EU is still developing the calculation and verification methodology.
UK rules are also changing. From 1 April 2027, pre-consumer plastic waste will no longer count towards the recycled-content threshold for Plastic Packaging Tax. UK EPR is also making recyclability increasingly important through the RAM methodology.
Keep separate records for:
- post-consumer and pre-consumer recycled content.
- mechanically and chemically recycled content.
- mass-balance claims.
- supplier certification.
- recyclability assessments.
Evidence used for one regulation may not automatically satisfy another.
