The Packaging and Packaging Waste Regulation (EU) 2025/40, abbreviated as PPWR, is a unified regulation developed by the EU to comprehensively reform the packaging industry, replacing the original Packaging and Packaging Waste Directive (94/62/EC). As a directly applicable EU regulation, PPWR does not require member states to convert it into domestic law, but is uniformly implemented in all 27 member states, completely eliminating the problem of market fragmentation caused by differences in legislation among countries. The PPWR will officially come into effect on February 11, 2025, but most of its provisions will take effect from August 12, 2026, following an 18 month transition period. The regulations cover the entire lifecycle of packaging - from design, production, to market launch, to reuse, recycling, and disposal - with the goal of reducing per capita packaging waste by 15% by 2040.
(a) Overall regulatory framework
(b) Definition of Packaging
Official definition: The criterion for determining whether an item is "intended to be used by an economic operator to accommodate, protect, transport, deliver, or display a product" and is not a part of the product itself.
① Other packaging situations: dust bags used for protecting and transporting clothing and shoes (for transportation and display); ② Other situations that do not belong to packaging: intravenous infusion bags, syringes (which are functional components of medical devices), garbage bags, and dog feces bags, etc; ③ Composite packaging: Composite packaging with a plastic content of ≥ 5% is considered packaging and is subject to packaging bans
(c) Core timeline for the implementation of EU PPWR regulations
(d) 2026 items need to be completed before August 12th
1. Label requirements
PPWR has established a phased and hierarchical packaging label system, gradually transitioning from basic information labeling to a unified EU standardized label.
Starting from August 12, 2026, packaging must be labeled with the following basic information
Identification requirements: All labels must be clear and visible, not easily worn, and still recognizable when the packaging is discarded, and must not be obscured by other information. Labels should be placed near other important consumer information such as barcodes, ingredient lists, or recycling symbols.
2. EPR registration
EPR (Extended Producer Responsibility) is one of the core compliance obligations of PPWR. Starting from August 12, 2026, all companies that place packaged goods on the EU market must fulfill their EPR obligations. Non compliant goods will face customs interception, platform delisting, market bans, mandatory recalls, and even restrictions on participating in EU commercial activities.
Step 1: Determine the sales country and evaluate the registration scope
PPWR follows the principle of territoriality: Sellers are required to complete separate packaging law EPR registration in each EU country for sale. For example, if the product is sold to five countries including Germany, France, Italy, Spain, and the Netherlands, registration needs to be completed for each of these five countries. The registration cycle in various countries is usually 1-4 months, and some countries (such as Italy) may take up to 6 months.
Step 2: Designate an Authorized Representative (AR)
Non EU sellers (including Chinese sellers) must designate a local authorized representative in each selling country, who is a legal entity with an EU address and is responsible for completing registration and declaration on their behalf. Some countries, such as France, Italy, and Spain, have explicitly required AR to participate in compliance processes.
Step 3: Complete EPR registration for each country
Registration can be completed through the following methods:
Official producer registration systems in various countries (such as LUCID in Germany, CITEO in France, CONAI in Italy)
Designated Producer Responsibility Organization (PRO)
Professional compliance service providers assist in handling
Step 4: Upload the registration number to the e-commerce platform (if applicable)
Taking Amazon as an example: log in to the seller platform → select the corresponding sales country → enter "Account Status" → "Manage Your Compliance" → "Submit Compliance Information", fill in the EPR registration number of the target country and submit for review. The review is usually completed within 7 working days.
