What you really need to know about Packaging and Extended Producer Responsibility (EPR) in the EU and UK

(5 min read)

The last few years have seen major reforms to the regulation of packaging in the EU and the UK which affect all businesses that either manufacture, import or supply any type of packaging (including the sale of packaged products). These changes reflect the important role that packaging has to play in the transition to a more circular and sustainable economy. In this article we consider the amendments to the UK extended producer responsibility (EPR) regime for packaging as well as the EU’s new flagship packaging regime introduced by the Packaging and Packaging Waste Regulation (PPWR). It is crucial for any business that handles or uses packaging to start considering the impact of these developments on its activities now. In respect of EU PPWR there are plenty of opportunities for affected businesses to input on developing guidelines and secondary legislation in advance of obligations becoming applicable from August 2026.

Key aspects of EU PPWR

Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) repeals and replaces the existing Packaging and Packaging Waste Directive (94/62/EC). PPWR will regulate all aspects of the packaging lifecycle, aiming to reduce the adverse impacts of packaging and packaging waste on the environment and human health. PPWR does so through a range of different measures with the first obligations becoming applicable in just over a year’s time on 12 August 2026.

1. Making packaging more sustainable

PPWR provides for:

A requirement for all packaging to be recyclable by 2030 and then recyclable at scale by 2035.
Minimum post-consumer recycled content requirements for plastic packaging (e.g. 30% for single use plastic beverage bottles from 2030).
Compostability standards for certain packaging items (including sticky labels on fruit, very lightweight plastic bags, and tea and coffee bags or pods).
Harmonised labelling requirements to provide information on material composition and facilitate consumer sorting and recycling, addressing issues caused by various Member States (e.g. Italy, France and Spain) adopting their own packaging labelling regimes.
Restrictions on the use of PFAS in food packaging.

Significantly, packaging manufacturers will need to carry out a conformity assessment and prepare a Declaration of Conformity (or DoC) confirming packaging complies with these requirements. To the extent that packaging is produced outside of the EU, EU importers will be responsible for verifying that these requirements have been complied with.

2. Increasing the use of refillable and reusable packaging solutions

From 2030, PPWR prohibits the placing on the market of single use plastic packaging for:

Grouping products (e.g. bottles, cans, tins etc.)
Unprocessed fresh fruit and vegetables
Food and drinks made and consumed within restaurants and similar establishments in the HORECA sector (with packaging for takeaway food and drink separately addressed through the refill and reuse provisions commented on further below)
Individual portions or servings of condiments, preserves, sauces, creamer and sugar etc. (although these are still permitted where provided with takeaway ready-prepared food and in certain medical and care establishments)
Miniature shampoos, shower gels, soaps etc. provided in hotels
Very lightweight plastic carrier bags with a wall thickness below 15 microns.

PPWR seeks to drive the use of reusable packaging formats by imposing a range of targets on businesses in respect of the use of reusable packaging solutions including:

From 2030, a mandatory 40% target for businesses using transport packaging (e.g. pallets, boxes, trays, containers, drums etc.) which increases to an aspirational (i.e. non-mandatory) 70% target from 2040. Note, businesses will be required to use 100% reusable transport packaging for moving products between their own sites located within the EU, as well as for transporting products to other businesses located within the same EU Member State. Helpfully though, cardboard boxes are excluded from these targets.
From 2030, a mandatory 10% target for grouped packaging which increases to an aspirational 25% target from 2040. Again, cardboard boxes are excluded.
From 2030, a mandatory 10% target for businesses that sell directly to consumers certain types of bottled and canned drinks which increases to an aspirational 40% target from 2040. Notably these targets do not apply to certain types of bottled dairy products, wines and spirits.

PPWR also seeks to reduce the amount of single use packaging used by businesses selling takeaway food and drinks packaged at the point of sale by requiring those businesses to offer:

refill for food and drink enabling consumers to bring their own containers and cups (from February 2027)
food and drink in reusable packaging within a system of reuse (from February 2028).

3. Harmonising Extended Producer Responsibility (EPR)

PPWR seeks to harmonise packaging EPR regimes across the EU. Historically, Member States introduced EPR regimes for packaging to comply with their obligations under the Packaging Waste Directive but the lack of specificity in the Directive means that there has been inconsistency in how these regimes have developed and operated across the EU. PPWR now provides for detailed requirements for EPR regimes with the aim of ensuring a more consistent implementation for businesses operating in multiple Member States. That said, crucially, business will still need to comply with EPR (i.e. register as a producer and report on quantities of packaging placed on the market) on a Member State by Member State basis.

4. Establishing Deposit Return Systems (DRS)

Many EU Member States already have (long) established Deposit Return Systems (or DRS) in place. These drive the collection of used drinks containers such as bottles and cans by charging a deposit that is returned to consumers when the container is returned. PPWR will make the adoption of these schemes mandatory across the EU with the aim of collecting at least 90% of single-use plastic bottles and metal beverage containers by 2029. Note, the UK is separately pursuing the adoption of DRSs with the implementing legislation now in place for England, Scotland and Northern Ireland and the associated DRS due to become operational in October 2027. Wales is expected to consult on its own planned DRS over the summer.

Update on UK EPR for packaging

The new EPR regime for packaging in the UK (often referred to as pEPR) has been introduced primarily through The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 and implementation is now underway. While the previous regime (introduced in 1997) sought to make businesses who supply and use packaging responsible for the cost of packaging recycling, pEPR seeks to make large producers also responsible for the full costs of packaging waste disposal paid to Local Authorities in respect of household packaging, commonly binned packaging and glass drinks containers. Large producers of household packaging will therefore be required to pay significantly increased fees in respect of the packaging that they place on the market in the UK.

In respect of recycling, producers can continue to rely on existing producer compliance schemes to assist with discharging their obligations by collecting evidence of packaging recycling on their behalf (i.e. by buying packaging recycling notes (PRNs) and packaging export recycling notes (PERNs) from waste reprocessors and exporters). Waste disposal fees will be invoiced to large producers directly from October 2025 based on data that they have already submitted in respect of packaging placed on the market in 2024. Business will only have certainty on the final amount of the waste disposal fee at that time, although the government has published illustrative base fees (with final fees expected to be confirmed in July) to enable producers to estimate and plan for the expected cost.

Other recent UK pEPR developments include:

The publication in April 2025 by PackUK (the scheme administrator for pEPR) of an updated version of the Recyclability Assessment Methodology (RAM). Waste disposal fees payable for packaging placed on the market in 2025 (i.e. fees invoiced in 2026) will be modulated to take into account the recyclability of packaging covered (i.e. the harder packaging is to recycle the more producers will have to pay). Large producers reporting packaging data for 2025 (the next reporting deadline being 1 October 2025) will need to confirm the outcome of their recyclability assessment (either red, amber or green) for each type of household packaging supplied.
The publication in May 2025 of additional guidance for “small producers” in respect of their obligations under pEPR, which are limited to registration and data reporting and do not require financial contributions towards the costs of recycling and waste disposal.

While these regimes present a complex and shifting framework that businesses must navigate, they will undoubtedly be a key driver towards the increased use of more sustainable packaging solutions in both the EU and the UK. Businesses should carefully assess the impact of these developments on any of their activities involving packaging, including manufacture, import, distribution and retail of packaging and packaged products. In respect of PPWR, the first obligations will become applicable from August 2026, with other obligations only applying from a later date. Crucially this means that there is still time for impacted businesses to plan for any required changes to their packaging suppliers as well as input into the development of the many pieces of secondary legislation required under PPWR and the Commission’s expected guidance documents.