The EU Regulation 2025/40 on packaging and packaging waste (PPWR) entered into force on 11 February 2025 and will apply from 12 August 2026. PPWR aims to harmonise the regulatory framework for packaging and packaging waste across the EU with guidance issued on the application at the end of March 2026 https://environment.ec.europa.eu/document/download/3d59ca88-539c-4b6b-a623-0f61068e853e_en?filename=Annex%20to%20the%20Communication%20to%20the%20Commission.pdf
The UK has similar dates for packaging regulations resulting as a legacy of the UK’s Membership of the EU. The UK Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 https://www.legislation.gov.uk/uksi/2024/1332/contents/made were made under the Environment Act 2021 and have been implemented from January 2025 with 1st April 2026 being the deadline for online marketplace Recyclability Assessment Methodology (RAM) submissions.
The EU packaging Regulations apply to all businesses placing packaging on the EU market—manufacturers, importers, distributors, and online retailers—regardless of company size, from 12th August 2026. They apply to all packaging types (primary, secondary, tertiary) regardless of material. Whereas the UK packing Regulations only apply to businesses with a turnover over £1million/annum and importing/supplying more than 25t/a of packaging which must record and report packaging data. Larger producers of over £2million/annum and more than 50t/a must pay an annual fee to manage the cost of household waste packaging in accordance with the RAM. Whilst the UK packaging Regulations apply to less businesses than the EU, they might be considered that they are more practical to apply.
New labelling, recyclability, and reusable packaging targets will apply in the EU from 2028-30 with the aim of reducing, reusing, and recycling packaging, with a maximum of 50% empty space in transport/e-commerce packaging by 2030. The PPWR mandates that all packaging on the EU market must be recyclable by January 1, 2030, with strict, grade-based (A-C) criteria adopted by 2028 to determine EPR fees. The UK should have mandatory “recycle” or “do not recycle” labels from April 2027 in line with OPRL (On-Pack Recycling Label) standards, and could be considered ahead of the EU as the EPR first payment period was October – December 2025.
The materials covered by the EU PPWR include plastics with a minimum 30% recycled content and a ban on single use plastics (hospitality items, films and shrink wraps); paper and cardboard; glass, metals and wood; compostable packaging (e.g. tea bags, coffee pods etc.); a ban on single-use packaging for sauces, sugars, and condiments; and 40% reuse by 2030 of pallets, boxes, trays and crates. The UK has a very similar list of materials covered and include items such as pouches and crisp packets (plastics); labels and bags (paper); steel aerosols and paint tins (metals); fibre-based composites (drinks cartons and pouches); and other materials such as cork, jute, hessian and ceramics. The EU has mandatory Extended Producer Responsibly (EPR) on textiles from September 2025 which is ahead of the UK. The UK is saying it will introduce textiles over the next five years.
The subtle differences between in EU and the UK packaging regulations include the approach, restrictions and bans, and recycled content and labelling. The EU PPWR are explicit market-access regulations where only packaging meeting strict recycling requirements by 2030 may be sold; whereas the UK EPR is a tripartite cost allocation mechanism with less recyclable materials facing higher costs. The EU (PPWR) imposes specific bans on certain single-use packaging under 100ml/g from 2027/2030 whilst the UK (EPR) has more limited bans on specific packaging formats, focusing instead on financial penalties (EPR fees) to deter poor design. The EU PPWR is introducing harmonized, mandatory waste sorting labels across all Member states and will in future introduce specific minimum recycled content percentages for range of materials. The UK currently only has a 30% recycled content for plastic packaging but aims to gain improvements in recycling other waste materials through producer fees.
A significant issue for both UK and EU manufacturers is that UK businesses exporting to the EU must comply with the stricter PPWR requirements, while simultaneously managing UK EPR data and fees for domestic sales. Clearly it would be simpler if the UK and the EU had the same packaging and packaging waste Regulations.
Frith Resource Management (FRM) can support manufacturers in advice on understanding and applying the EPR Regulations, and local authorities in the implications and application of the EPR Regulations to their resource and waste services. We also have experience around MRF adaptation and waste / recyclate flow impacts. Email info@frithrm.com or tel. 01746 552423 www.frithrm.com