The EU’s Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40 Regulation - EU - 2025/40 - EN - PPWR - EUR-Lex) was passed in January 2025 and has just been applied from August 12, 2026. This applies to packaging and packaging waste that the UK receives from and sends to Europe. EU Commission guidance on the application of PPWR was recently issued in June 2026 (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:C_202603084). The EU’s Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40 Regulation - EU - 2025/40 - EN - PPWR - EUR-Lex) was passed in January 2025 and has just been applied from August 12, 2026. This applies to packaging and packaging waste that the UK receives from and sends to Europe. EU Commission guidance on the application of PPWR was recently issued in June 2026 (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:C_202603084).
The UK packaging waste system operates under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, supported by Extended Producer Responsibility (pEPR) Regulations (https://www.legislation.gov.uk/ukdsi/2024/9780348264654). The UK Government issued guidance on pEPR in July 2025 which was last updated in July 2026 (https://www.gov.uk/government/collections/extended-producer-responsibility-for-packaging). pEPR obligated businesses must cover local authority collection, sorting, and disposal costs for household waste.
The EU PPWR does not use the UK Recyclability Assessment Methodology (RAM) red, amber, and green traffic-light rating system for waste packaging (https://www.gov.uk/government/publications/assess-packaging-recyclability-recyclability-assessment-methodology-ram-2027/ram-2027-overview). Under the UK RAM green waste packaging is widely recyclable with low compliance fees; amber waste packaging is recyclable with some collection or processing challenges; whilst red waste packaging is difficult or impractical to recycle, incurring heavy financial surcharges.
The EU PPWR evaluates packaging recyclability through performance letters (Grades A, B, and C) based on the percentage of the packaging weight that is recyclable: Grade A 95% or more recyclable by weight; Grade B 80% or more; Garde C 70% or more. Waste packaging below Grade C (70%) recyclable are to be banned from the EU market from 1st January 2030 and Grade C packaging will be phased out by 2038.
This is different from the UK where the UK Government is seeking to prevent non and low recyclable packaging through financial measures. The EU EPR is a comprehensive, bloc-wide market-access rulebook governing packaging design, mandatory recycled content, labelling, and reuse. In contrast, the UK’s Extended Producer Responsibility (EPR) focuses primarily on shifting municipal waste management and recycling costs onto producers via modulated fees and data reporting. Waste management in the UK is devolved to the four administrations of England, Wales, Scotland and Northern Ireland. Fortunately, RAM for pEPR applies fairly uniformly across England, Wales, Scotland, and Northern Ireland under PackUK.
The EU PPWR introduces mandatory, harmonized digital and physical waste-sorting labels across the entire EU bloc, alongside binding recycling-by-design deadlines scaling toward 2030 and 2035. Whereas the UK EPR relies heavily on fee modulation (and the separate UK Plastic Packaging Tax for plastics with under 30% recycled content) to encourage better choices, with fewer prescriptive design labels mandated in statute compared to the PPWR.
So how will companies operating in waste packaging in both the UK and the EU comply with the different regulations from 2030? At present, companies will need to operate two sets of different regulations for their packaging and packaging waste for the UK and EU. If a UK business sells products into the EU market, that specific packaging must comply with EU PPWR labelling and recyclability grading (A-C) standards, meaning dual-market products often require separate or multi-compliance layouts.
It should be noted that under the recently published EU PPWR Guidance plastic packaging must include specific minimum percentages of post-consumer recycled plastic (e.g. 30% for PET contact-sensitive packaging by 2030). Empty space in e-commerce, transport, and grouped packaging is capped at a maximum 50% ratio, and deceptive “false bottom” or double-walled packaging is prohibited to minimise waste volume, and standardized sorting labels and digital QR codes will appear on packaging and waste bins to ensure clear, cross-border consumer recycling instructions starting around 2028. There will also be enforced early bans and strict thresholds on harmful chemicals in food-contact applications, including limits on PFAS (“forever chemicals”) and heavy metals like lead and cadmium. pEPR in the EU will require manufacturers, importers, and e-commerce sellers shipping into the EU to register with national packaging registries, report material volumes, and pay fees scaled to environmental performance.
Should you wish for more guidance on pEPR and PPWR application to packaging and materials recycling please contact Paul Frith at Frith Resource Management https://www.frithrm.com/.