PPWR is now in force: What UK businesses exporting to the EU need to do next
16/07/2026
From today, 12 August 2026, the EU’s Packaging and Packaging Waste Regulation applies in full across all 27 member states. Every business placing packaged goods on the EU market now needs a Declaration of Conformity behind it, and that declaration is only as good as the evidence supporting it. Here is what has changed, who it affects, and why a template borrowed from a supplier or drafted by AI will not be enough on its own.
What Is the PPWR and Why Does It Come Into Force Today?
The Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40, replaces the thirty year old Packaging and Packaging Waste Directive. It was published in the Official Journal in January 2025 and entered into force the following month, giving businesses an eighteen month transition period. That period ends today.
The shift from a directive to a regulation matters. A directive had to be transposed into national law by each member state, which meant twenty seven slightly different versions of the same rules. A regulation applies directly and identically across the whole EU, with no national transposition and no grace period. From today, packaging placed on the EU market must comply with the PPWR’s requirements under Articles 5 to 12, covering restricted substances, packaging minimisation, recyclability, and labelling, or it is not compliant at all.
Who Does the PPWR Apply To?
The Regulation applies to any business placing packaged goods on the EU market, and that includes UK businesses exporting to the EU, not just companies based there. Manufacturers, importers, distributors, and online marketplaces all carry obligations under the PPWR, and the definition of packaging is broad, covering anything used to contain, protect, handle, deliver, or present goods.
In practice, we are seeing the most immediate pressure land on manufacturers exporting to EU customers, construction and building materials suppliers, food and agri-processing businesses, and retail and FMCG brands selling packaged goods into EU markets. If any part of your business places packaging on the EU market, whether directly or through a distributor, the PPWR applies to you now.
What Does a Declaration of Conformity Actually Require?
At the centre of PPWR compliance sits the Declaration of Conformity, a legally binding self declaration confirming that a specific packaging type meets Articles 5 to 12 of the Regulation. Without a valid Declaration of Conformity, access to the EU market is at risk.
The important word is evidenced. A Declaration of Conformity is only as strong as the technical file behind it: material composition data, substance information, recyclability and packaging minimisation assessments, and supplier declarations covering every packaging type placed on the market. The declaration itself is a summary of that evidence, not a substitute for it.
Why Are So Many Businesses Getting This Wrong?
In the run up to today’s deadline, we have seen a familiar pattern across the manufacturing and export businesses we work with. Someone realises, often quite late, that EU customers are starting to ask for a Declaration of Conformity. A colleague finds an example shared by a supplier, or asks an AI tool to draft something, fills in the company name, and circulates it as though the job is done. It looks complete. It reads well. But it is a shopping list of what needs to be true, not evidence that it is true.
This matters because most packaging estates are not uniform. Some product lines are relatively straightforward to assess against the PPWR’s recyclability requirements. Others, particularly multi layer or composite packaging, or products that sit ambiguously between categories such as medical devices and cosmetics, are considerably more complex, and may require supplier data or laboratory testing that has not yet been gathered. Across multiple subsidiaries or brands, even establishing who is legally the manufacturer, and therefore responsible, for each packaging type can take real work to unpick.
The risk is rarely about being stopped at customs on day one. The bigger and more immediate risk is commercial: an EU customer, or the customer’s own compliance team, asks for the evidence pack behind your declaration, and there is not one to hand. That is the point at which a shipment gets held, a contract gets paused, or a supplier gets quietly delisted.
What Should UK Businesses Do in the Next 30 Days?
The starting point is the same one we recommend for any new compliance obligation: a proper diagnostic before anything else. Map your packaging estate, product line by product line, and identify which packaging types, brands, and EU markets are actually in scope. Establish who is legally the manufacturer or producer for each packaging type under the PPWR’s definitions, particularly where packaging is made by a third party but carries your brand.
From there, pull together what evidence already exists. Many businesses hold more of the underlying data than they realise, scattered across regulatory, technical, and packaging supplier files, and the task is often less about generating new evidence from scratch than gathering and structuring what is already there. Classify each packaging type as fully evidenced, partially evidenced, or a genuine gap, and prioritise the gaps by which EU markets and customers are applying the most pressure. Only once that picture is clear should a Declaration of Conformity be finalised and issued.
How Does PPWR Fit Alongside Other EU Green Trade Rules?
PPWR is the first deadline in a wider cluster of EU green trade regulation, not the last. The EU Carbon Border Adjustment Mechanism has been financially live since January 2026, with a UK equivalent following from January 2027. The EU Deforestation Regulation brings due diligence obligations for commodities including cocoa, coffee, palm oil, and wood from December 2026 for larger operators. The proposed Green Claims Regulation, expected later this year, will require environmental marketing claims to be backed by recognised proof. And large company customers subject to CSRD and CSDDD reporting are already flowing sustainability data requests down their supply chains through procurement, regardless of whether their SME suppliers are directly in scope.
For UK businesses trading with the EU, the practical implication is the same across all of these: the businesses that get ahead of the evidence gathering, rather than reacting to each deadline as it lands, are the ones that keep their EU market access secure and their customer relationships intact.
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Frequently Asked Questions
Does the PPWR apply to me if I sell into the EU through a distributor rather than directly?
Very likely, yes. The PPWR’s obligations follow the packaging, not just the route to market. If your goods are packaged before they reach an EU distributor, or if your brand appears on the packaging, you may well be the manufacturer or producer under the PPWR’s definitions, even if a distributor handles the EU end of the sale. This is worth clarifying specifically for your business rather than assuming it does not apply.
What happens if I do not have a Declaration of Conformity in place today?
Technically, packaging placed on the EU market without a valid, evidenced Declaration of Conformity is not compliant from today. In practice, the most immediate consequence for most businesses will come from customers and their compliance teams asking for evidence, rather than from a customs stop on day one. Either way, the priority now is to move quickly to establish your position and close the gap, not to wait for a problem to surface.
Is there a grace period before enforcement begins?
No. The PPWR is a regulation, not a directive, so it applies directly and identically across all EU member states from 12 August 2026, with no national transposition and no formal grace period for this application date. Some specific provisions, such as harmonised labelling and mandatory recycled content, phase in later, between 2027 and 2030, but the core substance, minimisation, and recyclability requirements, along with the Declaration of Conformity itself, apply now.
How is the PPWR different from the UK's own packaging extended producer responsibility rules?
UK extended producer responsibility, known as pEPR, is a separate domestic scheme covering packaging placed on the UK market, with its own fees and reporting to PackUK. The PPWR covers packaging placed on the EU market. A business trading in both directions may need to meet both sets of obligations, and the evidence required for one, such as material composition data, often supports the other, but they are not interchangeable.
Do I need an authorised representative in the EU?
For many UK businesses placing packaging on the EU market, yes, an authorised representative based in the EU may be required to take on certain obligations under the PPWR on your behalf. Whether this applies to you, and who is best placed to act as that representative, depends on your specific packaging estate and EU trading structure, and is worth establishing early rather than at the point a customer asks.