EU Packaging & Packaging Waste Regulation: Global EPR Shift

Ascentium India

October 12, 2026

EU Packaging and Packaging Waste Regulation (PPWR)EU PPWR Regulation EU Regulation 2025/40 Packaging Waste Regulation

For decades, packaging materials were treated as waste. The regulations focused on what happens to packaging ‘after’ use, that is, collection, sorting, and disposal of the packaging waste. This approach, however, is currently undergoing a major transformation – gravitating towards preventing waste rather than managing it. Regulators are now focusing upstream, asking a much harder question – ‘How is the packaging designed in the first place?’ The newly introduced EU Packaging and Packaging Waste Regulation (EU PPWR), applicable from August 12, 2026, is the clearest expression of the latest shift. It will affect all packaging suppliers, manufacturers, producers, retailers, and waste management companies for packaging made from any material placed on the EU market. For business leaders, this shifts packaging from an operational decision to a strategic issue.

EU Packaging and Packaging Waste Regulation: Understanding the Framework

The EU Packaging and Packaging Waste Regulation is a more comprehensive framework, covering the lifecycle of packaging material, from substance restrictions, recyclability, recycled content, and minimisation to labelling, reuse, and producer responsibility. Its reach is broader as it applies to all packaging placed on the EU market. Companies outside the EU will be affected, either directly or through the customers and supply chains they serve.

The EU Regulation 2025/40 is supported by the following key pillars:

Waste Prevention and Minimisation

The regulation aims to make supply chains more sustainable and reduce packaging waste at source by minimising unnecessary and excessive packaging material.

Graded Recyclability and Recyclability at Scale

Packaging must be designed with end of life in mind. The packaging material will be assigned grades like A, B, and C, depending on recyclable mass. Anything below grade C will be banned by 2030. The vision shifts from packaging material being theoretically recyclable to being practically recycled ‘at scale’ using established European infrastructure.

Recycled Plastic Packaging Content

The new framework establishes a legal minimum threshold for Post Consumer Recycled (PCR) content in plastic packaging. It necessitates transparency for sourcing, procurement, traceability, and supplier documentation. It is not enough to use recycled content; businesses must back claims with evidence.

Reuse and Refill

The EU Regulation 2025/40 reflects the growing conviction that recycling alone is not enough. It prioritises keeping packaging material longer in circulation through reuse and refill.

Restrictions on Certain Packaging Formats

There is a ban on certain packaging materials containing toxins, including non-polymeric PFAS. The changing regulatory landscape requires businesses to review existing packaging portfolios now rather than face regulatory violations later.

Labelling, Packaging Information, and Traceability

The EU Packaging and Packaging Waste Regulation aims to harmonise packaging information and data for effective compliance and recycling. Good packaging data is becoming as important as a good packaging design.

Why EPR is not Enough: Why the EU Introduced the EU Packaging and Packaging Waste Regulation

A question that surfaced after the EU Regulation 2025/40 was introduced: Why do we need a new regulation when the Extended Producer Responsibility guidelines are already present? The answer lies in their approach. Extended Producer Responsibility (EPR) focuses solely on managing the end-of-life disposal of packaging material rather than upstream design and material standards.

Its principles were clear, but its implementation was not. Jurisdictions vary widely in the scope of targets, registration, reporting, financing, and enforcement. The EU Packaging and Packaging Waste Regulation places greater emphasis on upstream packaging decisions. It now governs how packaging is designed and proven compliant: recyclability, recycled content, minimisation, substance restrictions, and labelling.

Comparison between the Current EPR and EU Regulation 2025/40

EPR is highly localised, while the EU Regulation 2025/40 harmonises the standards and makes them evidence based. What they share is a direction: greater producer responsibility and a closer link between EPR, waste management, and circularity.

Why Global Businesses Should Pay Attention

The impact of the EU Packaging and Packaging Waste Regulation will travel beyond the geographical boundaries of Europe to impact global businesses in more than one way. Exporters of packaged goods to the EU, Indian manufacturers serving European customers, and packaging manufacturers supplying EU-bound products will encounter its requirements, often first through customer questionnaires, supplier audits, and contractual specifications.

Additional challenges include:

Managing multiple and evolving packaging regimes at once
Expanding capabilities for regulatory mapping and packaging data management across markets

EU Packaging and Packaging Waste Regulation and Indian Business Leaders

Indian companies may find themselves answering a new set of questions on the recyclability of the plastic used in packaging ahead of the next shipment. These questions are coming from European buyers tightening supply chain requirements with the EU Regulation 2025/40 coming into effect.

Indian companies will experience changes whether they are:

Selling packaged goods directly in the EU market.
Supplying components, private-label goods or contract-manufactured products to European counterparts.
Supplying packaging materials (films, cartons or components) into EU-bound supply chains.

EU PPWR compliance for exporters requires Indian suppliers to meet their own EPR obligations.

EU PPWR vs India EPR Packaging: From Plastic EPR towards Packaging Circularity

The EU and India have taken different regulatory routes, but their destinations increasingly overlap.

Dimension	EU Regulation 2025/40	India EPR
Regulatory approach	Single, directly applicable regulation covering the full packaging lifecycle	Plastic waste rules and EPR guidelines, evolving through amendments
Waste prevention	Explicit focus on recyclability and reusability of packaging material focused on minimization of waste	Growing focus, alongside restrictions on certain single-use plastic items
EPR	One of the pillars within a wider framework	Central compliance mechanism for plastic packaging
Recyclability and recycled content	Design-for-recycling and recycled-content requirements	Establishes recycled-content requirements for specified plastic categories
Reuse and refill	Strongly emphasised	Emerging, largely enabled through EPR pathways
Restrictions	Restricts specified formats and uses	Mostly regulates single-use plastic items
Information and data	Sets clear expectations for labelling, information, and traceability expectations	Registration, reporting and documentation through the EPR portal

The two frameworks are not identical in structure, but they are moving in a broadly similar direction — toward prevention, recyclability, recycled content, and better data, not just downstream waste management.

Where the Change Will Actually Happen

For Indian companies, the transformation due to the EU Packaging and Packaging Waste Regulation will be reflected in:

Recycled content evidence shifting sourcing and procurement from a cost conversation to a traceability one.
Scrutiny of certain packaging materials (laminates, mixed-material pouches, non-recyclable coatings) prompting Indian exporters to reassess packaging portfolios against applicable EU Regulation 2025/40 requirements.
Restrictions on excessive packaging, requiring design optimisation.
Harmonised labelling rules making marking, documentation, and data part of packaging design.
Indian companies’ own compliance becoming essential to supporting EU customers’ obligations.

From EPR Compliance to Packaging Circularity

This is where leadership makes a difference. Companies already making this move are advancing in the following directions:

Shifting focus

Treating packaging as a cross-functional issue rather than a compliance line item. Mapping a packaging portfolio, identifying materials, formats, components, quantities, suppliers, and markets.

Getting ahead of customer questionnaires

Understanding what applies across the EU, India, and other key markets.

Prioritising supplier-level packaging data

Tightening data collection and management at the source. Building reliable channels and gathering information on composition, recycled content, recyclability, and volumes.

Review existing processes

Testing existing materials against evolving guidelines, defining the evidence required from packaging and material suppliers, and exploring redesign opportunities.

The Larger Point

The packaging regulation has quietly rewritten its own purpose. It has shifted from asking how best to handle waste to asking a design question: Why does this packaging exist in this form at all, and could it exist better?

The EU Packaging and Packaging Waste Regulation makes that shift binding. The trajectory is clear: waste management → EPR → packaging design → circularity. For Indian businesses, this is not a distant European development to monitor from afar. EU importers carry obligations that flow backwards through their supply chains. India’s own EPR framework, evolving steadily from plastic waste rules towards broader circularity thinking, shares the same underlying direction even as its mechanics differ. Companies that act early, invest in reliable packaging data and embed circularity into everyday decisions will not only meet requirements but also contribute to a more resilient supply chain.

Why Choose Ascentium India?

As the EU Packaging and Packaging Waste Regulation pushes companies to rethink packaging, Indian companies need more than just a checklist. They require a structured approach to map material, trace recycled content, and build supplier data systems that hold up to scrutiny. Ascentium India’s ESG services help companies to exactly navigate this transition, regulatory mapping with EU PPWR compliance for exporters, Extended Producer Responsibility packaging rules, and packaging data management and reporting. By partnering with us, businesses can move beyond reactive compliance towards proactive circularity, turning packaging from a regulatory burden into a strategic differentiator. To learn more about our services, please email us at in-info@ascentium.com or reach out to us via WhatsApp at (+91) 77380 66622.

Authored by:

Joyeeta Sinharay | Sustainability & ESG

FAQs

1. What are the new packaging guidelines in EU packaging and packaging waste regulation?

The EU Packaging and Packaging Waste Regulation primarily focuses on:

Recyclability: All packaging materials must be recyclable by 2030.

Recycled content: Plastic packaging material should meet the minimum recyclable content threshold.

Banning PFAS: The EU Regulation 2025/40 restricts the use of PFAS in food content packaging.

Waste reduction: Targets to reduce per capita waste by 5% by 2030.

Reuse: Increase the reusability of packaging materials and promote circularity.

Labelling: The EU Packaging and Packaging Waste Regulation harmonises materials and reuse labels follow from 2028.

2. What is the Extended Producer Responsibility (EPR) packaging rules in the EU?

The EU Packaging and Packaging Waste Regulation requires producers to establish EPR compliance in every member state where packaging enters the market. Producers can meet these obligations through any of the following approaches.

Fulfil compliance obligations directly through individual scheme
Join a producer responsibility organization (PRO) in each relevant market to meet compliance collectively
Designate an authorised representative where the producer has no local establishment. This also applies to online sellers
Proactively redesign for recyclability, reuse, and recycled content to align with Extended Producer Responsibility packaging rules and avoid future compliance risks

3. Who does the EU Regulation 2025/40 apply to?

The EU Regulation 2025/40 covers economic operators across the packaging value chain including:

Manufacturers
Suppliers
Importers
Distributors
Final distributors
Authorised representatives
Fulfilment service providers
Producers placing packaged goods on the EU market

The regulation also affects companies outside the EU that export packaged products to EU member states.

4. What are the mandatory recycled content and reusability targets under EU PPWR?

Under the EU Packaging and Packaging Waste Regulation (PPWR), businesses are required to both reduce packaging waste and increase packaging reusability. By the beginning of 2030, the regulation mandates that plastic packaging materials must contain specified levels of post-consumer recycled content ranging from 10% to 35%. In 2040, the requirements become more stringent, with recycled-content levels rising to between 25% and 65%.

The second focus is on the reusability of packaging materials. For transport and logistics packaging, economic operators must ensure that at least 40% of packaging is reusable by 2030, with the target increasing to 70% by 2040.

5. What is the difference between packaging and packaging waste regulation and Extended Producer Responsibility packaging rules?

The EU Packaging and Packaging Waste Regulation (PPWR) and the EPR differ in both in scope and ambition. The EPR primarily imposes operational responsibility on producers for collection, recycling and disposal of packaging material once they reach end-of-life. EU Regulation 2025/40, however, takes a broader lifecycle approach. Beyond waste collection and recycling, it sets requirements for packaging design, recyclability, recycled content, reuse systems, labelling, and waste prevention.

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