Packaging Compliance: EU PPWR, EPR, Recycling Symbols, and Substance Restrictions
What is Sustainable Packaging?
Sustainable packaging is designed to minimize environmental impact throughout its lifecycle—from production to disposal. Key characteristics include:
Biodegradability or compostability – Breaks down naturally without harming ecosystems.
Recyclability – Made from materials that can be reprocessed into new products.
Renewable materials – Sourced from responsibly managed resources (e.g., bamboo, recycled paper).
Minimalist design – Uses fewer materials and reduces waste.
Non-toxic inks & adhesives – Avoids harmful chemicals in printing and assembly.
Unlike conventional packaging (think plastic bubble wrap or Styrofoam), sustainable options prioritize long-term ecological health without sacrificing functionality.
EU Packaging Compliance
Packaging compliance in the European Union is evolving from a directive-based framework toward a more harmonized regulatory model. Historically, EU packaging requirements were mainly governed by the Packaging and Packaging Waste Directive 94/62/EC, which established essential requirements for packaging and packaging waste management across EU Member States.
The EU has now adopted the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, which entered into force on February 11, 2025 and will generally apply from August 12, 2026. Unlike a directive, a regulation applies directly in EU Member States, helping create more consistent packaging requirements across the European market.
For companies placing packaged products on the EU market, this evolution means packaging compliance is no longer limited to waste management. Businesses must increasingly consider the full packaging life cycle, including packaging design, material selection, recyclability, recycled content, labeling, extended producer responsibility, waste prevention, and documentation.
Packaging and Packaging Waste Regulation (PPWR)
The Packaging and Packaging Waste Regulation (PPWR) is the EU’s new packaging framework designed to reduce packaging waste, improve circularity, and harmonize packaging rules across the European Union. It applies to packaging throughout its life cycle and affects many economic operators placing packaging or packaged products on the EU market.
Scope
The PPWR covers packaging and packaging waste across many sectors and packaging formats. This may include sales packaging, grouped packaging, transport packaging, e-commerce packaging, reusable packaging, and other packaging used at industrial, commercial, office, retail, service, or household levels.
Packaging Placed on the EU Market
Packaging placed on the EU market must meet applicable PPWR requirements, including sustainability, labeling, and documentation obligations. The regulation aims to ensure that packaging does not create unnecessary risks for the environment or human health and that it supports the EU’s circular economy objectives.
Imported Packaging
The PPWR can also apply to packaging used for imported products. Companies outside the EU that sell packaged products into the EU may need to verify that their packaging complies with EU requirements before those products are placed on the market.
Packaging Minimization
One of the key objectives of the PPWR is to reduce unnecessary packaging. Companies may need to review packaging design to avoid excessive volume, weight, or empty space while still protecting the product and maintaining safety, quality, and functionality.
Recyclability
The PPWR strengthens the EU’s focus on recyclable packaging. Companies should assess whether their packaging materials, structures, inks, adhesives, coatings, labels, and components support effective collection, sorting, and recycling.
Recycled Content
The PPWR introduces requirements for recycled content in certain plastic packaging. The regulation refers to minimum percentages of recycled content recovered from post-consumer plastic waste, depending on the packaging type and format.
Labeling
Packaging labeling requirements are also part of the PPWR framework. Labels may be used to support proper sorting, collection, reuse, recycling, and consumer information. Companies should ensure that packaging claims and labels are accurate, substantiated, and aligned with applicable EU rules.
Extended Producer Responsibility
Extended Producer Responsibility, or EPR, remains a key part of packaging compliance. Under EPR systems, companies placing packaging on the market may have obligations related to registration, reporting, fees, collection, recycling, and waste management financing.
Packaging Waste Reduction
The PPWR supports broader packaging waste reduction goals by encouraging prevention, reuse, refill, recycling, and better packaging design. For businesses, this means packaging compliance should be integrated into product development, procurement, supplier management, and environmental compliance programs.
Packaging and Packaging Waste Directive
Before the PPWR, the main EU legal framework for packaging was the Packaging and Packaging Waste Directive 94/62/EC. This directive covered packaging placed on the EU market and packaging waste generated at industrial, commercial, office, retail, service, household, and other levels, regardless of the packaging material used.
The Directive introduced important concepts such as essential packaging requirements, prevention of packaging waste, recovery and recycling targets, and extended producer responsibility. However, because directives require implementation by each Member State, packaging obligations could vary across the EU.
The new PPWR replaces Directive 94/62/EC and creates a more harmonized regulatory framework. For companies selling packaged products in Europe, this change makes it important to update packaging compliance programs, supplier documentation, packaging specifications, labeling reviews, and EPR assessments.
Why is Compliance Packaging Important?
The environmental and business benefits of sustainable packaging are undeniable:
1. Reduces Environmental Footprint
Lowers carbon emissions from production and transportation.
Decreases reliance on fossil-fuel-based plastics.
Prevents pollution in landfills and oceans.
2. Meets Consumer Demand
3. Complies with Regulations
Governments worldwide are enforcing stricter packaging waste laws (e.g., EU Plastic Tax, U.S. state bans on single-use plastics).
Proactively switching avoids fines and future compliance headaches.
4. Cuts Costs in the Long Run
Lightweight materials reduce shipping expenses.
Recyclable designs can qualify for tax incentives.
Minimized material use = lower production costs over time.
Model Toxics in Compliance Packaging Legislation
This Model Legislation first appeared in 1989 and was known as the Coalition of Northeastern Governors (CONEG) legislation. Overall, their main objective was to reduce the presence of these four heavy metals and their compounds in packaging and its components. Thus, they intended for all the US states to adopt this legislation. However, only 19 adopted it as of 2021. These are the 19 member states of the Toxics in Packaging Clearinghouse (TPCH).
The Model Legislation also took hold in the EU where, for example, the packaging and packaging waste Directive 94/62/EC was instated.
Generally, the requirements for these regulations are to prohibit the intentional use of the four metals in any amount. Additionally, any incidental use of these metals cannot surpass a cumulative sum of 100 ppm by weight (0.01% w/w).
EU Packaging Compliance Requirements: Documentation, EPR, and Substance Restrictions
Key Compliance Requirements Substance-Restricted Packaging Compliance:
1. Management of Declarations of Conformity:
Importers and manufacturers collect and manage declarations of conformity from packaging suppliers. These documents confirm compliance with the EU’s stringent substance restrictions and environmental criteria.
2. Extended Producer Responsibility (EPR):
Importers and manufacturers of goods:
- Register with national authorities in each Member State where they market their products.
- Subscribe to a compliance scheme, which includes reporting packaging quantities placed in every Member State.
- Finance the recycling and disposal of packaging waste, following national regulations and targets the PPWR sets.
3. Provisions in the PPWR:
The PPWR strengthens measures to reduce the environmental and health impacts of packaging waste. These measures include:
- Waste reduction targets.
- Restrictions on excessive packaging, particularly in e-commerce.
- Improvements in recyclability increased recycled content and the elimination of harmful substances such as PFAS (per- and poly-fluoroalkyl substances).
4. Appointment of an Authorized Representative (AR):
Producers appoint an Authorized Representative (AR) to act on their behalf in the EU. One AR represents producers across all EU Member States. These AR obligations align with those for battery waste management but differ from WEEE (Waste Electrical and Electronic Equipment) regulations.
The PPWR harmonizes national regulations and ensures sustainable management of packaging and packaging waste across the EU.
Key Changes in the EU Packaging Regulation - Table 1:
Deadlines to Consider - Table 2:
Other Changes - Table 3:
United States Toxics in Packaging
These laws diverge in the allowable exemptions they allow and the enforcement of their requirements. However, state laws are always precedent over the original Model Legislation.
Additional Requirements to TPCH
In February 2021, the US updated the Model Toxics in Packaging Legislation. The legislation now includes the following substances:
- Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS);
- Ortho-Phthalates, (commonly known as phthalates).
Additionally, they introduced new criteria and processes for regulating and identifying other concerning chemicals in packaging.
Each state will need to adopt these changes within its local laws or issue a new regulation addressing toxic substances in packaging.
China Packaging National Standards
Notably, China has similar standards for packaging used in various applications. For instance, GB 43352-2023 limits heavy metals used in express and mail packaging made of paper, plastic, and textile fibers.
Compliance Packaging with Substance Restrictions: How to be Toxics-Free?
To do so, you can use the free EPEC Enviropass Product Environmental Compliance Form.
EPR Packaging Laws in the United States: What You Need to Know
With increasing concerns about packaging waste, several states in the U.S. have introduced Extended Producer Responsibility (EPR) packaging laws. These laws aim to hold producers responsible for the entire lifecycle of their packaging, from production to disposal. The goal? To reduce packaging waste, promote recycling, and relieve local governments of the financial burden of managing waste.
Under EPR laws, producers must:
- Join a Producer Responsibility Organization (PRO) to manage recycling and waste.
- Report packaging data and pay fees based on packaging volume and sustainability.
- Adopt eco-friendly packaging to reduce waste and minimize costs.
These laws are currently in place in California, Colorado, Maine, Minnesota, and Oregon. While each state has a unique approach, they share the goal of reducing waste and increasing recycling rates. For example, California’s Senate Bill 54 aims to recycle 65% of single-use plastics by 2032, and Colorado’s House Bill 22-1355 mandates that producers fund a statewide recycling program.
By complying with these laws, businesses can avoid penalties, reduce environmental impact, and benefit from a more sustainable brand image.
If you’re unsure of your compliance obligations or need help navigating these regulations, Enviropass can provide expert guidance and support.
Recycling Symbols on Packaging
Packaging should have recycling symbols. The recycling marking discloses whether the packaging is recyclable and provides information about the packaging materials. The table below summarizes different recycling markings used for various types of materials.
Other obligations, like EU REACH on Substances of Very High Concern (SVHC) and Permanent Organic Pollutants (POP), also apply to packages. You can use the EPEC form to cover all Packaging, REACH, TSCA-PBT, California Proposition 65, and POP requirements.
How Enviropass Can Help
Enviropass can help companies assess packaging compliance requirements, review supplier documentation, verify substance restrictions, evaluate PPWR obligations, identify EPR requirements, and prepare compliance evidence for packaging placed on the EU, Canadian, U.S., and international markets.
Packaging Compliance - FAQ
Ask Enviropass to perform compliance assessments for the packaging you use on your behalf, whether it is about labeling, technical documentation maintenance, or simply following up with suppliers.
