New EU packaging rules are arriving – what does PPWR mean for undertakings?

The European Union’s new Packaging and Packaging Waste Regulation (PPWR) entered into force in February 2025, with its provisions generally applicable from 12 August 2026. The Regulation is directly applicable in all Member States, including Hungary, and aims to reduce packaging waste, limit the use of virgin raw materials, and facilitate the transition to a circular economy.

Who is affected?

The Regulation affects all players in the packaging value chain, including manufacturers, importers, distributors, authorised representatives, and undertakings that place packaged products on the EU market. However, the obligations of economic operators differ: manufacturers are primarily responsible for ensuring and documenting compliance, while importers and distributors also have verification and traceability duties.

What does it regulate?

The PPWR governs the entire lifecycle of packaging, from design and manufacture through to waste management. In the long term, the new rules are expected to significantly transform undertakings’ packaging practices, with greater emphasis on the recyclability of packaging, the use of recycled content, reuse, demonstrable compliance with composition and environmental performance requirements, and the introduction of a uniform EU labelling system.

When does it enter into force?

Although the Regulation is generally applicable from 12 August 2026, most product requirements will be phased in gradually. Many of the recyclability requirements, minimum recycled content rules, and certain reuse and packaging minimisation obligations will become applicable from 2030. This does not, however, mean that undertakings can afford to wait until 2030 to prepare.

From 12 August 2026, new compliance and documentation obligations will apply. Food-contact packaging must not contain PFAS substances (“forever chemicals”) in quantities exceeding the limits set out in the Regulation, and the presence of other Substances of Concern (SoC) in packaging must be reduced to the lowest possible level. These include chemical substances that may pose risks to human health or the environment, or that may hinder the safe reuse or recycling of packaging.

What should be done now?

In practice, this means that undertakings should commence preparations immediately.

In this context, it is advisable to: 

• Assess the extent to which the undertaking is affected by the Regulation (as manufacturer, importer, distributor, or in multiple capacities);
• Review the material composition and structure of packaging placed on the market;
• Examine what packaging and material composition data is available from suppliers;
• Prepare for documented proof of packaging compliance;
• Identify packaging that may require modification due to future recyclability or recycled content requirements;
• Review internal data management and record-keeping processes.

One of the most significant practical impacts of the PPWR is expected to be that data relating to packaging will become strategically important. In future, undertakings will need to know not only how much packaging they place on the market, but also precisely what materials their packaging consists of, the extent to which it is recyclable, whether it contains recycled content, and be able to substantiate this with appropriate documentation.

What does PPWR mean for EPR regulation?

The Regulation does not directly amend the Hungarian extended producer responsibility (EPR) system, but it is expected to have a significant impact on its future operation. EU rules place increasing emphasis on so-called eco-modulation of fees, with the aim that packaging that is more favourable from a circular economy perspective (i.e., easier to recycle) will face lower costs, while packaging that is more difficult to recycle will incur higher costs.

On this basis, preparation for PPWR is no longer solely an environmental or compliance issue. Information on packaging composition, traceability, and documentation will increasingly determine undertakings’ costs, EPR obligations, and market access opportunities in the coming years.

Should you require support in interpreting the rules or with preparation, please contact our specialist colleagues.