If you run a small or medium-sized business in the EU your packaging will change. Guaranteed.
These new rules will soon restrict what types of packaging you can use. This guide is a starting point to help you avoid fines, high EPR fees, and unsellable stock.
This guide breaks down the three regulations most businesses need to care about:
- PPWR – the new EU rule that decides what counts as recyclable packaging.
- EPR – the rule that determines how much you'll pay for that packaging at end of life.
- ESPR – the rule that demands material transparency and will affect supplier contracts and product data.
Let's go through each simply and with clear "what to do now" steps.
1. PPWR: The Rule That Decides If Your Packaging Is "Recyclable"
PPWR = The Packaging & Packaging Waste Regulation.
The PPWR is the EU's attempt to finally force real recyclability into the market. Most of the regulation will begin in August 2026.
The PPWR mostly affects what you're allowed to use and what counts as recyclable. Because of this, some packaging will disappear from the market and if your products are packed in them, they will disappear too.
The PPWR essentially sorts packaging into three buckets:
"Generally Safe" Choices (most likely to stay compliant)
- Mono-material plastics such as PET, PP, HDPE (as long as they are not colored black, heavily printed, or mixed with liners).
- Fiber-based packaging without PFAS (bags, cups, trays, clamshells with water-based coatings).
- Aluminum — already widely recycled across the EU with robust infrastructure.
- Plain paperboard for dry foods (think pizza boxes without grease-resistant coatings).
"High Risk" / Likely to Become Non-Compliant
- Paper containers with plastic or foil linings bonded into them (e.g., many soup cups, noodle bowls, fast-food wrappers).
- Multi-material trays or pouches (PET + PE + EVOH barriers).
- Anything with PFAS grease-resistant coating — these will be banned from food-contact packaging by August 2026 if they exceed specific thresholds (25 ppb for individual PFAS, 250 ppb for total PFAS, or 50 ppm for all PFAS including polymeric).
- Black or dark-colored PP containers — sorting systems often can't detect them.
"Almost Certainly Out"
- Non-recyclable plastics (PVC, PS/polystyrene foam).
- Plastic-lined paper that can't be delaminated — these fail recyclability tests.
- Compostable packaging that can't be collected or processed locally — the PPWR evaluates recyclability based on existing infrastructure, not hypothetical systems. Most EU municipalities don't accept these containers in organic waste streams, so they end up in general waste.
- PLA and other bioplastics — they contaminate recycling streams and aren't accepted at most composting facilities.
What PPWR means in real life:
- Ask your supplier to supply documentation that their packaging will be PPWR compliant. Begin shifting to packaging that already meets PPWR recyclability scoring.
- Review your current inventory. The August 2026 deadline is closer than it feels.
2. EPR: The Rule to Determine How Much Your Packaging Will Cost You
EPR = Extended Producer Responsibility. The principle is simple: The polluter pays. If your packaging is expensive to collect, sort, and recycle, you pay more.
The new rules mean fees: will increase, will be more directly tied to recyclability, and will punish mixed-material packaging.
What EPR means in real life:
- If it's easy to recycle, fees go down. It's designed to push you toward better packaging choices.
- A PET container may cost more upfront than a cheap paper bowl, but you'll likely pay lower EPR fees on the PET because it's actually recyclable at scale.
- Expect non-recyclable paper/plastic hybrids to become very expensive very fast. These will be hit with higher fees as "eco-modulation" penalties kick in.
- The fees will vary but the direction is consistent: simple, mono-material packaging will cost less; complex, multi-layer packaging will cost more. Very in line with PPWR.
What you should do now.
- Try our PPWR and EPR calculators to begin planning your next generation of packaging.
- Identify the materials with the highest fee bands. If you sell takeaway food, switch anything PFAS-coated or lined with multiple plastics — these will likely face penalty fees. For shipping, reduce empty space or switch box sizes. PPWR plus EPR together will also penalize oversized packaging.
3. ESPR: The Rule to Force Suppliers to Provide Material Transparency
ESPR = The Ecodesign for Sustainable Products Regulation
You will be asked to prove what materials and chemicals are in your packaging.
ESPR extends to virtually all physical products placed on the EU market, with limited exceptions like food and medicine.
This is because ESPR introduces material disclosure requirements, digital product passports, and design-for-circularity criteria for many product groups. These digital product passports will be mandatory for regulated products, providing detailed sustainability information via scannable QR codes or similar technology.
What ESPR means in real life:
You'll need to ask suppliers for things like:
- Material breakdown (e.g., "100% PET," "PP with aqueous coating")
- Confirmation that packaging is PFAS-free
- Confirmation that packaging meets PPWR recyclability criteria
- Documentation on substances of concern
Suppliers who can't give you clear material data will become liabilities.
What you should do now.
- Start requiring material specs from all packaging suppliers — don't wait until it's mandatory.
- Add a line to supplier contracts: "Supplier must disclose material composition and provide PFAS-free documentation where relevant."
- Build a simple spreadsheet of every packaging SKU you use and what it's made of — include columns for material type, recyclability grade (if known), PFAS status, and supplier contact info.
- Request conformity documentation — under PPWR, suppliers must provide an EU Declaration of Conformity for packaging (Annex VIII).
Putting It All Together: How a Small Company Actually Stays Compliant (The Simple Way)
- Choose packaging that is mono-material and actually recyclable in the EU.
Think PET, PP, HDPE, aluminium, plain board + water-based barrier. These materials have established recycling infrastructure and will stay acceptable and have low fees. - Avoid PFAS and multi-layer materials.
Fast-food wrappers, soup cups, and laminated trays are the biggest problem area. PFAS will be banned from food-contact packaging by August 2026. Multi-layer formats will face steep EPR fees and likely fail recyclability tests. - Pressure your supplier for clear data.
If they can't provide a spec sheet, assume the packaging will fail PPWR tests.
Ask for:
- Material composition
- PFAS-free certification (for food-contact packaging)
- Recyclability grade (or at minimum, confirmation it's mono-material)
- EU Declaration of Conformity
- Pay attention to EPR invoices.
If fees rise sharply for one packaging type, switch materials. The fee structure is designed to guide you toward better choices. - Expect stricter rules every year from now to 2030.
The good news? The rules are finally becoming clearer. Aluminum, PET, simple PP, and uncoated paperboard are safe bets. Multi-layer laminates, PFAS coatings, compostable plastics, and foam containers are on their way out.
But the general direction is stable: fewer materials, simpler materials, more transparency.
Choose accordingly.
P.S. We can help you assess your products. Give our free try a tool or contact us with any questions.