2026 is a pivotal year for packaging regulation in Europe. While the UK has already introduced its new packaging producer responsibility regime, the EU’s Packaging and Packaging Waste Regulation (PPWR) will begin applying from 12 August 2026.
Although both systems share the same broad objective — making businesses more responsible for the environmental impact and waste-management costs of packaging — their scope, compliance requirements and impact on businesses are significantly different.
For companies supplying packaging or packaged products into both the UK and EU, understanding these differences is becoming increasingly important.
A Shared Goal: Extended Producer Responsibility
Both the UK and EU regimes are built around the principle of Extended Producer Responsibility (EPR).
In simple terms, businesses that place packaging on the market are expected to contribute towards the cost of collecting, recycling and managing packaging waste.
Both systems are also designed to discourage unnecessary or difficult-to-recycle packaging by linking producer costs increasingly closely to factors such as packaging volume and recyclability.
Importantly, both regimes adopt a very broad definition of packaging.
This includes not only conventional retail boxes, bags and containers, but also:
- transport and grouped packaging;
- labels and tags;
- packaging components;
- hangers supplied with clothing;
- tubes used to hold film or foil;
- single-serve tea and coffee units; and
- other materials used to contain, protect, transport, deliver or present products.
Businesses should therefore avoid assuming that only obvious retail packaging falls within the rules.
The UK Packaging Regime
The UK’s Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 came into force in January 2025.
The system focuses primarily on producer responsibility, packaging data reporting, recycling obligations and waste-management costs.
The extent of a company’s obligations depends on both its turnover and the amount of packaging it handles.
Larger producers — generally businesses with annual turnover of at least £2 million that handle at least 50 tonnes of packaging — face additional responsibilities, including recycling obligations and associated fees.
Smaller producers may still have data-recording and reporting requirements where the relevant thresholds are met.
Who Is a Producer in the UK?
Under the UK regime, the producer is not necessarily the company that physically manufactures the packaging.
Depending on how the supply chain is structured, responsibility may fall on a:
- brand owner;
- packer or filler;
- importer;
- distributor; or
- online marketplace operator.
Generally, the legislation seeks to allocate responsibility to the business closest to the first supply of the packaging in the UK, avoiding duplication of producer obligations further down the supply chain.
Brand ownership is particularly important.
Where a UK-established company’s own brand appears on filled packaging, that company will normally be treated as the producer.
For multinational corporate groups, however, responsibility can become more complicated. If the legal owner of the brand is outside the UK, another UK-established company within the same group that supplies the branded packaged product may be treated as the brand owner for packaging compliance purposes.
Where no UK group entity makes the relevant supply, responsibility may instead move further down the chain to the UK importer or first UK owner of the goods.
How the EU PPWR Goes Further
The EU’s Packaging and Packaging Waste Regulation (EU) 2025/40, or PPWR, has a considerably broader scope.
Like the UK system, it introduces producer registration, reporting and EPR obligations.
However, the PPWR goes much further by establishing rules covering the entire lifecycle of packaging, including:
design, substances, recyclability, reuse, minimisation, labelling, traceability and conformity assessment.
As a result, PPWR compliance is not simply a waste-management or reporting exercise. It can directly affect whether packaging is legally allowed to enter and be sold on the EU market.
Producer Responsibilities Under the PPWR
Under the PPWR, producer responsibility is generally determined on a Member State-by-Member State basis.
A producer will typically be the first business making packaging or packaged products available in a particular Member State.
Where products are supplied directly from another EU Member State or from outside the EU to a professional or consumer end user, the foreign supplier may itself become the producer.
Producers must therefore assess their responsibilities separately in every EU country in which they first make packaging available.
By 12 August 2026, producers are expected to comply with applicable registration requirements in relevant national producer registers.
Non-EU businesses supplying directly into EU markets may also need to appoint an Authorised Representative in the relevant Member State for EPR purposes.
Producer fees will ultimately become increasingly linked to the recyclability performance of the packaging.
Manufacturers Face Additional EU Obligations
One of the biggest differences between the UK and EU regimes is the role of the manufacturer.
Under the PPWR, manufacturers carry primary responsibility for demonstrating that packaging meets applicable sustainability and labelling requirements.
Depending on the commercial structure, the manufacturer may be the company producing and supplying the packaging or, in certain branded-product arrangements, the company under whose name or trademark the packaging is marketed.
Manufacturers must establish a compliance framework that includes:
a Conformity Assessment, Declaration of Conformity and Technical Documentation.
They must also ensure that packaging can be traced through the supply chain using appropriate identification, such as a type, batch or serial number, together with relevant manufacturer information.
This means PPWR compliance increasingly resembles a product compliance regime, rather than simply an environmental reporting system.
Sustainability Requirements Starting in 2026
Some important PPWR sustainability requirements begin applying from 12 August 2026.
These include requirements relating to:
- minimisation of substances of concern;
- limits on certain heavy metals; and
- restrictions on PFAS in specified food-contact packaging.
Manufacturers will need to address these requirements within their conformity assessment and technical documentation.
Further PPWR requirements will be phased in over the following years.
These are expected to include stronger requirements relating to:
- harmonised recycling labels;
- packaging recyclability;
- recycled content;
- reusable packaging;
- packaging minimisation; and
- maximum empty or void space.
The result is a regulatory framework that will progressively influence not only how packaging is reported, but also how it is designed and manufactured.
UK PRO vs. EU PPWR: The Key Differences
Although both regimes support similar environmental objectives, there are several important differences.
1. Scope of Businesses
The UK regime primarily applies to businesses established in the UK and uses turnover and packaging-volume thresholds to determine the extent of their obligations.
The PPWR has a broader territorial reach and can impose obligations on businesses established outside the EU where they supply packaging or packaged products directly into EU markets.
2. Size Thresholds
The UK framework includes thresholds that reduce or limit obligations for smaller businesses.
Under the PPWR, many fundamental packaging obligations apply regardless of company size, meaning that smaller businesses and e-commerce sellers may also fall within the regime.
3. Product Compliance
The UK system is predominantly focused on EPR, reporting and waste-management responsibilities.
The EU PPWR combines EPR with detailed product-level sustainability and compliance requirements.
This makes the PPWR significantly more demanding for manufacturers, importers and brand owners.
4. Conformity Documentation
The PPWR introduces formal conformity assessment and technical documentation requirements for packaging.
There is no directly equivalent overarching product-conformity framework under the UK producer responsibility regime.
5. Packaging Design
The PPWR will increasingly determine how packaging must be designed, including its recyclability, material composition, empty space, reuse characteristics and labelling.
The current UK regime is much more focused on the producer’s responsibility for packaging waste after products have entered the market.
What Should Businesses Do?
Companies supplying packaging or packaged products into both the UK and EU should avoid treating the two regimes as interchangeable.
A business may have relatively limited obligations under the UK system while facing significantly broader responsibilities under the PPWR.
Businesses should therefore review:
- where their packaging and packaged products are sold;
- which group company acts as producer in each market;
- whether they qualify as a manufacturer, importer or distributor;
- packaging materials and substances used;
- traceability information;
- technical documentation;
- EPR registration requirements; and
- upcoming sustainability and labelling requirements.
This assessment is particularly important for non-EU manufacturers and exporters supplying directly to customers in the European Union.
Conclusion
The UK and EU are moving in the same direction: businesses that place packaging on the market are expected to take greater financial and environmental responsibility for it.
However, the EU PPWR represents a much broader regulatory shift.
The UK regime currently focuses primarily on producer responsibility, packaging reporting and waste-management costs. The PPWR combines those obligations with detailed requirements covering packaging design, materials, sustainability, traceability and conformity.
For businesses operating across both markets, this means that a single packaging compliance strategy may no longer be sufficient.
With the UK rules already in force and key PPWR requirements beginning to apply from 12 August 2026, businesses should review their packaging supply chains, documentation and regulatory responsibilities now.
For manufacturers and exporters in particular, packaging compliance is increasingly becoming part of the product itself — not simply an administrative obligation after the product reaches the market.