On 12 August 2026, the new European Packaging and Packaging Waste Regulation, known as the PPWR, will start to apply generally across the European Union.
The Regulation establishes a common framework throughout the EU and covers packaging across its entire lifecycle, from design and composition to marketing, reuse, recycling and waste management. Its scope includes packaging regardless of the material used or the sector involved.
Therefore, this is not simply a regulation aimed at plastic manufacturers or the hospitality sector.
Depending on their role within the supply chain, it may also affect companies that manufacture, import, distribute or market packaged products in the European market.
There is another important point to consider: not all the new obligations start on 12 August. The Regulation establishes a phased implementation timetable that will extend over the coming years. We explain the key points below.
What changes from 12 August 2026?
Regulation (EU) 2025/40 entered into force on 11 February 2025, but its general application begins on 12 August 2026. From that date, it becomes the new European reference framework for packaging and packaging waste.
Its objectives include reducing packaging waste, encouraging reuse, increasing recyclability, reducing the use of virgin raw materials and harmonising certain rules across the European market.
However, this does not mean that every company must immediately change all of its packaging on 12 August.
The Regulation includes obligations with different application dates. Some begin now, while others will be introduced progressively in 2027, 2028, 2030 and subsequent years.
For example, the European Commission has clarified that food-contact packaging placed on the market after 12 August 2026 must comply with the new limits established for certain PFAS substances. Packaging already placed on the market before that date does not have to be withdrawn for this reason.
What types of companies may be affected?
One of the key aspects of the PPWR is the broad range of organisations it may affect.
The Regulation does not only apply to companies that physically manufacture packaging. It establishes obligations for different economic operators depending on their involvement in the manufacture, import, distribution or marketing of products.
In practice, companies should review the Regulation if they:
- Manufacture or commission the manufacture of products that are sold in packaging.
- Import packaged products from outside the European Union.
- Distribute or market packaged products within the EU.
- Use transport or grouped packaging as part of their business activities.
- Market products under their own brand.
Operate in several European countries and need to coordinate their packaging requirements.
The European Commission has also published specific guidance to clarify concepts such as manufacturer, producer, importer and packaging. This is particularly relevant because identifying the role performed by each company may determine which obligations apply to it.
PPWR and the plastic packaging tax: two different obligations that may affect the same company
In Spain, there is another issue that should not be confused with the new European Regulation.
The Special Tax on Non-Reusable Plastic Packaging is a Spanish tax obligation that may affect, among others, manufacturers, importers and intra-Community acquirers of certain products containing non-reusable plastic. In some cases, it also involves registration, documentation and Form 592 filing obligations.
Therefore, the PPWR and the Spanish plastic packaging tax are not the same obligation.
The PPWR establishes a new European framework for packaging and packaging waste, while the Spanish tax applies to certain non-reusable plastic packaging.
However, the same company may be affected by both. For example, a business that brings packaged products into Spain from another EU country may need to review both its obligations under the new European packaging rules and its position regarding the Spanish plastic packaging tax.
A change that should be considered beyond the environmental department
The new European Packaging Regulation will be implemented progressively, but its effects may extend across different areas of a business.
Purchasing, manufacturing, product development, supplier contracts, imports, distribution, taxation and regulatory compliance may all be affected, depending on the company’s activity.
For this reason, the first step is not to change all packaging immediately. Instead, companies should identify their role within the supply chain and determine which obligations apply now and which ones they will need to prepare for in the coming years.
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