EU Packaging Rules: What UK Businesses Selling to EU Customers Need to Know

The EU’s new Packaging and Packaging Waste Regulation, commonly called the PPWR, is now in effect across all EU member states.

The regulation affects UK businesses that sell and send packaged products to customers in the EU. It covers the packaging around the product as well as the packaging used to protect and deliver it.

Importantly, packaging compliance is separate from VAT, customs duty and the value of the goods. A low-value parcel is not automatically exempt.

What is the PPWR?

The PPWR is designed to reduce packaging waste, improve recycling and limit harmful substances in packaging.

It applies to all types of packaging placed on the EU market, regardless of the material used. This includes cardboard, plastic, glass, metal, wood and combinations of different materials.

The rules cover the full lifecycle of packaging, from its manufacture and use through to recycling and disposal.

The legal requirements are set out in Regulation (EU) 2025/40 ↗.

Which UK businesses may be affected?

The rules may affect your business if you:

• Sell products directly from the UK to consumers in the EU
• Supply packaged goods to EU businesses
• Sell through online marketplaces
• Use packaging carrying your own name or brand
• Have packaging manufactured specifically for your products
• Send food, drink, cosmetics or other products in food-contact packaging
• Store or distribute packaged products within the EU

The PPWR applies to packaging, not only to the product inside it. This means packaging requirements can apply even when the product itself meets all relevant EU standards.

What counts as packaging?

The regulation covers more than the box immediately around a product.

It can include:

• Product or sales packaging, such as bottles, jars, packets and retail boxes
• Grouped packaging used to hold several products together
• Transport packaging, such as outer cartons, pallets and protective materials
• Ecommerce packaging used to send online orders
• Packaging components, including lids, labels, tape, inserts and closures

For an online order, there may be several different pieces of packaging that need to be considered.

For example, a glass jar may have a metal lid, a printed label, a cardboard product box, protective filling material and an outer delivery carton.

What should UK businesses do now?

1. Identify all the packaging you use

Create a list of every piece of packaging used to sell and send your products to the EU.

Include product packaging, outer cartons, protective materials, labels, tape and any packaging supplied by another company.

Do not look only at the main box. Individual components can also be covered by the rules.

2. Understand your legal role

Your responsibilities can depend on how your business operates.

If packaging or a packaged product is sold under your company’s name or trademark, your business may be treated as the manufacturer for PPWR purposes.

A UK business selling packaged products directly to EU customers is also likely to be treated as a producer for Extended Producer Responsibility, or EPR.

Where an EU-established business imports the goods, that business may have separate importer responsibilities.

A business can have more than one role, so this should be checked for each sales route and destination country.

3. Obtain evidence from your packaging suppliers

Ask suppliers for evidence showing that the packaging meets the relevant EU requirements.

Depending on the packaging, this may include:

• An EU Declaration of Conformity
• Technical documentation
• Material and composition specifications
• Laboratory or test reports
• Information about restricted substances
• Packaging identification or batch information
• The manufacturer’s name and contact details

If packaging is manufactured under your own name or brand, do not assume that the packaging supplier holds all the legal responsibility.

The full technical file does not normally need to be placed inside every parcel. However, it must be kept available and supplied to the relevant authority when required.

Manufacturers must generally retain documentation for five years for single-use packaging and ten years for reusable packaging. Authorities can request information within a short timescale.

4. Check packaging for restricted substances

The combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 milligrams per kilogram of packaging.

Food-contact packaging also has specific limits for PFAS, sometimes described as “forever chemicals”:

• 25 parts per billion for any individually measured targeted PFAS
• 250 parts per billion for the combined targeted PFAS
• 50 parts per million for total PFAS, including polymeric PFAS

Businesses are not necessarily expected to carry out their own laboratory testing. However, they should obtain reliable evidence from the packaging manufacturer or supplier.

These requirements are contained in Article 5 of the PPWR ↗.

5. Review whether the packaging can be recycled

Packaging placed on the EU market should be capable of being recycled.

More detailed EU design-for-recycling criteria and packaging performance grades will be introduced later. Businesses should not confuse those future grading rules with the basic requirement that already applies.

For now, businesses should review their packaging with suppliers and avoid materials or combinations that unnecessarily prevent recycling.

The European Commission has published guidance on how the PPWR requirements apply during the transition to the later detailed rules ↗.

6. Check EPR requirements in each EU country

Extended Producer Responsibility makes producers financially and operationally responsible for the packaging they place on a market.

EPR registration, reporting and fees continue to be managed at national level. A UK business selling directly to customers in several EU countries may therefore have obligations in more than one country.

Businesses should check:

• Whether producer registration is required
• Whether packaging quantities must be reported
• What fees must be paid
• Whether a local authorised representative is required
• Whether registration numbers must appear on marketplace accounts or invoices

Businesses placing less than 10 tonnes of packaging on a market may qualify for simplified reporting in some circumstances. This is not a general exemption from EPR obligations.

Online marketplaces may also request producer registration numbers or evidence that a seller complies with the relevant national requirements.

7. Keep compliance records organised

Documents should be stored in a way that allows them to be found quickly.

A simple compliance file could contain:

• A list of packaging components
• Packaging supplier details
• Declarations of Conformity
• Material specifications
• Test reports
• EPR registration numbers
• Packaging quantity reports
• Records of any packaging changes

If a supplier changes a material, coating, adhesive or manufacturing process, check whether the supporting documentation also needs to be updated.

Can goods be held at the EU border?

Yes. Customs and market-surveillance authorities can suspend the release of imported goods where required information is missing or there is reason to believe that the packaging does not comply.

This can happen even when the underlying customs declaration is correct.

A correct commodity code, customs value or VAT declaration does not prove that the packaging meets environmental and product-compliance requirements.

EU market-surveillance powers are explained in the EU Market Surveillance Regulation ↗.

Does IOSS cover packaging compliance?

No.

The Import One-Stop Shop, or IOSS, deals with VAT on certain consumer sales. It does not replace packaging compliance, EPR registration or technical-documentation requirements.

The same principle applies to customs duty arrangements. How taxes and duties are collected does not remove the need for compliant packaging.

Are small businesses exempt?

There is no general exemption simply because a business is small or sends only low-value parcels.

Some simplified reporting arrangements and narrow exceptions may be available, depending on the business, packaging quantity and destination country.

Small businesses should therefore check their position instead of assuming that the rules do not apply.

Are all PPWR requirements already fully phased in?

No. Some parts of the PPWR apply now, while other detailed measures will be introduced over several years.

Future requirements include more detailed recyclability grades, harmonised packaging labels, recycled-content targets, empty-space limits and reuse targets.

However, the later introduction of these measures is not a general grace period. Businesses still need to deal with the requirements that currently apply, including restricted substances, documentation, basic recyclability and relevant national EPR obligations.

EU member states are also completing their national penalty arrangements. This does not place the underlying compliance duties on hold.

Practical checklist for UK businesses

Before sending packaged goods to EU customers:

• List every packaging component used
• Confirm who manufactured each component
• Identify your role as manufacturer, producer or exporter
• Request compliance documents from suppliers
• Check heavy-metal limits
• Review PFAS evidence for food-contact packaging
• Review whether packaging can be recycled
• Check EPR registration in each destination country
• Check whether a local representative is required
• Keep registration numbers and technical documents accessible
• Review packaging whenever suppliers or materials change

What this means for UK sellers

Packaging compliance is becoming an important part of selling into the EU.

UK businesses should treat packaging with the same care as product compliance, VAT and customs information. The product, its retail packaging and the ecommerce packaging used to send it can all affect whether goods are accepted onto the EU market.

The most useful first step is to speak to packaging suppliers and obtain written evidence showing what each material contains and which requirements it meets.

Businesses should also review their EPR position separately for every EU country where they sell packaged products.

Further information is available in the European Commission’s PPWR frequently asked questions ↗ and the full EU Packaging and Packaging Waste Regulation ↗.