The Packaging and Packaging Waste Regulation, also known as PPWR (or Regulation (EU) 2025/40), sets rules for packaging placed on the EU market. These rules cover how packaging is designed, what it contains, how it is labelled and how packaging waste is managed in the EU.
This regulation has applied since 12 August 2026 and affects businesses across the packaging supply chain, including fashion brands selling products in the EU. Not sure if you've got everything in order for PPWR? Here are eight signs your brand might not be PPWR-compliant.
1. You don't know your PPWR role
PPWR applies to every link down the supply chain, from the manufacturer to the last distributor. Most of the paperwork falls on the manufacturer, which is often the brand. For fashion, apparel, and textile brands, remember that your role is determined by the packaging. Here are the three important roles that are likely applicable to you:
- Manufacturer: the company whose name or logo is on the packaging. If your brand name is on the box, bag or mailer, this is usually you (even if a factory made it).
- Importer: an EU-based company that brings packaging, or packaged products, into the EU from outside it. Think plain master cartons, pallets, bubble wrap and fillers from a non-EU factory.
- Distributor: the packaging that has already been placed in the EU market and is further circulated by you. If you are, for example, an EU reseller, then under this role the packaging includes retail boxes accompanying other brands’ products that were previously imported by those brands.
- Producer: the manufacturer, importer, or distributor that first makes the packaging available in an EU country. The producer signs up for EPR and pays the fees there (see sign 6).
You can be any or all of these. You can also have different roles for different products or countries.
2. You don't have an EU Declaration of Conformity (DoC)
What is an EU Declaration of Conformity
An EU Declaration of Conformity is a signed document. In it, the manufacturer says, "This packaging follows the PPWR rules." Since 12 August 2026, packaging placed on the EU market needs one.
The DoC is only the top page. Behind it, you need a technical file. This is the proof, such as test reports, material details and supplier papers. You must keep it for at least five years.
Signs of trouble:
- You have never heard of a DoC.
- You have a DoC, but no technical documentation to back it up.
- Your DoC is old, or it doesn't cover all your packaging.
3. You take your suppliers' word for it
Many brands get an email or a short note from a supplier saying, "Our packaging is compliant." That is not enough.
PPWR limits harmful substances in all packaging. For example, four heavy metals (lead, cadmium, mercury, and hexavalent chromium) must total no more than 100 mg/kg. If you are the manufacturer, you are the one responsible – not your supplier.
Signs of trouble:
- You have a supplier's promise, but no test reports.
- You don't know which tests were done, or when.
- You never asked for proof.
4. You forgot about the small parts
Many brands check the main box or bag and stop there. But packaging is more than one item. PPWR also covers the smaller parts, such as:
- Tapes and adhesives (glue)
- Labels and sleeves
- Stickers and printed labels
- Hangtags and the strings or fasteners that hold them
- Tissue paper and inserts
- Inks and coatings
- Moisture control sachets
- Hangers (when sold with a clothing item)
The heavy metal limit applies to each part, not just the whole pack. Cheap tape or brightly coloured ink can cause a problem on its own. Small parts also affect how easy your packaging is to recycle.
5. Your packaging doesn't say who made it
From 12 August 2026, the manufacturer's details must be on the packaging. This means:
- your name, registered trade name or trademark
- a postal address where people can contact you (plus an email or website, where you have one)
- a type, batch or serial number so the packaging can be identified
If you import packaging into the EU, you must also show your own details as the importer. If the packaging is too small, some of this can go on a document that travels with the product.
6. You haven't signed up for EPR in every EU country you sell to
What is EPR
EPR stands for Extended Producer Responsibility. Packaging EPR requires producers to help pay for the packaging waste they create by placing it on the EU market. To do this, producers must register in each EU country where they sell. They usually join a local scheme and pay fees there.
If you sell directly to shoppers in an EU country where you have no base, you may need an EU authorised representative for EPR. This is a local company that registers and reports on your behalf. EU-based brands must appoint one in each other EU country they sell into. For brands outside the EU, such as UK or US brands, each country sets its own rule. Germany, for example, requires one.
Signs of trouble:
- You are registered in one EU country, but you sell to many.
- You sell online to EU shoppers but did not register for EPR anywhere.
- You don't have a representative in countries where you need one.
7. You can't prove your recycled content
From 1 January 2030, plastic packaging must contain a minimum amount of recycled plastic. For most fashion packaging, like polybags and plastic mailers, the target is 35%. This recycled plastic must come from things people have already used and thrown away. This is called post-consumer waste.
That date may seem far away, but the problem exists today, too. If you already say your packaging is "made from recycled plastic," you need proof now. Claims you can't back up can be seen as misleading.
Signs of trouble:
- You have a recycled content claim, but no evidence like a certificate or test to back it up.
- You don't know how much of your plastic packaging is recycled.
- Your supplier can't show where the recycled material came from.
8. Your parcels are full of air
Have you ever opened a big box with a small T-shirt inside? That empty space is a problem that PPWR addresses in an upcoming rule.
Packaging must be kept as small and light as possible while still protecting the product. Further, from February 2028, sales packaging should contain only the empty space necessary to protect the product.
From 1 January 2030, there is a firm limit for e-commerce, shipping and grouped packaging: no more than 50% empty space. Remember: bubble wrap, paper, air pillows, packing chips and other filling material all count as empty space.
Signs of trouble:
- You use one or two box sizes for everything.
- Your parcels are often filled with paper or air pillows.
- You have never measured how much empty space is in your parcels.
Where Should I Start To Become PPWR Compliant?
As we have established, not every PPWR rule starts at the same time. Some rules apply now, while others are coming later. But just because it’s coming later doesn’t mean you can’t start working on it now. Here is what we recommend working through at EdgeComply to ensure your brand is PPWR and Packaging EPR Compliant:
- First, tackle what’s already in place (since 12 August 2026): knowing your role, the DoC and technical file, limits on harmful substances, manufacturer details on packaging, and EPR sign-up.
- Then, focus on what’s coming in 2028 (at the earliest): new EU-wide sorting labels that tell shoppers how to dispose of packaging.
- Finally, start planning for rules coming in 2030 (at the earliest): recycled-content targets for plastic, the 50% empty-space limit, and rules on how recyclable packaging must be.
Conclusion
If you spotted one or more of these signs in your business, don't panic. Start with the rules that already apply. Then plan for 2028 and 2030 so you aren't rushing later.
Product compliance might seem like a mountain to climb, but it’s one worth scaling. It keeps you out of regulatory hot water, builds customer trust, and lays a strong foundation for your brand’s growth. Think of compliance as the quiet engine driving your product’s success: powering you forward, keeping you safe, and ensuring a smooth ride into any market you target.
At EdgeComply, our expert team makes that journey as seamless as possible. By handling the complex, tedious parts of compliance, we free up your time so you can do what you do best: innovate, expand, and build a brand people trust.
References:
- European Union. Regulation (EU) 2025/40 on packaging and packaging waste. Official Journal of the European Union, 22 January 2025.
- Council of the EU. Simplification: Council agrees negotiating stance to cut red tape for small packaging producers. 21 October 2026.
- OneStop ESG. EU Packaging and Packaging Waste Regulation: What Changed for Producers and Importers. 9 September 2026.
- Baker McKenzie. Navigating the PPWR: Insights from the guidance and FAQs published by the EU Commission. 10 June 2026.
- Cooley. Productwise Bitesize: EU Packaging and Packaging Waste Regulation. 27 April 2026.
- Freshfields. An overview of the new EU packaging regulation (PPWR).
- Intertek. EU PPWR requirements effective from August 2026. 2026.
- Latham & Watkins. European Packaging and Packaging Waste Regulation: Summary of Provisions and New Guidance.
- Carbonfact. How the EU PPWR affects packaging for fashion brands. 2 January 2026.
- CIRS Group. How exactly will the EU PPWR be enforced? Official answers to 11 frequently asked questions.
