A revolution in packaging. How the PPWR Regulation and national reforms will change Polish and European business.

The circular economy is ceasing to be merely a lofty environmental postulate and is becoming a hard, unforgiving foundation of market competition. Businesses operating in the European Union face one of the most radical regulatory transformations of recent decades. Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 January 2025 on packaging and packaging waste, widely known by the acronym PPWR, redefines the rules for designing, placing on the market and accounting for packaging across all sectors of the economy. The act was officially published on 22 January 2025, meaning that following its entry into force on 11 February 2025, the whole of European logistics and manufacturing entered a phase of intense countdown. The key date for the broad application of most provisions has been set at 12 August 2026, leaving management teams little time to adapt their operational structures. Implementation of these regulations coincides with deep, though delayed, domestic reforms in Poland, creating an extremely complex legal and business landscape.

For management staff, operations directors and supply-chain leaders, understanding the mechanisms of the PPWR is key to preserving business continuity. This analysis provides an in-depth look at the impact, scope and implementation timetable of the new provisions, with particular attention to challenges specific to the Polish market.

A new era of environmental regulation: why the PPWR changes the rules of the game

Understanding the revolutionary character of the PPWR requires looking at the legal form of the regulation itself. The EU's previous packaging policy was based on Directive 94/62/EC, which required transposition into the national legal orders of each member state. In practice this led to deep fragmentation of the single market. Individual governments applied different definitions, varying limits on empty space in parcels, and highly specific local labelling systems. A prime and often business-criticised example was the restrictive labelling obligations introduced unilaterally in France, which forced manufacturers to design separate packaging lines for that market. The choice of a regulation as the legal instrument eliminates these discrepancies at source. The new act directly amends Regulation (EU) 2019/1020 and Directive (EU) 2019/904, while repealing the existing Directive 94/62/EC. In addition, Decision 97/129/EC, which sets out the current material identification codes, is scheduled to be phased out from 12 August 2028. This means that from mid-2026 the rules will be uniform from Lisbon to Warsaw, and the absence of national transposition will rule out local easing of the requirements.

The origin of this act is closely tied to the goals of the European Green Deal, the Circular Economy Action Plan and the EU Chemicals Strategy for Sustainability. EU lawmakers aim to fully decouple economic growth from the consumption of natural resources. The scale of the challenge is enormous, since the packaging sector currently accounts for around forty per cent of plastics consumption in the EU, and every average resident of the Union generates around one hundred and eighty-six and a half kilograms of packaging waste per year. To reverse this worrying trend, the PPWR sets binding national targets for reducing the quantity of packaging waste relative to the 2018 baseline year. By 2030, member states must reduce this mass by five per cent, focusing on optimising packaging, eliminating unnecessary single-use formats and banning excessive empty space in e-commerce. By 2035, the reduction is to reach ten per cent through the scaling-up of reusable systems and the automation of return processes, reaching a target of fifteen per cent by 2040, coinciding with the full replacement of virgin plastics with post-consumer recyclate.

Who is responsible for what in the new value chain

The material scope of the PPWR Regulation is characterised by an absence of any material exemptions. All packaging placed on the EU market is, without exception, subject to its provisions, regardless of whether it is made of plastic, paper, cardboard, glass, metal, wood or composite materials, and regardless of the sector in which it is used. The regulation significantly redefines the concept of packaging, extending it in the annexes to products that are designed and intended to be filled at the point of sale. This category includes, among others, paper or plastic shopping bags, disposable plates and cups, cling film, sandwich bags, aluminium foil, and protective film used by dry cleaners. All packaging layers are subject to a technical breakdown, including primary packaging that directly protects the product, secondary packaging grouping retail units, transport packaging that protects goods in logistics, and dedicated shipping packaging used in e-commerce.

In terms of the parties covered, the regulation imposes precise obligations on all supply-chain participants, defining them as economic operators and differentiating their responsibilities. The role of the manufacturer and the owner of the brand under which the product is placed on the market involves conducting a full conformity assessment, drawing up an EU declaration of conformity and preparing technical documentation ensuring the compliance of serial production. The importer, placing products from third countries on the market, becomes the guardian of that compliance at the EU border, bearing the obligation to verify the actions of the foreign manufacturer, retain documentation and physically mark packaging with its own details. The packaging supplier, providing raw materials or semi-finished products, is legally required to provide the full source information needed to demonstrate the compliance of the finished product. The distributor, including wholesalers and retail shops, must in turn verify the presence of the required markings and confirm the manufacturer's registration in the relevant national registers.

Particularly stringent obligations have been imposed on entities engaged in cross-border e-commerce sales and marketplace platform operators. Any company selling products in packaging directly to consumers in another member state must register in the local producer register and regularly report the mass of packaging placed on the market under Extended Producer Responsibility. This entails the need to appoint an authorised representative in every destination country where the company has no physical presence. Although at the end of 2025 the European Commission put forward a proposal to suspend the obligation to appoint authorised representatives for businesses established within the EU until 2035, that proposal still requires final approval, meaning economic operators must be prepared for immediate enforcement of this requirement. At the same time, marketplace platforms will be legally obliged to verify the registration status of their sellers, which in practice means blocking the accounts of non-compliant operators from August 2026. An important element tightening the system is Article 22 on traceability, which imposes on all operators an absolute obligation to identify each supplier and recipient of packaging. This data must be archived and made available on request to supervisory authorities, forcing deep integration of ERP-class systems and product lifecycle management systems.

The critical August 2026 threshold and new chemical restrictions

For economic operators, 12 August 2026 marks a key compliance horizon, the date on which the first absolute bans and procedural obligations take effect. The most radical technical change is the ban introduced by Article 5 on placing on the market packaging intended for contact with food that contains per- and polyfluoroalkyl substances, known as PFAS, above strictly defined thresholds. These so-called "forever chemicals", previously valued for their grease- and water-repellent properties in paper and cardboard packaging, are being drastically restricted. EU lawmakers base these restrictions on precise analysis, setting a maximum threshold of twenty-five parts per billion for any single measurable PFAS compound, with polymers excluded from quantification. For the sum of measurable PFAS compounds this limit is two hundred and fifty parts per billion, while for the total PFAS content, including polymeric forms, the limit is fifty parts per million. Where total fluorine content exceeds fifty parts per million, the manufacturer or importer must prove the origin and exact structure of these compounds.

Regardless of the packaging's intended use, the existing limit on heavy metals is maintained and rigorously enforced. The combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging or its components may not exceed one hundred parts per million. In addition, from mid-August 2026 a ban on bisphenol A in metal packaging and cans in contact with food enters into force, forcing manufacturers to switch immediately to alternative coatings. At the same time, a ban on single-use plastic sachets for condiments, sauces, sugar or small milk portions comes into force for the hospitality and catering sector, provided consumption takes place on the premises. These formats must be replaced with reusable dispensers, although their continued use is permitted in takeaway services and home deliveries.

The conformity-assessment procedure and the DoC declaration as a condition of market entry

From 12 August 2026, the lawful placing of any packaging on the EU market will be conditional on passing a formal conformity-assessment procedure and issuing an EU declaration of conformity, drawn up strictly in line with the template set out in Annex VIII to the PPWR Regulation. This process requires businesses to implement a multi-stage verification procedure. The first step is a full inventory of the packaging portfolio, mapping structures, weights, chemical composition and intended use. Next, destructive laboratory testing for heavy metals is required to confirm compliance with the one-hundred-parts-per-million limit. For food-contact packaging, laboratory analysis of PFAS content and determination of total fluorine content are of key importance.

At the same time, businesses must verify raw-material compliance with the REACH Regulation, substances of very high concern and regulations on persistent organic pollutants, relying on certificates and declarations from suppliers. All test results, technical drawings and descriptions of production processes must be consolidated into a single technical documentation file, which, depending on the type of packaging, must be retained for five years for single-use packaging or ten years for reusable packaging. Only on this basis can an authorised person sign the declaration of conformity for a specific type of packaging, assuming full legal responsibility. It is worth noting that during the transitional period until the end of 2029, the harmonised European standard EN 13430:2004 will remain the basic technical standard for demonstrating packaging compliance with recycling requirements.

Design for recycling and the circular economy after 2030

The next milestones, scheduled for 2030 and beyond, form the second stage of the revolution, aimed at removing hard-to-process materials from the market and promoting full circularity. From 1 January 2030, all packaging placed on the EU market will be assessed against design-for-recycling criteria and classified into performance grades from A to E. For packaging to be allowed onto the market, it must achieve at least grade C, meaning a minimum of seventy per cent of its mass must be recyclable. Packaging with lower performance, classified as grade D or E, will be banned altogether, and in 2038 the requirements will be tightened further, permitting only grades A and B, where the recyclability threshold is eighty per cent.

To stimulate the secondary-raw-material market, from 2030 the PPWR introduces mandatory minimum shares of post-consumer recyclate in the plastic parts of packaging. For contact-sensitive packaging made of polyethylene terephthalate, such as beverage bottles or food trays, the required recyclate share will be thirty per cent, while for contact-sensitive packaging made of other plastics the threshold is set at ten per cent. Single-use plastic beverage bottles will need to contain at least thirty per cent recyclate, and other plastic packaging, including stretch film and stabilising tape, thirty-five per cent. By 2040 these requirements will rise sharply, reaching fifty per cent for contact-sensitive packaging other than PET, sixty-five per cent for bottles and sixty-five per cent for other plastic formats.

Equally revolutionary are the provisions on minimising empty space. From 2030, for transport, secondary and e-commerce shipping packaging, a rigid limit on empty space of a maximum of fifty per cent of the packaging's total volume will apply. The provisions clearly classify all fillers, such as air cushions, bubble wrap or paper scraps, as empty space, and the calculation algorithm will be based on the ratio of packaging volume to the volume of the product itself. In addition, from 2030 there will be a total ban on certain single-use formats, including miniature hotel cosmetics, packaging for fresh fruit and vegetables weighing less than one and a half kilograms, and single-use tableware and cutlery in the catering sector for on-site consumption. At the same time, strict targets for reusable packaging will come into force, requiring, among other things, that at least forty per cent of transport packaging used within the EU and a minimum of ten per cent of beverage packaging operate within closed-loop systems.

The Polish regulatory landscape: EPR, the deposit-return system and legislative delays

For the Polish market, in which around one hundred and thirteen thousand businesses placing products in packaging are registered in the waste database, the EU regulation overlaps with deep and complex domestic legislative processes. The most important element of adaptation is the draft new Act on Packaging and Packaging Waste, marked with the symbol UC100, being prepared by the Ministry of Climate and Environment. This draft envisages the full implementation of a new Extended Producer Responsibility model based on the principle that the entity placing products on the market covers the actual costs of waste management. The new system eliminates the existing free-market recovery organisations in favour of full centralisation of financial flows under the supervision of the National Fund for Environmental Protection and Water Management. This fund will collect a so-called packaging fee from producers and distribute these funds directly to municipalities to finance the cost of municipal collection.

The UC100 draft envisages a two-year transitional period with gradually rising fee rates, to prevent a sudden price shock for consumers. The planned fee rate for plastics is to rise from fifty groszy per kilogram in 2026, through one złoty in 2027, to three złoty in 2028. Similar progressive paths are envisaged for glass, paper, metals, wood and multi-material packaging, with the latter to bear the highest rate, reaching four złoty fifty groszy per kilogram in 2028. Total budgetary revenue is expected to reach a target level of more than five billion złoty annually. However, the legislative process is meeting strong protests from the agri-food industry and jurisdictional disputes, which has led the Ministry to signal that parliamentary work will be pushed back to the second half of 2026. At the same time, the draft lowers the existing, unrealistic recycling targets for municipalities for 2025 from fifty-five to fifty per cent, setting a gentler growth path through to 2029.

Regardless of the delays in the EPR area, since 1 October 2025 a nationwide deposit-return system has been operating in Poland, with 2026 being its first full operational year. From 1 January 2026, beverage producers are required to place on the market only packaging bearing the special deposit graphic mark, with unmarked goods permitted to be sold only until stocks run out. The system covers single-use plastic bottles up to three litres, metal cans up to one litre, and reusable glass bottles up to one and a half litres, with the deposit set at fifty groszy for plastic and metal packaging and one złoty for glass. For hygiene and sanitary reasons, dairy-product packaging has been entirely excluded from the system. Implementing the deposit-return system, however, generates significant systemic challenges. It is estimated that Polish municipalities could lose up to one billion eight hundred and fifty million złoty annually due to the loss of the most valuable raw-material fractions to reverse vending machines, which could translate into a rise in local waste-collection fees for residents of up to fourteen per cent. In addition, transport and collection under the deposit-return system generate a higher carbon footprint, raising CO2 emissions per bottle from five hundredths of a kilogram under municipal collection to fifteen hundredths of a kilogram under deposit-return logistics.

A strict system of administrative penalties and the appeal path

The penalty system envisaged in national draft legislation, and directly linked to breaches of PPWR provisions, is exceptionally strict. Penalties are administrative in nature and are imposed by the Provincial Environmental Protection Inspector by way of a decision, without the need to prove intent on the part of the business. The highest penalties, reaching as much as two million złoty, apply to placing on the market packaging that fails to meet sustainability requirements, including exceeding the chemical limits for PFAS and heavy metals. For procedural failings, record-keeping errors or the lack of a reliable supply-chain traceability system, penalties ranging from ten thousand to five hundred thousand złoty are envisaged.

Failure to meet the statutory obligation to allocate at least two per cent of the net value of packaging placed on the market to public education campaigns will result in a fine of between forty thousand and seven hundred and fifty thousand złoty. Meanwhile, the absence of the required entry in the BDO register while placing packaging on the market is punishable by a fine of up to one million złoty and an immediate order to suspend sales. In addition to the severe financial penalties, supervisory authorities have the power to order the complete withdrawal of non-compliant batches of packaging from the entire EU market at the business's sole expense. The right to impose these penalties lapses after five years from the end of the year in which the breach occurred. Businesses have the right to appeal to the Chief Environmental Protection Inspector within fourteen days, followed by a complaint to the Provincial Administrative Court and cassation to the Supreme Administrative Court.

How to prepare your company for the PPWR

Knowledge of the new requirements alone is not enough. Preparing an organisation for the PPWR requires establishing roles in the supply chain, taking an inventory of packaging, obtaining data from suppliers, preparing technical documentation and declarations of conformity, and putting EPR, BDO, contracts, processes and internal accountability in order.

As part of a comprehensive PPWR implementation, we help translate regulatory requirements into a working compliance system covering law, data, the supply chain, environmental fees, governance and technology.

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Strategic recommendations for company boards

An analysis of the dynamics of the PPWR Regulation's implementation and the Polish regulatory environment leads to an unambiguous conclusion: procurement, design and legal processes in businesses need to be reconfigured immediately. In business practice, the greatest commercial risk falls on the entity placing the finished product on the market – that is, own-label brands, the FMCG sector and distributors. It is their finished product that can be blocked and withdrawn from shelves, which carries catastrophic financial and reputational consequences. For this reason, procurement and quality-control departments can no longer settle for general assurances from packaging suppliers about the compliance of their products with standards. It is becoming a market standard to carry out detailed technical audits at packaging manufacturers and to demand hard, source-based reports from accredited external laboratories confirming that PFAS and heavy-metal limits are not exceeded. Businesses unable to provide such certificates in 2026 will be permanently excluded from supply chains.

Implementing the PPWR requires moving from traditional graphic packaging design to advanced materials engineering, where every milligram of plastic, the type of adhesive used, coating thickness or the ease of label separation determines the recycling classification. This requires integrating internal product-lifecycle management systems with the global GS1 identification standards and preparing the organisation for the roll-out of the Digital Product Passport, which will in future be accessible to consumers and recyclers via QR codes placed directly on the packaging.

To minimise legal and operational risk, company boards should take immediate action in several key areas. It is essential to carry out an immediate audit and inventory of the entire portfolio of packaging placed on the EU market, with particular attention to food-contact packaging. A permanent relationship should be established with accredited laboratories to carry out independent destructive tests for heavy metals and total-fluorine PFAS chemical analyses. It is also necessary to implement formal conformity-assessment procedures, assign personal legal responsibility for signing declarations of conformity, and adapt commercial contracts with raw-material suppliers, introducing rigorous warranty clauses and contractual penalties for failure to meet environmental obligations. Finally, for cross-border e-commerce, a key step is verifying registration status in EPR systems in destination countries and appointing authorised representatives there, to avoid automatic blocking of sales by marketplace platforms in August 2026. Time to act is running out relentlessly, and the winners of this transformation will be the businesses that treat the new regulations not as a costly obligation, but as an opportunity to build lasting competitive advantage in the green economy of the future.

If you need not only an analysis of the regulations but also practical implementation of the PPWR within your organisation, we can support the entire process – from qualifying roles and auditing packaging to documentation, EPR, data, contracts and ongoing compliance monitoring.

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