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ARTICLE · 03 SEPTEMBER 2026

EU Packaging And Packaging Waste Regulation—what International Corporate Groups Should Know

A&O Shearman
A&O Shearman
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The European Union's new Regulation on packaging and packaging waste has fundamentally transformed compliance requirements for companies placing packaged goods on the EU market, replacing decades-old directive-based frameworks with directly applicable product-law rules. While promising regulatory harmonization across member states, the reality presents a complex dual-compliance landscape where businesses must navigate both EU-wide packaging standards and diverging national implementation approaches.

European UnionEnvironment

For companies placing packaged goods on the EU market, Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste (PPWR) is no longer a future regulatory project. Its core framework has applied across the EU since 12 August 2026. The PPWR replaces Directive 94/62/EC on packaging and packaging waste (Packaging Directive), subject to limited transitional carve-outs, and introduces a directly applicable product-law regime for packaging design, substance restrictions, labelling, conformity documentation, traceability, recyclability, reuse, recycled content and extended producer responsibility (EPR).

Because the PPWR is directly applicable and replaces the Packaging Directive and the national laws that transposed it, businesses could in principle benefit from a single EU packaging framework instead of the previously fragmented national requirements. However, diverging national law remains a central part of the compliance

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