Written by IngChang Tan
Summary
The Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025, with its core obligations applying from 12 August 2026. The legislation aims to achieve the following key objectives:
- Reduce packaging waste
- Encourage circular packaging solutions
- Restrict PFAS in food-contact packaging
Set to be implemented in stages, the restriction on PFAS in food-contact packaging applies from August 2026. Harmonised EU sorting labels become mandatory by 2028, and minimum recycled plastic content requirements take effect by 2030. These measures align with broader EU efforts to improve raw material efficiency and strengthen resource independence.
Administrative and Regulatory Impact
A key area of discussion surrounding PPWR implementation involves existing stock and labelling requirements. As it stands, packaging placed on the market before 12 August 2026 may generally be sold through without a strict cut-off date. However, it must carry a unique identifier—such as a batch or type number—to meet baseline physical or digital traceability standards.
Labelling requirements considered misleading and environmental claims are being enforced alongside secondary anti-greenwashing rules. However, there remains ambiguity and confusion over recyclability threshold and sustainability claims. Thus creating a reporting, labelling, and bureaucratic headache for many businesses. Consequently, several companies with strong sustainable reputations have reported to have self-opted to remove claims and labels of sustainable products from their packaging to bypass this ambiguity and reduce their legal risk.
What does it mean for ASEAN business?
All exporters shipping consumer goods into the EU—whether selling through B2B/wholesale channels or directly to consumers—are affected regardless of their country of origin. This has direct implications for major ASEAN export sectors, including seafood, coffee, palm oil, fresh produce, textiles, etc.
Exporters should note that traceability requirements under general EU food safety laws do not satisfy PPWR compliance; separate documentation and traceability tracking are required specifically for packaging material. Additionally, specific rules banning single-use plastic packaging for unprocessed fresh fruits and vegetables under 1.5 kg are set to take effect, with detailed exemption guidelines expected from the European Commission.
Furthermore, ASEAN manufacturers exporting raw packaging materials (such as paper, boxes, and plastic films) into the EU must ensure their products meet PPWR substance restrictions, maintain accurate technical documentation (Declarations of Conformity), and fulfill all applicable batch traceability requirements.
A FAQ published by the European Commission on PPWR can be found here. Alternatively, contact us directly for more information on PPWR labelling and certification.
