Status: ✅ Approved EU law
From August 2026, the Packaging and Packaging Waste Regulation (PPWR) will start introducing European Union–wide requirements to reduce the environmental impacts of packaging across its lifecycle. The regulation sets the objective that all packaging placed on the EU market must be recyclable by 2030 and compatible with the EU collection and recycling systems.
For apparel and footwear brands, the PPWR applies to packaging formats such as shoe boxes, polybags, protective packaging, and e-commerce shipments. It establishes rules on recycled content in plastic packaging, limits on empty space, labeling requirements, and Extended Producer Responsibility.
Let’s dive into the new requirements!
TL;DR
- What: Establishes new standards and targets for all packaging materials. The goal is to use less packaging, minimize (and in some cases, ban) single-use plastics, and adopt more circular packaging solutions. Harmonizes national packaging EPRs across the EU member states.
- Who: All brands placing packaging or packaged products on the EU market. Applies to EU and non-EU apparel and footwear brands, B2B and B2C.
- When:
- August 2026: Obligations start to apply, including harmonization of national packaging EPR schemes. Brands must also start preparing for the 2030 requirements.
- 2030: All packaging must be recyclable and meet a minimum recyclability performance grade. Plastic packaging must meet minimum post-consumer recycled content thresholds, while grouped, transport, and e-commerce packaging must comply with the 50% maximum empty-space limit.
- By 2030 and 2040: EU Member States must reduce per-capita packaging waste by 5% by 2030, 10% by 2035, and 15% by 2040, compared to 2018 levels.
What Is the Packaging and Packaging Waste Regulation?
The Packaging and Packaging Waste Regulation (PPWR) applies the life-cycle and the waste hierarchy thinking to packaging. The waste hierarchy is the EU principle that prioritizes preventing waste first, followed by reuse and recycling, with disposal as a last resort. Under the PPWR, this means reducing unnecessary packaging and increasing reuse where possible, before relying on recycling.
Meanwhile, the life-cycle thinking considers environmental impacts across the entire life of the packaging. For brands, this translates into compliance obligations and financial responsibility through Extended Producer Responsibility (EPR) schemes.
In practice, the regulation focuses on three core objectives:
Prevent Unnecessary Packaging Waste
The PPWR prioritizes waste prevention by limiting excessive packaging, reducing empty space in transport and e-commerce packaging, and restricting single-use packaging.
Improve Recyclability and Material Recovery
The Regulation requires packaging to be recyclable and introduces minimum recycled content thresholds for plastic packaging. Together with harmonized labeling rules, these measures aim to improve waste sorting and increase the quality and quantity of material recovered through recycling systems.
Align Packaging Rules Across the EU
By setting EU-wide requirements on packaging design, labeling, and Extended Producer Responsibility (EPR), the PPWR harmonizes different national approaches with a single regulatory framework.
Which Fashion Brands Are Affected by the PPWR?
The PPWR applies to any brand that places packaging or packaged apparel and footwear products on the EU market, regardless of where the brand is headquartered.
This includes:
- EU-based brands selling apparel or footwear in the EU.
- Non-EU brands exporting packaged products to the EU.
- B2C and B2B brands, including direct-to-consumer and wholesale.
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E-commerce brands, where transport and shipping packaging are used.
Under the PPWR, responsibility for packaging lies with the economic operator that places packaging or packaged products on the EU market for the first time.
“Placing packaging on the market for the first time” means the moment a packaged product is first made available in the EU. For example, when an apparel brand sells a garment in a polybag to an EU retailer or consumer, the brand placing that packaged product on the EU market is responsible.
Types of Packaging Covered Under the PPWR
The PPWR defines “packaging” broadly as any material or product used for the containment, protection, handling, delivery, or presentation of goods. This includes packaging placed on the market regardless of its material, format, or sales channel.
For the apparel and footwear industry, packaging covers everything from protective garment bags to e-commerce shipping materials. Let’s take a look at some examples:
- Primary (Sales) Packaging – Refers to the packaging that directly contains and protects the product, typically until it reaches the consumer. This includes garment bags, protective tissue paper, and hang tags or labels.
- Secondary (Grouped) Packaging – Used to group together multiple products, either to protect them or to facilitate handling and transport. Think: multi-pack box cartons for socks and accessories.
- Tertiary (Transport) Packaging – Used for bulk handling, transport, and shipping. This can refer to either B2B packaging, such as pallets and stretch wrap, or B2C cardboard boxes and envelopes.
Under the PPWR, an item is not considered packaging only if it is integral to the product and necessary for its function throughout its entire lifetime.
Key PPWR Requirements for Apparel & Footwear Packaging
Now that packaging in scope has been defined, it is important to clarify how PPWR requirements are structured and how brands should read them. The PPWR sets binding obligations in the regulation itself across areas such as packaging waste prevention, recyclability, recycled content, labeling, and Extended Producer Responsibility.
However, the regulation also leaves many technical details – such as how recyclability is assessed, how empty space is calculated, and how packaging labels must be designed – to delegated and implementing acts adopted by the European Commission. These secondary acts will determine how compliance is measured and enforced, and some requirements only become applicable once these details are in place.
The sections below summarise the PPWR requirements that are already defined in the regulation and relevant for apparel and footwear brands:
Packaging Waste Reduction
In general, each Member State must reduce packaging waste generated per capita vs. 2018 by at least:
- 5% by 2030.
- 10% by 2035.
- 15% by 2040.
These waste-reduction targets apply at the Member State level and may lead to national measures affecting packaging placed on the market.
Extended Producer Responsibility (EPR)
Packaging Extended Producer Responsibility (EPR) is already mandatory across the EU. Under the PPWR, Member States are required to apply fee modulation based on packaging environmental performance.
In addition, the regulation strengthens EU-wide rules on producer registration, reporting, and oversight of Producer Responsibility Organisations (PROs), increasing harmonization across national EPR schemes from August 2026.
Recyclability Standards
From 2030, all packaging placed on the EU market must be recyclable. The PPWR also introduces a recyclability performance grading system (A/B/C), under which packaging must meet a minimum recyclability grade to remain on the market.
From 2038, packaging should be at least grade B in order to be placed on the market.
The detailed grading criteria and assessment methodology will be defined through delegated acts adopted by the European Commission ahead of 2030. Recyclability performance is also expected to influence EPR fee modulation at the national level.
Recycled Content Requirements
From 2030 onward, plastic packaging, such as polybags, hang tags, or plastic wrapping, will need to contain a minimum percentage of recycled content.
For example, by 2030, brands should meet these minimum requirements for recycled content in plastic packaging:
- 30% for contact-sensitive packaging, where polyethylene terephthalate (PET) is the major component.
- 10% for contact-sensitive packaging made from other polymers.
- 35% for packaging other than those listed above (most relevant for fashion companies, as apparel and footwear packaging is not contact-sensitive with exeption of cosmetics).
All recycled content must come from post-consumer waste, which should push brands to find more sustainable sourcing options for their plastic packaging.
PPWR Timeline
Here is the PPWR timeline apparel and footwear brands should keep in mind:
2025
The PPWR enters into force. The European Commission begins developing detailed rules through delegated and implementing acts (e.g., labelling, recyclability criteria, calculation methods).
August 2026
The PPWR becomes applicable across the EU, replacing the Packaging and Packaging Waste Directive. Obligations start to apply, including harmonization of national packaging EPR schemes. Brands must also start preparing for the 2030 requirements.
2026–2029
The Commission progressively adopts more than thirty delegated and implementing acts, clarifying technical requirements such as recyclability criteria, labelling formats, and recycled content calculation rules.
2030: Major compliance milestone
- Only packaging meeting the PPWR recyclability criteria may be placed on the EU market.
- Plastic packaging must meet minimum post-consumer recycled content requirements.
- Packaging must meet a minimum recyclability performance grade to be placed on the EU market.
- Empty space limits apply to grouped, transport, and e-commerce packaging.
2035
- Higher recyclability performance thresholds apply.
- EU packaging waste reduction targets must be met, potentially driving stricter national measures.
2038
Only A&B-rated packaging allowed, phasing out lower-performing types.
Decarbonize Packaging With Carbonfact
Carbonfact is the Environmental platform, built specifically for apparel and footwear brands to measure the environmental impact of their products and take actionable steps to reduce their footprint.
PPWR is not only about disclosure but also about packaging environmental performance over time – recyclability, waste prevention, and recycled content – that will allow brands to avoid non-compliance fines.
Our Product Impact Simulation tool enables you to run what-if scenarios on a product level, where you can experiment with different packaging materials, suppliers, renewable electricity share, or transportation methods, and build concrete company-level decarbonization scenarios.
Lidia Lüttin
