Last updated: January 2, 2026

EU Packaging and Packaging Waste Regulation (PPWR) Timeline for Apparel & Footwear Brands

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January 2, 2026

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: The regulation entered into force in February 2025 and is already law. General application – meaning companies must actively comply – begins 12 August 2026. Requirements are phased in over the years.

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.

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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.

PPWR EU: Which Fashion Brands Are Affected?

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.
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.

EU PPWR: Types of Packaging Covered

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.

Packaging EPR Compliance From 2026

While all EU states already have Extended Producer Responsibility (EPR) systems for all packaging, PPWR will standardize requirements across the EU. From August 2026, these harmonized rules will replace national legislation to strengthen waste reduction and recycling efforts.

Every brand selling in the European Union will have to:

Step 1 – Register in every EU country where they sell into.

Non-EU brands placing packaging on the EU market must appoint an authorized representative for EPR in each Member State they sell into.

Step 2 – Report annually

Today, each Member State's PRO defines its own producer register, with its own data fields, ID formats, and onboarding flow. From August 2026, PPWR sets common minimum requirements for these national registers – same producer definition, same data points.

The Commission will publish an implementing act setting the harmonised producer register and reporting formats. That act is still pending. Until then, brands continue to use each PRO's existing format.

Step 3 – Pay the fee: weight × material base rate × eco-modulation coefficient

Weight – total kilograms of each packaging material placed on the market in that country per year
Base rate – a fee in €/tonne set by the national PRO, which varies significantly by country and material.
Eco-modulation – a multiplier applied based on recyclability.

Fee increase incoming: From August 2026, EPR fees apply but are based on each country's existing national rules. The Commission has until January 2028 to publish the criteria defining recyclability grades A, B, and C (more on that in the next chapter). Once published, member states have 18 months to update their national EPR fees accordingly, so packaging with the worst letter will pay more in EPR fees. France, Belgium, and Italy already apply this nationally.

EU PPWR Timeline for Apparel & Footwear Packaging

The PPWR sets the EU-wide framework for packaging design, content, labeling, and end-of-life. But the regulation leaves much of the technical detail to delegated and implementing acts that the Commission is publishing through 2028. This means that the requirements will be phased in over time.

Here is the timeline of requirements apparel and footwear brands should keep in mind:

Timeline	PPWR Requirement
August 2026	EPR obligations begin.
January 2028	Design-for-Recycling (DfR) criteria published: the EU defines what makes packaging Grade A, B, or C – based on material, design, inks, adhesives, and labels. Brands then have until January 2030 to audit every packaging SKU and redesign anything below Grade C.
February 2028	Sales packaging – shoeboxes, garment boxes, premium retail boxes – must be sized to the product, with empty space reduced to what's necessary for protection and handling. Fillers (tissue, air cushions, bubble wrap, foam, polystyrene chips) count as empty space, not as fill.
August 2028	All packaging on the EU market must show a harmonized EU label indicating its material composition for consumer sorting. The exact label design is still to be set by the Commission (expected by August 2026). National schemes like the French Triman will be replaced by the harmonized EU-wide label. Transport packaging is exempt, except for e-commerce shipping.
February 2029	Any packaging the brand operates as reusable (returnable totes, reusable garment bags) must carry a "reusable" label and a QR code with reuse-system info, return points, and trip count. To qualify, the packaging has to be designed for multiple rotations, cleanable between uses, recyclable at the end of life, and run inside a formal reuse system. The minimum number of rotations per format will be set separately (expected by February 2027). Without the label, packaging cannot count toward the 2030 reuse targets.
January 2030	All packaging must be designed for minimum weight and volume. No double walls, false bottoms, or unnecessary layers – unless the design or trademark was legally protected before February 2025. Brands document compliance against 8 performance criteria (product protection, logistics, hygiene, recyclability, etc.).
January 2030	All packaging on the EU market must meet at least Grade C by design. Anything below Grade C is treated as non-recyclable and banned.
January 2030	Plastic packaging must contain a minimum share of post-consumer recycled content: 35% for non-contact-sensitive formats (polybags, mailers, plastic film, hangers), 30% for contact-sensitive PET, 10% for contact-sensitive other plastics. Measured as an annual average per manufacturing plant per category, so brands rely on supplier certification. Plastic parts representing less than 5% of total packaging weight are exempt.
January 2030	Empty space in grouped, transport, and e-commerce packaging cannot exceed 50%. Fillers (paper cuttings, air cushions, bubble wrap, foam, polystyrene chips) count as empty space.
January 2030	At least 40% of the transport packaging a brand uses each year – pallets, plastic crates, IBCs, pallet wrappings, straps – must be reusable within a formal reuse system (e.g. EuroPool). Cardboard outer cartons are exempt.
January 2030	At least 10% of the non-cardboard grouped packaging a brand uses each year must be reusable.
January 2030	Transport packaging used between a brand's own sites, between companies in the same group, or between operators within the same EU country (e.g., factory-to-warehouse, warehouse-to-retailer within Germany) must be 100% reusable. Cardboard, pallet wrappings, and straps are exempt.
~ Mid 2031 (earliest)	The harmonized A/B/C recyclability grades must modulate EPR fees in every EU country. A Grade C polybag will pay meaningfully more than a Grade A polybag in every Member State.
January 2035	Packaging must demonstrate it is actually collected, sorted, and recycled at scale through real infrastructure, not just theoretically recyclable by design. DfR criteria updated to reflect real-world recycling performance.
January 2038	Recyclability tightened to Grade A or B. Minimum acceptable recyclability grade raised. Grade C packaging no longer permitted on the EU market.
January 2040	Minimum post-consumer recycled content rises: 65% for non-contact-sensitive plastic packaging (most apparel formats), 50% for contact-sensitive PET, 25% for contact-sensitive other plastics.

PPWR for Fashion: What Is Decided at EU Level vs. Nationally

PPWR is an EU Regulation, so it applies directly in every Member State without national transposition. The implementation layer, by contrast, is national: each Member State runs its own EPR register, sets its own fees, operates its own collection and recycling infrastructure, and enforces its own penalties.

The regulation also sets binding EU-wide recycling targets that Member States must achieve through national infrastructure:

65% of all packaging waste will be recycled by the end of 2025
70% by the end of 2030.

Material-specific sub-targets for 2030 include 55% for plastic and 85% for paper and cardboard – the two materials most relevant for apparel and footwear packaging. The table below shows what is decided by Member States vs the EU to achieve these targets:

Topic	EU level	National level
Core requirements	All packaging rules set by EU – empty space, recyclability grades, recycled content, reuse targets, labeling.	Member States cannot block compliant packaging or set conflicting national rules.
Recyclability grades (A/B/C)	Defined by Commission delegated acts (due Jan 2028), uniform across all countries.	None.
EPR registration	Mandatory for all brands placing packaging on the EU market.	Each country runs its own register; brands register country by country.
EPR fee amounts	Not set by EU, but fees must be "transparent, proportional, non-discriminatory and efficient".	Each country sets its own €/tonne rates per material.
EPR fee modulation	From ~mid-2031 (earliest), national fees must be modulated by the harmonized A/B/C grades.	Until then, each country applies its own eco-modulation (France, Belgium, and Italy already do).
Labeling format	Standardized EU pictogram mandatory from August 2028.	National packaging labels (Triman, Green Dot) may need to be aligned with the new harmonized EU labeling system.
Enforcement & fines	Penalties must be "effective, proportionate and dissuasive", amounts not set.	Each country sets its own fine levels and enforcement.
Recycling infrastructure	EU sets targets, for example, 70% of all packaging waste recycled by 2030.	Member States build and run collection, sorting, and recycling infrastructure to make sure they achieve those targets.
EPR reporting format	Commission to set harmonized format via implementing act (due Feb 2026, currently delayed).	Countries use their own reporting format until a harmonized format is enforced.

EU PPWR: 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.

Sustainability reporting for apparel and footwear Measure your product-level impact Generate audit-ready reports Stay compliant with CSRD, DPP, AGEC

References

Packaging Waste Regulation – European Commission

Lidia Lüttin,

Lidia Lüttin is the Head of Marketing at Carbonfact, where she amplifies the company's message, ensuring that apparel and footwear brands seeking to minimize their environmental footprint can easily find an ally in Carbonfact. She focuses on educating Carbonfact's clients on textile regulations, material footprints, and decarbonization. Working closely with sustainability-forward brands, such as ARMEDANGELS, Allbirds and On, Lidia helps share their experiences with other brands to foster learning and progress across the industry. Driven by a passion for tech and a desire to fight climate change, she is proud to contribute to a platform that helps the fashion industry decarbonize.