UK EPR vs EU PPWR: What UK Brands Selling into the EU Need to Do Before 12 August 2026

UK Extended Producer Responsibility and the EU Packaging and Packaging Waste Regulation are not the same thing.

That distinction matters because many UK businesses are treating compliance with one as compliance with the other. It is not. UK EPR and EU PPWR operate under different legal frameworks, cover different obligations, and failing to understand the gap between them could result in packaged goods being refused entry to EU markets from 12 August 2026.

This guide explains what each regime requires, where they diverge, and the practical steps UK exporters should take now.

1) What UK EPR Does

UK packaging EPR is governed by the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, which came into force on 1 January 2025, with PackUK formally launching on 21 January 2025. The scheme is administered by PackUK, a body within Defra, and operates across England, Scotland, Wales, and Northern Ireland.

UK EPR requires businesses that manufacture, import, or supply packaging in the UK to:

• Register with their environmental regulator and report packaging data (tonnages, materials, packaging types)
• Pay waste disposal fees based on the packaging they place on the UK market
• From 2026, pay modulated fees linked to the recyclability of their packaging, assessed using the Recyclability Assessment Methodology (RAM)

The scheme is designed to fund household packaging waste collection and recycling infrastructure across the UK. Large producers (annual turnover above £2 million and more than 50 tonnes of packaging) carry the financial obligations. Small producers (turnover above £1 million, more than 25 tonnes) must register and report data but do not pay disposal fees.

UK EPR does not set rules about what goes on your packaging labels. It does not require material identification codes on the pack. It does not mandate recycling icons, sorting instructions, or disposal text aimed at consumers.

2) What EU PPWR Does

The Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 — entered into force on 11 February 2025. Its main provisions apply from 12 August 2026. Unlike the UK system, PPWR is an EU Regulation, meaning it applies directly across all 27 member states without needing national transposition.

PPWR covers the entire packaging lifecycle: design, composition, labelling, recyclability, reuse, and waste management. From 12 August 2026, businesses placing packaging on the EU market must comply with obligations including:

• Material identification codes under Decision 97/129/EC — these are voluntary at EU level but widely expected by retailers, supply chains, and national regulators. Many national rules effectively require them.
• Packaging minimisation — packaging must be the minimum weight and volume necessary for its function. For grouped, transport, and e-commerce packaging, empty space must not exceed 50%.
• Substances of concern — PFAS in food-contact packaging must not exceed specified limits from 12 August 2026, with no exemption for packaging containing recycled materials.
• Technical documentation and compliance evidence — from 12 August 2026, brands should have the technical documentation and compliance evidence required for the PPWR provisions that already apply to their packaging, while recognising that some detailed recyclability conformity requirements depend on later delegated and implementing acts.
• Recyclability requirements — all packaging must be recyclable by 2030, with phased targets for design-for-recycling criteria running through to 2038.
• Recycled content minimums — mandatory recycled content targets for plastic packaging apply from 2030 and increase through 2040.

The European Commission published its first comprehensive guidance document and FAQ on 30 March 2026, clarifying how to determine whether a company is a manufacturer or producer under PPWR, what counts as packaging, and how PFAS limits are enforced.

3) Why Selling into the EU Triggers a Different Compliance Problem

If your business manufactures packaged goods in the UK and sells them into any EU market, you are placing packaging on the EU market. PPWR applies to you regardless of where the packaging was manufactured.

UK EPR compliance does not satisfy any PPWR obligation. The two regimes have different legal bases, different scopes, and different requirements.

The UK government’s own business guidance states explicitly that UK exporters must comply with PPWR when selling packaged goods into the EU, and that non-compliance could result in goods being rejected at EU borders.

In practical terms, this means a UK brand exporting to France, Germany, Italy, or Spain needs to address:

• EU-level requirements (material codes, minimisation, conformity documentation)
• National requirements that sit on top of the EU framework (see next section)
• EPR registration in each member state where they place packaging on the market

4) Where France, Italy, and Spain Create Extra Labelling Friction

On top of the EU-wide PPWR requirements, several member states have their own national labelling rules that UK exporters must comply with. These are current national obligations, not future PPWR provisions.

France

The AGEC law (Loi Anti-Gaspillage pour une Économie Circulaire) requires the Triman logo and Info-Tri sorting instructions on all household packaging sold in France. Info-Tri tells consumers which bin to use for each packaging component. This has been mandatory since March 2023. The requirements are administered through Citeo, the French PRO. Packaging under 10 cm² may use digital means to provide this information.

Note: the European Commission issued a formal notice (2023) and reasoned opinion (2024) regarding France’s Triman/Info-Tri requirements and their interaction with EU single market rules. The requirements remain in force as a current national obligation.

Italy

D.Lgs 152/2006 (as amended by D.Lgs 116/2020) requires environmental labelling on all packaging released for consumption in Italy — both B2B and B2C. B2C packaging must carry material identification codes and disposal instructions in Italian. The Ministry Guidelines (Decree 360/2022) set out the format. QR codes and digital channels are permitted for some information. This has been mandatory since 1 January 2023.

For multi-layer plastic packaging, Italian practice follows CONAI/MASE guidance in using code 7 under Decision 97/129/EC, though this is not an explicitly named category in the EU Decision itself.

Spain

Royal Decree 1055/2022, Article 13, requires household packaging sold in Spain to indicate the waste fraction or container where packaging waste should be deposited, effective 1 January 2025. Pictograms are common practice, but the law does not prescribe a single pictogram format — producers have discretion over how they communicate this information. Ecoembes pictograms are widely used but are recommended convention, not a legal mandate. Material codes under 97/129/EC are voluntary in Spain.

Other Markets

Germany does not have mandatory on-pack labelling requirements, but material codes are widely expected by retailers and supply chains. The Green Dot is no longer required. EPR registration via the LUCID database is mandatory.

Belgium, Netherlands, and Portugal each have their own PRO systems and varying levels of labelling expectation. Portugal’s Decree-Law 24/2024 references labelling obligations but primary source verification of its detailed requirements remains ongoing.

For more detail on France, Italy and Spain labelling rules: France, Italy & Spain Packaging Labelling in 2026

5) 5-Step Compliance Checklist for UK Exporters

1. Audit your packaging formats and target markets. List every SKU you sell into the EU. For each one, identify the packaging components (primary, secondary, transport), materials, and the specific EU markets where the product is sold.
2. Map material codes. Assign the correct Decision 97/129/EC material identification code to every packaging component. This is the foundation for both EU-level and national labelling requirements.
3. Check country-specific labelling requirements. For each target market, confirm what national labelling is required beyond the EU baseline. France, Italy, and Spain each have distinct mandatory requirements. Do not assume that compliance with one country covers another.
4. Prepare technical documentation and compliance evidence. From 12 August 2026, brands should have the technical documentation and compliance evidence required for the PPWR provisions that already apply to their packaging. Some detailed recyclability conformity requirements under Article 6(4) depend on later delegated acts, so focus first on the obligations that apply from the general application date.
5. Register for EPR in each EU member state. PPWR harmonises EPR requirements across the EU, but registration and reporting remain member-state-specific. Non-EU companies placing packaging on the EU market may need to appoint an authorised representative within the EU.

6) How PPWR Copilot Helps

PPWR Copilot generates structured compliance dossiers that translate your packaging data — material composition, component structure, weight, and target markets — into country-specific labelling guidance, material identification codes, recycling icon requirements, and sorting instructions.

The platform currently supports France, Germany, Italy, Spain, Belgium, Netherlands, Portugal, and other European markets.

A 7-day free trial is available at ppwrcopilot.com.

For brands that need expert assessment of existing packaging artwork against current EU and national requirements, the Label and Artwork Risk Review service provides structured compliance preparation documents across multiple SKUs and markets.

Key Sources

• Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation: EUR-Lex
• European Commission PPWR guidance and FAQ (30 March 2026): EC Environment — Packaging Waste
• Decision 97/129/EC — Material identification codes: EUR-Lex
• UK government PPWR guidance for exporters: business.gov.uk
• UK Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024: legislation.gov.uk
• France – AGEC law / Info-Tri: Decree 2021-835
• Italy – Environmental labelling: D.Lgs 152/2006, D.Lgs 116/2020, Decree 360/2022
• Spain – Waste fraction indication: Royal Decree 1055/2022, Article 13