EU PPWR explained: what UK food & supplement manufacturers must do

If you make food, supplements, cosmetics or pet products and you sell any of it into the EU, the Packaging & Packaging Waste Regulation is now your problem too — Brexit doesn't get you out of it. Here's the plain-English version of what's changing and what to do about it.

What PPWR actually is

PPWR is Regulation (EU) 2025/40 — the EU's new, much tougher rulebook for packaging. Crucially, it's a regulation, not a directive, which means it applies directly and identically across all 27 member states. There's no national version to interpret; the same rules land everywhere at once.

The test for whether it applies to you is simple: does your packaging get placed on the EU market? If a pallet of your product crosses into the EU, your packaging has to comply — regardless of where it was filled. Plenty of UK producers assume this is an "EU company" issue. It isn't. The moment you export, you're in scope.

The headline changes

PPWR is broad, but for a small recipe-based manufacturer it comes down to a handful of obligations that touch your packaging directly:

• PFAS & BPA out of food-contact packaging (Article 5). "Forever chemicals" (PFAS) and bisphenol A (BPA) must be eliminated from packaging that touches food, above defined thresholds. You'll need supplier attestations and, in some cases, test results proving your materials are clean.
• Recycled content minimums. Plastic packaging must contain a minimum percentage of post-consumer recycled (PCR) material, with targets stepping up over time.
• Design for recycling. By the end of the decade, packaging has to be designed to be recyclable against graded criteria — the worse it scores, the more it's restricted.
• Packaging minimisation (Article 10). No more oversized boxes full of air. Empty (void) space in grouped and transport packaging is capped, and every component has to be justified.
• Extended Producer Responsibility (EPR) & registration. You must be registered as a producer in each market you sell into, and pay fees based on the packaging you put on the market.
• Deposit Return Schemes (DRS). Single-use plastic bottles and cans increasingly fall under deposit return obligations.

Five things to get in order now

You don't need to solve all of PPWR this quarter. But you do need to know where you stand, because the first audit question is always "show me your evidence." Start here:

1. Map every piece of packaging you use

For each SKU, list every packaging component — pot, lid, film, label, outer case, shrink wrap — with its material, weight and recycled content. You can't comply with rules about your packaging until you actually know what your packaging is. Most producers discover gaps here immediately.

2. Get PFAS & BPA attestations from your suppliers

Email every packaging supplier and ask for written confirmation that their food-contact materials are free of PFAS and BPA above the regulated limits. Keep the responses on file. Where a material is borderline, you may need a test certificate. This is the single most common thing producers haven't started — and it depends on third parties, so it takes time.

3. Check your void space

Walk your despatch area and look for boxes that are mostly air. Article 10 caps empty space, so oversized outers are a direct compliance risk as well as a cost. Right-sizing packaging is one of the few PPWR tasks that saves you money while ticking a box.

4. Sort your EPR registration

Identify every EU market you sell into and check the producer-registration requirement for each. Registration and reporting obligations differ country by country, and selling without being registered is the kind of gap that gets flagged fast.

5. Keep a Declaration of Conformity and an evidence file

PPWR runs on documentation. For each packaging type you'll want a Declaration of Conformity backed by the attestations, recycled-content figures and assessments behind it. If it isn't written down, as far as an auditor is concerned it didn't happen.

The bottom line

PPWR is a lot of regulation, but the work for a small producer is mostly knowing your packaging, getting paperwork from suppliers, and keeping it all in one place that's ready when an auditor asks. Start the supplier attestations now — they're the part you don't control — and build the rest around a single source of truth rather than a folder of emails.