Legal | Tax | Compliance
Legal | Tax | Compliance
New EU rules are making packaging a compliance issue: from recycled materials and reuse to compliance.
Design, recycled materials, reuse and producer responsibility
The Packaging and Packaging Waste Regulation (PPWR) has been in force since 12 August 2026. However, many key design and volume requirements will not come into effect until 2028 or 2030 and are, in some cases, subject to delegated acts, implementing acts and technical standards.
This article explores the packaging module of the mini-series in greater depth. For context within the broader framework of circular economy and product legislation, please refer to the overview article «The circular economy becomes binding product legislation».
I. Key obligations
The PPWR generally covers all packaging and packaging waste. Manufacturers must carry out conformity assessments and prepare technical documentation. Importers and distributors have their own testing and response obligations. Producers bear extended producer responsibility in the Member State in which the packaging is likely to become waste.
II. Key implementation stages
From 12 August 2026: general application of the PPWR and PFAS limit values for food contact packaging.
From 2028 or later: harmonised material labelling, subject to the entry into force of the necessary implementing acts.
From 2030 or later: Design for recycling, minimum recycled content requirements for plastic packaging, packaging minimisation, void space requirements for certain transport, collection and e-commerce packaging, and bans on certain single-use packaging.
From 2030: Reuse targets for certain transport packaging. Special requirements apply in some cases to deliveries between sites of the same company and within individual Member States.
From 2035: Recycling on an industrial scale will form part of the recyclability assessment.
Numerous delegated acts, implementing acts, standardisation work and guidelines are still required for operational implementation. The PPWR is therefore both applicable law and a regime that requires significant further elaboration.
III. Comparison with Switzerland
The new Swiss Packaging Ordinance will come into force at the start of 2027. It extends the previous approach to beverage packaging to cover packaging in general. In particular, it sets out requirements for avoiding unnecessary packaging and for dealing with substances of particular concern. At least 55 per cent of plastic packaging and at least 70 per cent of beverage cartons are to be recycled. Manufacturers and retailers of certain single-use plastic packaging must provide separate collection schemes.
The Swiss regulation is therefore more strongly focused on collection and recycling. The PPWR has a more far-reaching impact on design, compliance, labelling, recycled content and reuse.
IV. Implications for Swiss companies
Record the packaging portfolio by function, material, product and country of sale.
Determine roles as manufacturer, importer, distributor and producer for each distribution channel.
Separate EU compliance documentation from Swiss proof of recovery.
Integrate PFAS, void space, recyclability and reusability into design approvals.
Adapt contracts with packaging suppliers to meet information, reporting and amendment obligations.
Continuously monitor delegated acts and labelling standards.
For PFAS limit values and the impact on material cycles, see «PFAS are becoming a litmus test for material cycles». Product and packaging data should align with the data governance described in the article «Digital Product Passport and ESPR are transforming product management». Reuse and repair-friendly product and packaging concepts are covered in «Repair is becoming part of the business model». Packaging claims and sustainability labels must also be assessed in accordance with the communication rules set out in the article «Circularity claims also require robust evidence».
«Circular Economy» mini-series
Find out more about the individual regulations relating to the circular economy in our mini-series. The other articles in the mini-series cover the following topics:
«PFAS are putting material cycles to the test»: PFAS regulation, recyclability, replacement parts and supply chain data.
«Digital Product Passport and ESPR are transforming product management»: eco-design requirements, data architecture and governance.
«The PPWR is already changing packaging today»: packaging design, recycled materials, reuse and producer responsibility.
«Repair is becoming part of the business model»: right to repair, spare parts, software support and product lifespan.
«Circularity claims also require robust evidence»: EmpCo, the Swiss Unfair Competition Act (UWG), the New Federal Act on Consumer Protection (NUFG) and the Climate Protection Ordinance.
The articles should be read as a coherent implementation chain: material and product data form the basis for compliance and repair; packaging and circularity strategies determine the operational framework; and robust evidence sets limits on permissible communication.
