At Woodland Group, we recognise that evolving regulatory standards can present real operational challenges for businesses navigating complex global supply chains.

Our priority is to help you understand the practical impacts of the EU Packaging and Packaging Waste Regulation (PPWR) and to support the operational shifts required to keep your logistics running seamlessly. While compliance responsibility ultimately sits with the business placing products on the EU market (the importer), we are fully committed to supporting our clients to ensure complete readiness.

We are actively driving change within our own operations by auditing our packaging workflows, collaborating with suppliers, and establishing practices that minimise excess packaging without compromising product safety.

The Packaging and Packaging Waste Regulation (PPWR) marks the most comprehensive update to EU packaging legislation in more than three decades. Its core aim is to curb packaging waste, elevate recyclability standards, and accelerate the transition toward a fully circular economy.

We understand these legislative updates can feel overwhelming. Our team is here to help you navigate how the PPWR directly affects your business. We will ensure our warehousing, fulfilment, and freight transport solutions adapt to continuously align with your sustainability and packaging targets.

This guide covers:

PPWR Overview: What the regulation entails and who falls under its scope

• Compliance Roles: Your key responsibilities when introducing products to the EU market
• Preparation Steps: Actionable measures your business should implement today
• Our Internal Commitments: How Woodland Group is optimising our own logistics operations
• Strategic Support: How we will guide and protect your supply chain throughout this transition
  

What is the EU Packaging and Packaging Waste Regulation (PPWR)?

The EU PPWR is a binding law that overhauls rules on packaging design, recyclability, and waste reduction. It is applicable from the 12th of August 2026 and affects all businesses placing packaged goods on the EU market. The regulation covers all packaging and packaging waste, regardless of material or origin, sets requirements for manufacturing, composition, and the reusable or recoverable nature of all packaging placed on the EU market, and includes packaging waste management and prevention measures. It aims to mpackaging anding on the EU market recyclable in an economically viable way by 2030, safely increase the use of recycled plastics in packaging, and decrease the use of virgin materials in packaging, and put the sector on track to climate neutrality by 2050.

The full regulation and annexes can be found here. These should be used by all businesses to assess the impacts of the PPWR on their own supply chains. This document should not be used as legal advice, and has been produced as an advisory document, outlining Woodland Group’s understanding and position on the EU PPWR in the role of a freight forwarder.

First deadline – 12th August 2026:

From 12 August 2026, every unique packaging SKU placed on the EU market must be covered by a Declaration of Conformity (DoC) backed by technical documentation. Economic operators must be able to provide the DoC and supporting technical documentation to market surveillance authorities upon request, generally within 10 working days. Based on discussions with customs and compliance experts, the DoC is not expected to be routinely required as part of standard customs clearance processes, although authorities may request supporting information as enforcement approaches evolve.

Also from the 12th of August 2026, the PPWR prohibits placing food-contact packaging on the market if it contains per-fluoroalkyl and poly-fluoroalkyl substances (PFAS) at or above specified concentration limits – e.g. no more than 25 parts per billion (ppb) for any individual PFAS. PFAS are often used for grease-resistant coatings.

The regulation also maintains existing heavy metal limits (100 parts per million (ppm) total for lead, cadmium, mercury, and hexavalent chromium).

The scope is intentionally broad so that almost no operator selling physical goods into the EU escapes it. PPWR scope covers every item used for the containment, protection, handling, delivery or presentation of products placed on the EU market, including imports, B2B packaging, and e-commerce shipments.

Each unique packaging type needs a Declaration of Conformity backed by verifiable supplier data. This will involve collecting verified substance test results, recycler certificates, and full material breakdowns from every supplier in the chain.

Packaging covered by PPWR:

• Primary packaging (e.g. yoghurt cups, shampoo bottles, sachets)
• Secondary packaging (e.g. shrink-wrap around can multipacks)
• Transport (tertiary) packaging (e.g. pallets, pallet wrap, shipping cartons)
• e-commerce shipping packaging
• Coffee capsules and pads
• Clothing hangers and tags (when sold with the product)
• Single portion formats previously exempt under national rules (e.g. small sauce/condiment sachets, miniature hotel toiletries, individual sugar packets, and single serve butter and jam tubs)
• Imported packaging from outside the EU

Packaging NOT covered by PPWR:

1. Items that are products in their own right (empty toolbox sold standalone)
2. Refillable pepper mill sold empty (it is the product)
3. Food packaging sold empty by the final distributor
4. Items integral to the product (permanent product housings)
5. Clothing hangers and tags sold separately

‘Primary Packaging’ vs. ‘Integral Product Component’ Definitions

Under PPWR, primary packaging is a distinct, separate container designed to enclose, deliver, and present a product to the consumer at the point of sale, making it fully subject to PPWR recyclability rules, EPR fees, and recycled-content targets.

In contrast, items integral to the product are non-packaging components that form an essential, permanent part of the product’s ongoing function and lifetime, intended to be used, consumed, and disposed of together with the product itself, thereby exempting them from packaging rules.

For example, a yoghurt cup, shampoo bottle, or sauce sachet are primary packaging discarded after use, and are within scope of PPWR. Whereas a TV/Laptop casing, a permanent zippers or buttons on clothing, or an electric toothbrush outer housing are integral items treated as part of the product itself, and are not within scope of PPWR.

Packaging Tiers

There are three packaging tiers under PPWR, each tier carries slightly different obligations. Primary packaging, the layer touching the product, faces the strictest substance and recyclability rules. Secondary packaging (grouped formats like multipack shrink-wrap) is subject to minimisation rules limiting empty space, amongst other targets. Transport, or tertiary, packaging (pallet wrap, shipping cartons, crates) includes various targets such as reusability, with a 40% reuse mandated by 2030 for B2B transport packaging between different companies. If the customer of the forwarder wraps, straps, or pallets the goods, the customer must hold the DoC for that stretch film and pallet. If a forwarder re-palletises, adds shrink wrap, or applies void fill, they are responsible for sourcing compliant materials and holding supplier technical files, to then share with customers.

Future targets (2028 onwards):

Mandatory labelling and documentation: The PPWR introduces harmonised labelling to help consumers recycle and improve transparency. Expect new symbols or QR codes on packaging indicating material composition, recyclability, reuse options, or the presence of certain substances. Material-composition labelling is scheduled to apply from the 12th of August 2028. Reusable packaging shall be labelled by 12th February 2029.

Packaging design requirements:By 2030, all packaging must be ‘recyclable’ according to EU criteria. Recyclability will be graded (A to C), and packaging that doesn’t reach at least 70% recyclability (grade C) will not be considered recyclable. From 2038, all packaging must be recyclable within grades A and B (80% and over). Importantly, future EPR fees (Extended Producer Responsibility packaging fees – mandatory costs charged to producers to cover the full net cost of collecting, sorting, and recycling packaging waste) will depend on these grades. Highly recyclable packaging means lower fees, while hard-to-recycle packaging will cost more.

Recycled content in plastics: the PPWR regulation mandates minimum recycled plastic content for many types of packaging. See below:

Reused and refilled packaging: From 2030, economic operators shall ensure that at least 40% of the following packaging they use is reusable: transport or sales packaging including pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters, including flexible formats or pallet wrappings or straps. The 40% reuse target is calculated based on the total number of packaging units of transport packaging used across your operations in a calendar year.From 2040, this will increase to at least 70%. From 2030, 100% of transport or sales packaging between different sites of the same company, as well as B2B transport or sales packaging within the same member state, shall be reusable.

Compostable packaging: By the 12th of February 2028, permeable bags or soft after-use system single-serve units of tea, coffee, or other beverages, and sticky labels attached to fruit and vegetables will have to be compostable in industrially controlled conditions.

Packaging minimisation: By 2030, the weight and volume of packaging shall be reduced to the minimum necessary for its functionality. Annex IV provides a methodology for a packaging minimisation assessment, including performance criteria (product protection, manufacturing processes, logistics, functionality etc).

Empty space ratio: By 2030, a maximum of 50% empty space ratio (including space filled with paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool, polystyrene or Styrofoam) will be allowed in grouped packaging, transport packaging and e-commerce packaging. A methodology for calculation of empty space ratio will be established in secondary legislation.

Roles and Responsibilities under PPWR:

Non-compliance with PPWR:

Economic operators are considered non-compliant when:

• The EU DoC has not been drawn up, or not drawn up correctly
• The QR code or data carrier does not provide access to the required information
• The technical documentation is not available, is not complete, or contains errors
• The registered name or trademark is absent, false, or incomplete
• The requirements on restrictions on uses of certain packaging formats or on excessive packaging are not complied with
• The requirements in relation to re-use or refill are not fulfilled
• The requirements on recyclable packaging and on minimum recycled content are not fulfilled

Penalties for PPWR non-compliance include market access denial, product recalls, retail delisting and administrative fines.

Please also note that non-EU importers into the EU that sell directly to the end consumer cannot sell into the EU without an Extended Producer Responsibility registration in every Member State they ship to. Customs clearances and freight movements will require proof of Extended Producer Responsibility registration numbers in destination Member States.

How Woodland Group can support with PPWR:

While Woodland Group is not the supplier, manufacturer or importer under PPWR, and is therefore not responsible for issuing or verifying Declarations of Conformity (DoCs), we can support your compliance by keeping a packaging register if we add transport (tertiary) packaging to your products in our warehouses.

Supplier Conformity Documentation:

We are currently engaging with our packaging suppliers to obtain technical documentation packs and supporting compliance information for packaging materials used within our operations. Where Woodland has added packaging materials to a shipment, we will be able to provide relevant supporting information to customers upon request.

Standard Operating Procedures:

We are reviewing and updating our packing processes, implementing and training relevant staff on the new SOPs in place to ensure compliance with PPWR as each new aspect of the regulation comes into force. These procedures are designed to make sure we are:

1. Selecting the smallest suitable carton for each order
2. Avoiding over-packing and the use of excessive void fill while still ensuring that goods are protected and packed safely
3. Reducing packaging waste
4. Prioritising efficient packing methods

Example EU-Bound Shipment Lifecycle

Here is an example of how Woodland expects to handle cargo due for import into the EU moving forward. In this example the ‘Exporter’ could be the manufacturer, supplier, or shipper of the product.

1. Exporter Prepares the Shipment

The Exporter packages the products in retail boxes, master cartons, and pallets. They maintain the required PPWR documentation, including any applicable Declarations of Conformity (DoCs) and technical files.

2. Woodland Receives the Cargo

Before shipment, Woodland may ask the Exporter to confirm that they have reviewed PPWR requirements and maintain the required documentation for their packaging. Including EPR registration, if relevant.

3. Woodland Handles the Cargo

3.a. If Woodland does not alter the packaging:

• Exporter remains responsible for the packaging compliance.

3.b. If Woodland re-palletises, adds stretch wrap, cartons, or void fill:

• Woodland tracks the packaging materials it added, including supplier, material type, weight, and recycled-content information.

4. Shipment Moves to Europe

The shipment is exported and imported into the EU through normal customs procedures. The Exporter maintains packaging compliance records and Woodland retains records for any packaging it added.

5. EU Authorities Request Information

If authorities ask for proof of packaging compliance:

• Exporter provides: DoCs, technical documentation, and packaging compliance records for the product packaging.
• Woodland provides: Documentation for pallets, stretch wrap, cartons, or other packaging Woodland supplied.

What should you do now?

1. Audit Packaging SKUs: Inventory all primary, secondary, and tertiary packaging layers shipped to the EU.
2. Collect DoCs and Test Reports: Obtain heavy metal and PFAS declarations from packaging suppliers.
3. Verify Markings: Ensure EU Importer/Manufacturer name and address are clearly marked on packaging and documentation.
4. Register for EPR: Secure valid EPR numbers for all EU destination countries where cargo is delivered.