If you've landed on this blog then you're probably a small business owner that's heard about the PPWR legislation that came into effect in August 2026 and is suddenly searching "what do I need to comply with this?" 

And for our clients for GPSR (safety documentation) compliance, if you've emailed us in the last few weeks asking some version of "wait, do I need to do something about packaging now too?", you're not alone.

PPWR, the EU's Packaging and Packaging Waste Regulation, took effect on 12 August 2026, and it's landed on top of GPSR just as most of you were getting that sorted.

Given the amount of questions we've had, we are running a client exclusive training session in partnership with Irmgard Considine from Green Impact Consulting, to answer our GPSR representative clients' questions on this new piece of legislation and compliance. 

In the meantime, we've put together this blog to answer some basic questions that you're asking. 

What is PPWR?

PPWR is separate from GPSR.

GPSR covers product safety.

PPWR covers your packaging: what it's made of, how recyclable it is, and how much of it you're putting on the EU market.

These are two different regulations with two different sets of obligations, and getting one sorted doesn't touch the other, so if you are still looking for GPSR compliance, we can help with that separate from PPWR.

PPWR stands for the Packaging and Packaging Waste Regulation.

It's an EU law, officially Regulation (EU) 2025/40, and its main rules started applying across the EU on 12 August 2026.

The aim behind it is to cut down on packaging waste across the EU. It pushes businesses to use less packaging, make what they do use easier to recycle or reuse, and take responsibility for what happens to that packaging once it's in the world.

In theory, we think this is something we all agree is a good thing. 

However where the difficulty lies, is in how this is being rolled out and how it affects you as a business owner, in order to comply. 

Before PPWR, packaging rules came from an EU directive, which each country turned into its own national law in its own way. That created a patchwork of slightly different rulebooks across the EU and mostly these didn't affect smaller producers.

PPWR replaces that with one regulation that applies the same way, automatically, in every EU country at once.

Each country still runs its own national system for registering producers and collecting the data.

The biggest change for a small business is who counts as a "producer" under the law.

Where before in many EU countries packaging reporting only applied once a business passed e.g. €1 million in turnover and placed 10 tonnes of packaging on the market a year, PPWR sets no such minimum.

As of August 2026, if you put packaging of any kind onto the EU market, you're in scope, whether that's one pallet a year or a thousand.

"Packaging" is defined broadly too. It isn't just the box a product ships in. It covers the bag, the label, the void-fill, the shrink wrap, anything that contains, protects, handles, delivers or presents your goods, from the moment it leaves you to the moment your customer unwraps it.

For a one-person or small team business, the practical takeaway is this:

if you sell physical products into the EU, packaging law now applies to you directly, even if it never did before.

It doesn't matter whether you manufacture the packaging yourself, buy it in from a supplier, or just repackage goods you've bought elsewhere. If your name is the one on the product when it reaches an EU customer, the obligation sits with you.

Conflicting advice on what to do next

In terms of what we're seeing from our clients, there is conflicting advice from fulfilment partners and manufacturers about how urgent registration with representatives in each country, tracking and submission of data actually is, and the honest answer right now (as at September 2026) is that enforcement isn't uniform across the EU. It varies country by country. 

Let's take Ireland, where RepGuardia is based, as an example, where there is still a gap.

Repak is Ireland's environmental not-for-profit organization that helps businesses manage and fund packaging recycling. 

Repak's existing threshold (turnover over €1 million and more than 10 tonnes of packaging placed on the Irish market) comes from Ireland's 2014 Packaging Regulations, not from PPWR, and it means a business below that line currently has no route to comply even if it wanted to.

Repak wasn't built to take smaller producers, and there's no separate PPWR scheme live yet to fill that gap. 

As at September 2026 the mechanism to register simply doesn't exist yet for smaller Irish-based or Ireland-shipping businesses, and we don't yet know whether that €1 million/10-tonne threshold will carry over once enforcement is properly stood up, get replaced by a different Irish threshold, or get overridden if an EU-wide exemption like the one Germany has proposed goes ahead.

Repak have told us (as at September 2026) that more guidance will be issued after November 2026, when we will be able to update clients on their obligations if a clear pathway is created. 

Is there a PPWR exemption for micro businesses?

Germany, which has run its own packaging register (LUCID) since 2019 and is the most active enforcer in the EU, has proposed a small-company exemption: businesses placing under 10 tonnes of packaging across the entire EU market, not per country, would fall outside the reporting requirement.

As it stands though, this is a proposal, not law. It hasn't been adopted, and there's no confirmed EU-wide threshold yet.

You may also have seen other figures circulating, including turnover thresholds tied to different regulations entirely.

We would advise you treat any number you haven't seen confirmed in official guidance as provisional, and for our clients we'll flag it clearly the moment something is actually confirmed.

What you need to be doing, regardless of thresholds or possible exemptions

Regardless of your size or what might come down the line, we're advising all our clients who send physical products into the EU the same:

You need to be tracking your packaging data now, regardless of the outcome.

Start recording what your packaging is made of (cardboard, plastic, shrink-wrap, foil, filling material), the weight of packaging per unit shipped, your total packaging volume placed on the EU market broken down by material type, and which countries you're shipping into.

If the exemption comes in, you'll need this data to prove you qualify for it. If it doesn't, you'll already have what's required for registration.

Waiting to start this tracking just means scrambling later, either way, so tracking everything from 12th August 2026 is the safest way to go.

How can RepGuardia help you with PPWR compliance?

We're building out PPWR and EPR representation, starting with Ireland, with other EU countries to follow.

Why can't we just cover you for the whole of the EU for PPWR compliance? Unlike GPSR, a single EU entity can't act as your representative across every country.

Germany, France, Spain, and every other member state require a locally established representative, which means this will be a country-by-country service rather than a one-off sign-up - which is where a lot of complaints and resistance has come from, given the expense of having a representative in each country you want to sell to.

We're running a training session for RepGuardia clients on PPWR compliance, covering what to track, how the country-by-country picture actually works, and what representation will look like as we roll it out. 

In the meantime, the one action that's useful no matter how any of this lands is to start tracking your packaging data now.

We will also be looking to create a PPWR template tracker for use across any and all countries to make this practical and easy to do. Watch this space. 

Find out more about RepGuardia's services.