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 October 2026) is that enforcement isn't uniform across the EU. It varies country by country. 
 

Is there a PPWR exemption for micro businesses?

As of 20th October 2026 the EU Parliament has issued a statement saying:

MEPs back a more targeted suspension that would apply only to EU-based small and micro enterprises (fewer than 50 employees and an annual turnover or balance sheet under €10 million) and until 2035, or until a more comprehensive circular economy act is adopted.

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?

Whilst the requirement to have a representative in each country is still in flux, we have created a PPWR Compliance Toolkit combining expertise from Green Impact Consulting, and our own in-house expertise of template building for simple EU compliance. 

It contains:

• Simple video explainers about what PPWR is and how it applies to you 
• A tracking spreadsheet to keep a log of the packaging you send into each country 
• A Declaration of Compliance template for each type of packaging you use 
• A list of the representative organisations in each EU country you need to register with 
• Updated information on the changing situation with authorised representation requirements and micro-business exemptions. 

Get your PPWR Compliance Toolkit now