For US manufacturers selling products into Europe, packaging is no longer simply a question of protecting a product, optimizing logistics or communicating a brand. It is increasingly a market-access issue.
The European Union’s new Packaging and Packaging Waste Regulation (PPWR — Regulation (EU) 2025/40) establishes a new regulatory framework covering packaging throughout its entire life cycle.
The Regulation entered into force in February 2025 and, as of August 12, 2026, its provisions have begun to apply across the European Union, with additional requirements being introduced progressively over the coming years. (Eur-Lex)
For American businesses exporting products to Europe, the important point is simple:
PPWR applies to packaging placed on the EU market regardless of where that packaging—or the product inside it—was manufactured.
That makes packaging compliance an issue US exporters should be addressing now.
What exactly is PPWR?
PPWR replaces the previous Packaging and Packaging Waste Directive with a directly applicable EU Regulation.
Its ambition goes significantly beyond traditional packaging waste legislation.
The Regulation covers all packaging, regardless of material or origin, and introduces requirements affecting packaging design, composition, recyclability, recycled content, minimization, labelling, reuse and waste management. (Environment)
The objective is to move the European packaging market toward a more circular model while reducing packaging waste and the consumption of virgin resources.
For manufacturers, this means that environmental performance is increasingly becoming a technical design requirement, rather than simply a sustainability commitment.
Why US exporters should pay attention
A common misconception is that PPWR primarily concerns European packaging manufacturers.
It does not.
If your company manufactures products in the United States and those products are placed on the European market, the packaging surrounding them enters the scope of European packaging legislation.
That can include:
Primary packaging around the product;
Secondary or grouped packaging;
E-commerce packaging;
Transport and distribution packaging;
Protective components and inserts;
And packaging components made from paper, board, plastics, metals, glass, wood or combinations of materials.
The Regulation explicitly applies to all packaging irrespective of the material used and whether it originates from industry, manufacturing, retail, distribution, services or households. (Eur-Lex)
In practical terms, a packaging specification developed exclusively around US requirements may therefore not be appropriate for products destined for Europe.
1. Recyclability becomes a design requirement
One of the most significant changes is the transition toward mandatory Design for Recycling.
The EU objective is for packaging placed on its market to be recyclable, with the major recyclability requirements applying from 2030. (Environment)
This changes the way packaging development should be approached.
It will increasingly be insufficient to argue that the individual materials used in a package are technically recyclable.
Companies will need to consider whether the complete packaging system is compatible with recycling.
That can put pressure on packaging designs involving:
multi-material structures, difficult-to-separate components, complex laminates, coatings, adhesives, labels, inks and barriers.
For US manufacturers, Design for Recycling should therefore become an input to packaging development—not a compliance exercise performed once the package has already been designed.
2. Packaging must be minimized
PPWR also pushes manufacturers toward reducing unnecessary packaging.
This does not mean simply making packaging thinner.
Packaging still has to perform its fundamental functions: protecting products, maintaining quality, supporting transportation and preventing product loss.
The challenge becomes finding the minimum amount of packaging necessary to perform those functions reliably.
That distinction matters.
Reducing packaging to the point where product damage increases can create more environmental impact—not less.
For exporters, packaging optimization should therefore consider the complete system:
product + packaging + logistics + distribution + end-of-life.
This is particularly important for companies shipping products long distances from North America into European distribution networks.
3. Empty space will increasingly matter
PPWR also targets excessive packaging and unnecessary empty space.
From 2030, specific requirements will apply to empty space in certain types of grouped, transport and e-commerce packaging. (Environment)
This is particularly relevant for US companies selling directly to European consumers.
An e-commerce packaging format optimized around US parcel networks may need to be reconsidered when entering Europe.
Right-sizing will increasingly become both a cost optimization opportunity and a compliance consideration.
4. Plastic packaging faces recycled-content requirements
Plastic packaging receives particular attention under PPWR.
From 2030, mandatory recycled-content requirements will apply to categories of plastic packaging, subject to the detailed rules and exemptions established by the Regulation. (Environment)
For manufacturers currently dependent on virgin plastic packaging, this can affect:
material sourcing, resin specifications, appearance, mechanical performance, food-contact compliance, supplier qualification and cost.
Companies should therefore start mapping their plastic packaging portfolio now rather than waiting until 2030.
The transition may require much more than replacing virgin resin with recycled resin in an existing specification.
5. PFAS restrictions are already relevant
Not every major PPWR requirement waits until 2030.
Since August 12, 2026, food-contact packaging containing PFAS above specified thresholds cannot be placed on the EU market.
This is particularly relevant for packaging using grease-, oil- or moisture-resistant treatments, including some papers, boards and food-service applications. (Environment)
Importantly, the European Commission has clarified that there is no general sell-through transition for non-compliant food-contact packaging manufactured before that date if it had not already been placed on the market.
For imported packaged products, the Commission guidance identifies release for free circulation following the customs procedure as the relevant point for determining placement on the market. (Eur-Lex)
US food manufacturers should therefore obtain appropriate information from packaging suppliers rather than assuming that an existing material specification is suitable for Europe.
6. Labelling will change
Europe is also moving toward harmonized packaging labelling intended to help consumers correctly sort packaging waste.
The new harmonized system is expected to apply from 2028. (Environment)
For international brands, this creates an important packaging-management question:
Can one global artwork serve both the US and European markets, or will Europe require a dedicated packaging version?
The answer will depend on the product, packaging format, markets served and final implementing requirements.
Companies should therefore leave sufficient flexibility within artwork and packaging specifications to accommodate future European labelling requirements.
7. Extended Producer Responsibility does not disappear
PPWR harmonizes many requirements across Europe, but it does not mean that every administrative obligation becomes identical across all 27 EU Member States.
Extended Producer Responsibility (EPR) remains particularly important.
The Regulation establishes producer responsibility for packaging waste and defines who is considered the producer in different supply-chain configurations. For distance sales directly to European end users, responsibilities can also arise for companies established outside the EU, with Member States able to require an authorized representative for EPR purposes. (Eur-Lex)
For a US exporter, compliance therefore cannot necessarily be managed simply as:
“We comply with PPWR, therefore we comply everywhere in Europe.”
Companies also need to understand where products are being sold, who places the packaged product on each national market, and which entity carries the relevant EPR obligations.
8. Europe should no longer be treated as an extension of the US packaging specification
This may ultimately be the most important strategic implication of PPWR.
Historically, many international manufacturers developed packaging primarily for their domestic market and then adapted labels or regulatory information when exporting.
PPWR makes that approach increasingly risky.
European packaging requirements now need to be considered much earlier in the development process.
For companies selling on both sides of the Atlantic, three strategies are possible:
Global specification — design the packaging from the outset to satisfy the most demanding relevant requirements.
Regional specification — maintain separate US and European packaging architectures.
Hybrid specification — retain a common structural platform while adapting materials, components, labels or configurations for each market.
There is no universally correct answer.
The right strategy depends on volumes, manufacturing footprint, supply-chain complexity, packaging costs and the technical differences between the markets.
What should US manufacturers do now?
The first step should not be redesigning every package.
It should be understanding exposure.
A practical PPWR readiness program should begin by mapping the packaging portfolio sold into Europe and identifying materials, components, suppliers, weights, formats and destination markets.
From there, companies can assess each packaging system against the emerging European requirements and classify it according to risk.
Priority should typically be given to packaging involving complex multi-material structures, significant plastic content, food contact, potentially problematic substances, excessive empty space or formats likely to face recyclability challenges.
Supplier documentation should also be reviewed.
European compliance will increasingly require manufacturers to understand what their packaging is actually made from, not simply what it is called on a purchasing specification.
Finally, companies should integrate European requirements into their packaging-development process so that recyclability, material selection, minimization and regulatory compliance are evaluated alongside cost and performance.
PPWR is not only a compliance challenge
There is another way to look at the Regulation.
For US manufacturers, PPWR can become an opportunity to reconsider packaging systems that may not have fundamentally changed for years.
Reducing material consumption can lower costs.
Right-sizing can improve logistics efficiency.
Moving toward simpler material structures can reduce complexity.
Increasing recycled content can reduce dependence on virgin resources.
And developing packaging that works effectively in European recycling systems can strengthen a company’s broader sustainability proposition.
The companies that treat PPWR purely as a regulatory deadline may eventually comply.
The companies that treat it as a packaging innovation and market-access program may gain considerably more from the transition.
The key takeaway
For US companies exporting to Europe, PPWR should no longer sit exclusively with the sustainability or regulatory team.
It affects R&D, packaging engineering, procurement, manufacturing, supply chain, marketing and commercial strategy.
And while several of the Regulation’s most transformative requirements arrive progressively toward 2030, PPWR itself is no longer future legislation.
It has started to apply.
The question for US manufacturers is therefore no longer whether European packaging requirements will affect their products.
It is:
Are your packaging specifications ready for the European market you will be selling into over the next five years?