On 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR Regulation, came into force. It is worth noting that, as of that date, only some of the new requirements are in force – further obligations will be phased in until 1 January 2040, gradually replacing the provisions of the previous Directive on packaging and packaging waste. Check when the specific requirements concerning the design, labelling and placing of packaging on the market will come into force.

PPWR regulations from 12 August 2026 – new obligations for packaging manufacturers

• Restrictions on PFAS in packaging intended to come into contact with food

From 12 August 2026, it will be prohibited to place food contact packaging on the market if it contains per- and polyfluoroalkyl substances (PFAS) in concentrations equal to or higher than the limit values set out in Article 5(5) of the PPWR Regulation. In its guidelines, the European Commission notes that there is currently no harmonised methodology for testing for the presence of PFAS and recommends the use of „an approach based on state-of-the-art analytical capabilities and a meta-analysis of studies on relevant matrices with regard to PFAS”.

The PPWR Regulation does not provide for a transitional period for food contact packaging containing PFAS that was manufactured but not placed on the market before 12 August 2026. – if they do not comply with the PFAS content limits, they will not be allowed to be sold.

• Minimising the content of hazardous substances

Packaging must be manufactured in such a way as to minimise the content and concentration of potentially hazardous substances both in the packaging materials themselves and in all components of the packaging. From 12 August 2026, the sum of the concentrations of heavy metals – lead, cadmium, mercury and hexavalent chromium – in packaging or its components must not exceed 100 mg/kg.

• Preparation of an EU Declaration of Conformity

From 12 August 2026, all packaging placed on the European Union market for the first time must be accompanied by an EU declaration of conformity confirming compliance with the relevant requirements of the PPWR Regulation. The packaging manufacturer is solely responsible for carrying out the conformity assessment, preparing the technical documentation and drawing up the declaration; the manufacturer may, however, seek assistance from external bodies.

Discover Check for Recycling – a digital tool for assessing whether packaging complies with the PPWR >>

PPWR obligations from 12 February 2028 – compostable packaging

From 12 February 2028, certain packaging formats must comply with compostability requirements as set out in Article 9 of the PPWR Regulation. This obligation will apply to:

• self-adhesive labels affixed to fruit and vegetables,
• permeable bags for tea, coffee and other drinks,
• packaging for coffee, tea and other drinks, which becomes soft after use (soft-after-use).

This packaging should be designed in such a way as to allow it to be composted under controlled industrial conditions (i.e. comply with the industrial composting standards set out in Annex III to the PPWR Regulation). Each Member State may, in addition, require that the above-mentioned packaging formats placed on its market are also suitable for home composting.

In its guidelines, the European Commission states that the compostability requirement set out in Article 9(1) of the PPWR is material-neutral, i.e. it does not depend on the type of material from which the packaging in question is made.

Since when has packaging labelling in accordance with the PPWR been in force?

• 12 August 2028 – labelling of packaging

All packaging placed on the market must bear harmonised labels containing information on material composition and facilitating its correct sorting. In the case of compostable packaging, the label must also indicate its compostability, state that it is not suitable for home composting (where applicable) and specify that such packaging must not be discarded into the environment.

Transport packaging (with the exception of e-commerce packaging) and packaging covered by deposit-return schemes are exempt from the labelling requirement.

Read also: Packaging labelling in accordance with the PPWR – a proposal for new waste sorting labels

• 12 August 2028 – labelling of packaging waste bins

All containers for packaging waste must be labelled with harmonised labels to facilitate separate collection. The design of the labels affixed to the containers must correspond to the design of the labels used to mark the packaging. The aim of this regulation is to make it easier for end-users to sort used packaging into the correct waste stream.

• 12 February 2029 – labelling of reusable packaging

Reusable packaging placed on the market must bear harmonised labels indicating that it can be reused. In addition, each such package must bear a QR code or other digital data carrier that enables the package to be tracked and the number of its journeys and rotations to be determined. Furthermore, from 12 February 2029, all reusable packaging offered at points of sale must be easy to identify and distinguish from single-use packaging.

PPWR obligations from 1 January 2030 – the biggest changes in packaging design

• Design for recycling (Design for Recycling, DfR)

All packaging placed on the Community market must be suitable for material recycling and meet the requirements of one of the recycling efficiency classes – A, B or C. This classification determines the extent to which the packaging complies with design-for-recycling criteria, with Class A packaging being the most recyclable and Class C packaging the least recyclable. Packaging that does not meet the requirements of Class C, i.e. packaging with a per-unit recyclability rating of less than 70%, will be deemed unsuitable for recycling and may not be placed on the market.

• Minimum recycled content

From 1 January 2030, plastic packaging will be required to contain a specified minimum level of recycled material. The required level of recycled material will depend on the type of packaging and will be as follows:

• PET contact packaging – 30%,
• disposable bottles – 30%,
• contact packaging other than that made from PET – 10%,
• other plastic packaging – 35%.
• Discontinuation of certain packaging formats

It will be prohibited to place on the market the types of packaging listed in Annex V to the PPWR Regulation, in particular certain single-use plastic packaging. The restrictions will include, amongst other things:

Packaging formats being phased out	Examples of packaging
single-use plastic bulk packaging	shrink film and film for bundling products (e.g. bottles, tins), plastic promotional wrappers
single-use plastic packaging for fresh, unprocessed fruit and vegetables	nets, bags, trays, containers
single-use plastic packaging used in the HoReCa sector	trays, disposable cups and plates, bags and boxes
disposable plastic packaging for food accompaniments in the HoReCa sector	sachets, cups, trays, boxes for items such as jams, sauces, coffee creamer, sugar and spices
single-use packaging used in the accommodation sector for individual bookings	mini hotel toiletries
very lightweight plastic shopping bags	thin disposable shopping bags and sachets, e.g. for packing fruit, vegetables or bread

• Minimisation

From 1 January 2030, the weight and volume of packaging must be limited to the minimum necessary to protect the product. Double-walled packaging, false bottoms and unnecessary layers that appear to increase the volume of the product will therefore be prohibited.

The provisions of the PPWR Regulation introduce a maximum void ratio for collective, transport and e-commerce packaging of 50%. Void space includes not only air-filled spaces but also any filling materials, such as bubble wrap, polystyrene, foam, paper and other similar materials.

• Objectives for transport packaging

From 1 January 2030, companies using transport or commercial packaging for the transport of goods within the EU – including pallets, collapsible boxes and plastic crates, trays, large bulk containers, vats, drums, canisters, palletised packaging or straps used to stabilise and protect products placed on pallets, shall ensure that at least 40 % of such packaging is reusable.

The PPWR also provides for an obligation; the PPWR also stipulates that, in the case of specific transport packaging used between different business premises of the same operator, or between an operator and an affiliated or partner company, such packaging must be reusable packaging operating within a reuse system. However, in accordance with Commission Delegated Decision (EU) 2026/429, this obligation shall not apply to pallet packaging and straps used to stabilise products on pallets.

PPWR obligations from 1 January 2035 – introduction of a large-scale recycling requirement

From 2035, the assessment of packaging recyclability will be expanded to include an additional criterion – large-scale recycling. This means that packaging will not only have to meet the requirements for design for recycling, but also actually be recycled on an appropriate scale. Manufacturers will therefore be required to carry out assessments based on the quantity (mass) of packaging material that is effectively recycled. The methodology for this assessment and the thresholds for large-scale recycling in each packaging category will be set out in implementing acts adopted by the European Commission.

PPWR obligations from 1 January 2038 – more packaging is being phased out of the market

From 2038, it will be prohibited to place on the market packaging that meets the criteria for Class C, i.e. packaging that can be recycled to a degree greater than 70% but less than 80%. Consequently, only packaging belonging to classes A and B will remain on the market.

Find out more about recycling efficiency classes A, B and C >>

PPWR obligations from 1 January 2040 – stricter requirements for generators and manufacturers

• Increase in the minimum levels of recycled content

The minimum proportion of recycled material used in the production of packaging will increase to:

Packaging type	Minimum recycled content
PET contact packaging	50%
disposable bottles	65%
contact packaging other than that made from PET	25%
other plastic packaging	65%

 

• Higher reuse targets for transport packaging

Companies using specific transport and retail packaging that have so far been subject to a 40 per cent reuse target (including pallets, collapsible plastic containers and crates, trays, large bulk containers, buckets, drums, canisters, palletised packaging and load-securing straps) are aiming to use at least 70% of such packaging in a reusable format within the reuse scheme.

The introduction of the PPWR Regulation requires businesses to correctly identify their role in the supply chain. This is because the scope of packaging obligations depends on whether the company acts as an importer, distributor, supplier or fulfilment service provider. Importantly, the same entity may fulfil several different roles simultaneously, and each of these involves separate requirements.

Importer under the PPWR Regulation

An importer of packaging within the meaning of the PPWR Regulation is any natural or legal person who has is resident or has its registered office in the EU and places on the market packaging originating from a third country. Before an importer places packaging on the EU market, they should ensure that:

• the packaging manufacturer carried out the conformity assessment procedure, drew up all the required technical documentation and the declaration of conformity for the packaging,
• the packaging bears a harmonised label to facilitate waste sorting (from 12 August 2028),
• The packaging bears the manufacturer’s details and the packaging identification number.

The importer must include their name, registered trade name or registered trade mark, their postal address and contact details on every package they import. All this information should be presented in a clear and legible manner.

The obligations of the packaging importer also include:

• keeping a copy of the EU declaration of conformity and making it available, together with the full technical documentation, to market surveillance authorities,
• ensuring that the packaging is transported and stored under appropriate conditions which do not adversely affect its compliance with the PPWR requirements,
• withdraw all packaging that does not comply with the PPWR from the market and inform the relevant authorities of this without delay.

Distributor as defined in the PPWR Regulation

According to the definition set out in the PPWR Regulation, a packaging distributor is an entity within the supply chain which places the packaging on the market but is neither the importer nor the manufacturer of that packaging. The distributor of the packaging may be either a natural person or a legal person.

NOTE: The packaging distributor should not be confused with the final distributor. There may be several distributors in the supply chain, but only one of them will be the final distributor.

Before placing the packaging on the market in a given Member State The distributor is obliged to check whether:

• the packaging manufacturer is registered in that Member State’s EPR register,
• a harmonised label has been affixed to the packaging to facilitate waste sorting (from 12 August 2028),
• The packaging bears the manufacturer’s and importer’s details, as well as the packaging identification number.

If the packaging does not comply with the currently applicable requirements of the Regulation, the distributor may not make it available on the market until the non-compliance has been rectified. In cases where packaging that does not comply with the PPWR has already been placed on the market, the distributor must either bring it into compliance or withdraw it from the market. They should also inform the relevant authorities of the non-compliance detected and the corrective measures taken.

At every stage of the distribution of packaging and packaged products, the distributor must to act with due care, including storing and transporting goods in a manner that does not adversely affect their compliance with the PPWR requirements. They are also obliged to provide documentation and information that will demonstrate the packaging’s compliance with the PPWR requirements. Although the PPWR does not require distributors to hold a declaration of compliance, keeping full documentation makes it significantly easier to pass any potential inspection. Interzero’s experts therefore recommend that all distributors obtain such declarations.

Can an importer or distributor also be a manufacturer?

Yes. This follows directly from Article 21 of the PPWR Regulation. The importer and distributor must fulfil the manufacturer’s obligations if:

• place packaging on the market under their own name or their own trade mark,
• modify packaging that has already been placed on the market in a way that may affect its compliance with the requirements of the PPWR Regulation.

Exception: if an importer or distributor meeting the above conditions is also a micro-enterprise, they will not be subject to the obligations of a producer. In this situation, the packaging producer will be the natural or legal person who supplies the packaging to that importer or distributor and is established in the EU.

Find out about the role and responsibilities of packaging manufacturers under the PPWR Regulation >>

Supplier as defined in the PPWR Regulation

Under the PPWR Regulation, a supplier is any natural or legal person who supplies the manufacturer with packaging or packaging materials. The supplier should provide the manufacturer with all the information and documents (including technical documentation) necessary to demonstrate the compliance of packaging and packaging materials with the PPWR Regulation. This information must be provided in a language the manufacturer can understand and supplied in either paper or electronic form.

NOTE: One should not confuse a „supplier” with an „order fulfilment service provider” – these entities are at opposite ends of the supply chain and have different roles and legal obligations.

Order fulfilment service provider at PPWR

The PPWR Regulation adopts the definition of a contract fulfilment service provider set out in Article 3(11) of Regulation (EU) 2019/1020. According to this definition, a contract fulfilment service provider is a business entity engaged in commercial activities, as part of which it provides at least two of the following services:

• product storage,
• product packaging,
• addressing parcels and dispatching products,

…without, at the same time, being the owner of those products. The group of order fulfilment service providers includes entities providing postal services, parcel delivery services or any other goods transport services.

Order fulfilment service providers are required to ensure that the storage, handling and packaging, addressing and dispatch of packaging (whether empty or containing a product) take place under conditions that do not adversely affect the packaging’s compliance with the requirements of Articles 5–12 of the PPWR Regulation. They should also assess whether the packaging manufacturer’s assurances regarding compliance with its EPR obligations are complete and reliable.

Under the provisions of the PPWR Regulation, the role of manufacturer is not always fulfilled by the entity that physically produced the packaging in question. In some cases, the manufacturer of the packaging may be the brand owner, an importer or a distributor. Find out how the PPWR Regulation defines a manufacturer and learn about the obligations that this entity must fulfil.

Who is a manufacturer under the PPWR Regulation?

In accordance with Article 3(1)(13) of the PPWR Regulation, a packaging producer is any natural or legal person who:

• produces (i.e. physically produces) the packaging or the product inside the packaging, or
• draws up specifications, commissions the design or manufacture of the packaging or the product inside the packaging under its own name or trade mark. In this case, it is irrelevant whether another party’s trade mark appears on the packaging or the product. What is decisive is who determines the design and specifications of the packaging and markets it under their own brand.

Exception: If the business commissioning the production of packaging is a micro-enterprise and the packaging supplier is established in the same Member State, the packaging supplier, rather than the brand owner, is deemed to be the producer.

Throughout the EU, each package may have only one manufacturer within the meaning of the PPWR Regulation.

See also: Who is a producer within the meaning of the PPWR regulations?

‘Producer’ as defined in the PPWR – practical examples

Manufacturer retail or bulk packaging is usually the entity that fills is the manufacturer of the product and places it on the market in the EU. In practice, this is usually the owner of the product’s brand. This rule does not apply to service packaging (e.g. drink cups, takeaway food boxes).

Example 1: A cosmetics manufacturer orders empty cream jars, then fills them, seals them, packs them into the cardboard boxes supplied to it, and sends them to a wholesaler. The cosmetics manufacturer is the producer of both the cream jar and the cardboard box, even though both items of packaging were physically manufactured by other businesses.

Example 2: A mobile café sells drinks prepared on the premises in multi-material cups without a logo. The café owner does not manufacture these cups.

The manufacturer of transport packaging, service packaging and packaging for primary production is the actual manufacturer of these packaging items. However, if such packaging bears the logo, trademark or brand name of another entity, then its manufacturer, within the meaning of the PPWR, is the owner of a trade mark or logo.

Example 3: The franchisee sells hot dogs in paper wrappers bearing the franchise chain’s logo. These wrappers are manufactured by the owner of the franchise chain, not by the business owner running the outlet.

Under the PPWR, the importer or distributor of packaging may also be regarded as its producer. This is the case if:

• an importer or distributor places packaging on the market under their own name or trade mark,
• an importer or distributor modifies packaging placed on the market in a way that affects the compliance of that packaging with the requirements of the PPWR Regulation.

Example: Company X imports porcelain mugs from China, packed individually in cardboard boxes. Company X then affixes plastic labels to each of these packages, containing washing and care instructions for the mugs (on the back of the package) and its own logo and the mug’s brand name (on the front of the package). Company X incorporates an element made of a different material into the original packaging, which is relevant to assessing the packaging’s compliance with the requirements of the PPWR; it therefore becomes the manufacturer of that packaging.

The obligations of packaging manufacturers under the PPWR Regulation

Packaging manufacturers must fulfil a number of obligations in relation to the packaging they place on the market. For this reason, operators involved in the packaging supply and distribution chain within the EU must ensure that they correctly identify both their role and the list of their legal obligations.

The main responsibilities of packaging manufacturers include, in particular:

• carrying out the conformity assessment procedure packaging (either independently or in collaboration with relevant organisations, such as testing laboratories),
• drawing up and updating the EU declaration of conformity confirming compliance with the PPWR requirements,
• preparation and storage technical documentation and the EU declaration of conformity for the period required by law (5 or 10 years, depending on the type of packaging and its intended use) and making them available upon request by the competent authorities,
• ensuring compliance and identification packaging manufactured in accordance with the requirements of the PPWR Regulation,
• to be displayed on every package a number that enables it to be uniquely identified (e.g. serial number, production batch number),
• to include on the packaging or in a QR code their name, registered trade name or trade mark, postal address and electronic contact details (where available). All information must be provided in a clear and legible manner and positioned so as not to obscure other mandatory information and markings on the packaging,
• notifying the relevant authorities of suspected non-compliance its packaging with the requirements of the PPWR Regulation and the corrective measures taken to remedy this non-compliance.

The full list of a manufacturer’s obligations within the meaning of the PPWR is set out in Article 15 of the Regulation.

The PPWR Regulation not only amends the requirements regarding the design and labelling of packaging, but also the method for determining the entity responsible for fulfilling the obligations arising from extended producer responsibility (EPR). Find out who is considered a producer under the PPWR and learn how to correctly determine your company’s role in various EU markets.

Who is considered a manufacturer under the PPWR Regulation?

The PPWR Regulation defines a producer as a manufacturer, importer or distributor who – depending on the type of packaging, place of business and method of distribution – places the packaging or the product in its packaging on the market of a given Member State for the first time or unpacks the product from its packaging without being the end user. The packaging or the product within the packaging may be made available through traditional sales channels or any form of distance selling, including online sales and telephone sales.

The aim of this regulation is to identify an entity which is located at the start of the supply chain in the Member State in question, and, consequently, should be held liable for packaging or packaged products placed on the market in that country for the first time.

In practice, a ‘manufacturer’ within the meaning of the PPWR regulations may be:

• manufacturer the packaging or the product inside the packaging,
• importer the packaging or the product inside the packaging,
• distributor the packaging or the product inside the packaging,
• an online retailer, who makes the packaging or the product in its packaging available directly to end users in another EU Member State,
• a trader who unpacks or repacks goods prior to their further distribution (only if the above points do not apply).

The PPWR Regulation introduces the principle „one manufacturer for each packaging unit”. This means that, in a given Member State, for every packaging unit, there is always one entity responsible for fulfilling the obligations of the ROP (. EPR) – regardless of how complex the supply chain is.

Are you a manufacturer of packaging or packaged products? Check your EPR obligations in various EU markets >>

‘Producer’ and ‘manufacturer’ in the PPWR Regulation

One of the most common mistakes made by companies operating within the supply chain is to equate a producer with a manufacturer. A manufacturer may also be a producer, but not in every case – The PPWR Regulation distinguishes between these two entities and assigns different responsibilities to each of them.

Manufacturer an entity that manufactures the packaging or the product in the packaging itself, or an entity that commissions the packaging and determines its specifications. Every package placed on the EU market has only one manufacturer, who is primarily responsible for ensuring that this packaging complies with the requirements of the PPWR Regulation regarding design, sustainability and labelling.

Example: Company X orders boxes for sports shoes from Company Y – specifying their exact shape, dimensions and colours, and requesting that its logo be printed on the lid of each box. In this situation, Company X is the manufacturer of the boxes.

Who is the packaging manufacturer? Check the definition and exceptions (article coming soon)

Manufacturer whereas they place the packaging or the packaged product on the market of a given EU Member State for the first time. They are responsible for fulfilling the obligations arising from extended producer responsibility in that Member State.

Example: Company Z operates a chain of supermarket stores in Poland, where it sells packaged products under its own brand. Company Z is the packager of these products (across the whole of the EU) and, at the same time, their manufacturer (within Poland).

When is an importer or distributor considered a manufacturer?

If the packaging manufacturer does not meet the definition of a producer within the meaning of the PPWR (i.e. does not place the packaging or the product in packaging on the market in a given Member State), then the importer or distributor of the packaging or the product in packaging, who meets the conditions set out in the definition of a producer, may be deemed to be the producer of the packaging or the product in packaging within the meaning of the PPWR Regulation, and makes them available for the first time within the territory of a given EU Member State.

If a natural or legal person purchases packaging (empty or containing a product) from another Member State or from outside the EU, and is then the first to place it on the market in one or more EU countries, that person may become the producer of the packaging or the product contained therein and will be required to fulfil the EPR producer’s obligations in each of those countries.

Example: A Polish company imports wholesale quantities of packaged cosmetics from Italy and begins selling them on the domestic market. Although it has not manufactured either the cosmetics or their packaging, it is regarded as the manufacturer in Poland because it was the first to make the packaged products available on the Polish market.

The owner of an online shop as a manufacturer of packaging and packaged products

If a business or an individual sells packaging or packaged products directly to end users in another Member State, rather than the country in which it is established, may be regarded as a producer within the meaning of the PPWR in that country and will be required to fulfil the obligations arising from the local EPR scheme. This means that any entity selling online to individual end-users located in a dozen or so EU countries is simultaneously a producer in all those countries and is subject to local EPR obligations in each of them. This mainly applies to businesses operating online shops, teleshopping and other distance selling channels.

Importantly, the PPWR Regulation explicitly states that in the case of distance selling simply offering the packaging or product to the end user (e.g. via an online shop or an e-commerce platform) is regarded as placing it on the market.

Example: This Polish jewellery manufacturer handcrafts its products and packages them in decorative boxes. It offers all its products via its online shop to end customers – private individuals throughout the EU. The manufacturer is therefore both the producer and the packager of the products in each EU Member State.

Unpacking and repackaging of products in accordance with the PPWR Regulation

A manufacturer, importer or distributor may also meet the definition of a producer where they unpack products from their packaging prior to their further distribution. This applies, amongst others, to logistics companies that are not end-users, which they repackage the goods into smaller packs, and then pass them on to other entities for sale.

How can you determine whether your company is a manufacturer within the meaning of the PPWR?

Assessing whether a given entity is a manufacturer within the meaning of the PPWR requires an analysis not only of the company’s activities themselves, but above all of its role within a specific supply chain.

Although the levels of separate collection of plastic waste are rising year on year, Poland is still failing to realise the potential of the raw material it collects. A report published in May 2026 by Plastics Europe shows that most plastic waste does not end up being recycled, but is sent to incinerators. The low circularity rate for plastics is not merely an environmental issue – at a time when Europe is increasingly committed to the circular economy and is mandating the use of recycled materials, this situation could lead to serious problems with the availability of recycled raw materials and a decline in the competitiveness of Polish companies.

We’re harvesting more and more, but we’re still not processing enough

The latest report from Plastics Europe The Circular Economy for Plastics – A European Analysis 2026 provides further worrying information that highlights the problems facing the Polish and EU plastic recycling sectors. According to the data presented in the report, 2.089 million tonnes of post-consumer plastic waste were collected in Poland in 2024. Only 436,000 tonnes, or 21% of the total stream, were sent for recycling. This means that only around one-fifth of the plastic was returned to the material cycle. The remainder of the waste was managed using other, less sustainable methods – as much as 865,000 tonnes, or 41.4%, of plastic waste was sent to incinerators, whilst 788,000 tonnes (37.7%) was disposed of in landfill. However, from a circular economy perspective, incineration should be a last resort, used only when recycling is not economically viable or impossible due to a lack of suitable technology.

Low levels of plastic recycling have a negative impact on manufacturers of raw materials and plastic products. The limited supply of recycled plastic, combined with price competition between virgin and recycled plastic, means that Only the 30% plastic production process currently relies on recycled materials – both post-consumer (19.6%) and pre-consumer (10%). The remaining 70% of plastics are still produced from virgin raw materials derived from fossil fuels.

Poland is no exception. Europe is also grappling with this problem

Excessive landfilling and insufficient recycling are not merely local problems – similar trends are observed across Europe. A report by Plastics Europe shows that of the 32.7 million tonnes of plastic waste collected in the EU27+3 countries, only 29.6% was recycled. At the same time, as much as 48.9% of waste was sent to incineration plants, and a further 21.5% to landfill sites. This means that over 70% of plastic waste is still not being returned to the material cycle.

Of all plastic waste Packaging waste comes closest to being circular – In Poland, 30% of plastic packaging is recycled, whilst the average for the EU+3 is 40.5%. Plastic waste from agriculture and horticulture ranks second (20% in Poland and 32.5% in the EU27+3). Between 2022 and 2024, both of these waste streams recorded an increase in their recycling rates. The opposite trend is evident in the category of plastic waste from the automotive sector – currently, 9% of this waste is recycled in Poland (compared with an EU average of 17.7%), and between 2022 and 2024, the EU recycling rate for this waste stream fell by as much as one-third.

Data from the automotive sector is particularly interesting in view of the approaching Vehicle ROP – The new regulations are set to require manufacturers to use at least 20% of recycled material in the production of new vehicles.

The authors of the report point out that, despite the increase in collection and sorting rates, Europe still lacks sufficient recycling capacity, and some of the sorted waste is exported outside the region for further processing. To prevent the loss of raw materials caused by exports and to protect third countries from excessive environmental burdens, the EU has amended the rules on cross-border shipments of waste, introducing, amongst other measures, a ban on the export of plastic waste.

Find out about the new regulations on the cross-border shipment of waste >>

Separate waste collection is still important

The Plastics Europe publication focuses not only on systemic issues, but also highlights the importance of individual efforts and actions. One such effort is the separate collection of plastic waste, which enables a significant amount of raw material to be returned to the cycle. The current recycling rate for separately collected plastic stands at 46.5%, whereas for waste entering the mixed waste stream, this figure is only 2.3%.

Countries that invest in technologies for sorting residual waste stand out significantly above the EU average. Thanks to improved sorting processes in Germany, Poland and Spain, it has become possible to recover a greater quantity of plastics from mixed waste, and the recycling rate for plastics from this stream has risen from 3.8% to 5.6%. However, separate collection remains the main source of waste sent for material recycling. Experience in these countries shows that even the most advanced sorting technologies are unable to completely replace source-separated collection. Mixed waste is significantly more contaminated, which limits its potential for reuse and increases the likelihood of it being sent for thermal treatment at a waste-to-energy plant.

 

Sources:

1. A dramatic slowdown in Europe’s transition to a circular plastics system, https://plasticseurope.org/media/circular-economy-report-2026-dramatic-slowdown-in-plastics-circularity/
2. Plastics Europe, The Circular Economy for Plastics: A European Analysis, https://plasticseurope.org/wp-content/uploads/2026/05/Circular-Economy-Report-2026-full-report.pdf
3. Poland is drowning in plastic. Only 21 per cent is recycled, https://www.bankier.pl/wiadomosc/Polska-tonie-w-plastiku-Tylko-21-proc-trafia-do-recyklingu-9135839.html
4. Plastics Europe, The Circular Economy for Plastics: A European Analysis – Executive Summary, https://plasticseurope.org/wp-content/uploads/2026/05/CER26-SINGLEPAGE-Executive-Summary.pdf

On 30 April 2026, the annual „Clean Odra” campaign came to an end, during which volunteers collected litter from the riverbanks and the water for the fifth time. One stage of the campaign involved not only a major clean-up, but also an analysis of the composition of the waste, which served as a test of the effectiveness of Poland’s waste management policy and the new measures implemented over the past 12 months.

Waste composition from the 5th edition of the ‘Clean Odra’ campaign

Thanks to the commitment of the Waste Free Oceans (WFO) Foundation, Dominik Dobrowolski, the West Pomeranian Province Landscape Parks Team and the Regional Water Management Authority in Szczecin (Wody Polskie), On 22 April 2026, an analysis was carried out of the composition of the waste collected during the clean-up campaign in Międzyodrze in the Lower Oder Landscape Park. This was the first study of its kind covering the period following the introduction of a deposit scheme for PET bottles and cans in Poland. It therefore had the potential to provide answers to questions regarding the rationale behind the implementation and the effectiveness of the Polish deposit scheme model.

During this one-day event, the following was collected:

• 240 kg of glass,
• 77 kg of plastic,
• 6 kg of aluminium cans not subject to a deposit,
• bulky waste (including tyres, garden furniture and other items).

We discuss the Odra clean-up campaign and other nature conservation initiatives in more detail on the ‘Eko bez kantów’ podcast: A clean Oder, a clean Vistula – is that possible? An interview with Dominik Dobrowolski

The deposit scheme is working – just two returnable bottles in Międzyodrze

As expected, the analysis of the composition of the waste collected during the clean-up of Międzyodrze has yielded some interesting findings regarding the recently launched deposit-refund scheme. During the all-day clean-up operation the volunteers found just two returnable bottles. Importantly, the result from Międzyodrze was no fluke – the organisers of the „Clean Oder” campaign noted that This year’s campaign collected far fewer plastic bottles and cans than in previous years. Although these figures do not yet conclusively prove the effectiveness of the deposit scheme, they clearly show a trend that is likely to continue in the coming months – packaging with economic value rarely ends up in the environment.

For environmental experts, this is a sign that a well-designed scheme based on a financial incentive to return packaging can reduce the amount of litter in the countryside.

Is single-use glass the new plastic?

The introduction of a deposit-return scheme and a significant reduction in the amount of discarded plastic packaging have led to a noticeable change in the composition of the waste collected during clean-up operations along the River Oder. In previous editions of the campaign, PET bottles and aluminium cans made up the bulk of the contents of the volunteers’ bags, but in 2026 these were replaced by single-use glass bottles. A morphological analysis showed that as much as 60% of the total mass of collected recyclable waste consisted of glass. Next on the list was waste that has been lying in the environment for years and is not regularly removed by local authorities. This mainly refers to old PET bottles and aluminium cans, which volunteers mostly found in hard-to-reach places.

The event organisers emphasise that glass waste is not merely an aesthetic problem – although it does not break down in the environment and does not emit harmful substances, it can pose a fire risk, and, when broken, it poses a danger to people and animals.

The results of the analysis and a detailed report on the Odra clean-up campaign have contributed to the ongoing debate on the possibility of introducing a deposit scheme for single-use glass bottles, particularly the so-called „małpki”. Small alcohol bottles are one of the most common types of litter found in the natural environment and in urban areas. Including them in the deposit-return scheme could have a measurable environmental impact comparable to that currently seen with PET bottles – instead of ending up in the natural environment, the glass would go into a bottle return machine and then be recycled. The Ministry of Climate and Environment is currently working on such a solution. The outcome of this work and the final decision on the future of single-use glass bottles will likely be announced after the summer holidays.

Read also: New rules for returning glass bottles under the deposit scheme >>

From 19 July 2026, large fashion companies will no longer be allowed to destroy unsold textiles – the ban will come into force on that date, although there will be certain exceptions. The new rules form part of the EU’s ESPR Regulation (Regulation on Ecodesign for Sustainable Products), which promotes sustainable production and supports the circular economy.

Who will be affected by the ban on the destruction of unsold textiles? Scope in terms of entities and subject matter

The European Union is introducing further legislation aimed at accelerating the transition to a circular economy. It will come into force as early as 19 July 2026 a ban on the destruction of unsold textiles – clothing, footwear and fashion accessories. It will cover not only products that have not been purchased by consumers – in accordance with the ESPR Regulation, „”unsold products’ also include products that were never put on sale (e.g. prototypes, post-show models or those from photo shoots) and products from returns made by consumers under their right to withdraw from a contract.

The last three operations listed in the waste management hierarchy – recycling, other recovery and disposal – will be classified as destruction. However, preparation for reuse, refurbishment and reconditioning will not be classified as destruction.

The ban on destroying unsold clothes and footwear will be introduced gradually – From 19 July 2026, new obligations will be imposed on large companies employing more than 250 staff. On 19 July 2030, i.e. four years later, the scope of the provisions will be extended to include medium-sized enterprises employing between 50 and 250 staff. To avoid excessive administrative burdens, micro-enterprises and small enterprises have been exempted from the ban on the destruction of textiles.

The EU legislator has also provided for a mechanism designed to prevent abuse and eliminate unfair practices by the largest market players. Article 25(2) of the ESPR Regulation provides for a mechanism designed to protect the smallest economic operators – small and micro-enterprises, which have been exempted from the scope of the new rules – must not destroy unsold consumer products that were supplied to them solely for the purpose of circumventing the ban.

Clothing and footwear covered by the ban on destruction

The products covered by the ban on destruction included unsold clothing, clothing accessories and footwear classified under the following CN codes:

• 4203 Articles of clothing and clothing accessories, of tanned leather or reconstituted leather
• 61 Knitted garments and clothing accessories
• 62 Non-knitted articles of clothing and clothing accessories
• 6504 Hats and other headgear, plaited or made by weaving strips of any material, whether or not lined or trimmed
• 6505 Hats and other headgear, knitted or crocheted, or made of lace, felt or other textile materials, in the piece (but not in strips), whether or not lined or trimmed; hairnets of any material, whether or not lined or decorated
• 6401 Waterproof footwear with soles and uppers of rubber or plastics, where the uppers are not attached to the sole or joined to it by stitching, riveting, nailing, screwing, pinning or similar means
• 6402 Other footwear with soles and uppers of rubber or plastics
• 6403 Footwear with soles of rubber, plastics, tanned leather or reconstituted leather, and uppers of tanned leather
• 6404 Footwear with soles of rubber, plastics, tanned leather or reconstituted leather, and uppers of textile materials
• 6405 Other footwear.

Exceptions to the ban on the destruction of unsold clothing and footwear

As stated in the explanatory memorandum to the ESPR Regulation, The destruction of unsold textile products is a common occurrence – it affects as many as 4-9 % for all products available on the EU market. The overproduction of textiles and their short lifespan have a negative impact on the environment and lead to the loss of valuable economic resources; they must therefore be resolutely combated.

Preventing damage to clothing and footwear must not be pursued at any cost; therefore, in the Commission Delegated Regulation of 9 February 2026,. A number of derogations have been established, relating mainly to safety, public health and intellectual property rights. In any case However, the manufacturer must provide evidence justifying the destruction of the products, and then retain the documentation collected for a period of 5 years and make it available upon request by the supervisory authority.

Read also: There will be a ROP for textiles >>

Mandatory disclosure of information on unsold consumer products

Pursuant to the ESPR Regulation Manufacturers who destroy unsold textile products will be required to disclose information o:

• the annual number and weight of products destroyed, broken down by type and category,
• the reasons for product damage,
• the method of managing textile waste and the percentage of products that have been prepared for reuse (including refurbishment and regeneration), recycling and other forms of recovery (including energy recovery),
• measures taken and planned to prevent the destruction of products in the future.

All this information must be included on the website the manufacturer and worded in a clear and legible manner. This is intended to discourage manufacturers from disposing of unsold consumer products, whilst at the same time providing information on the scale of this phenomenon.

On 21 May 2026, Regulation (EU) 2024/1157 of the European Parliament and of the Council (EU) 2024/1157 of 11 April 2024, introducing the most significant reform of the rules on transboundary movements of waste (TPO) within the Community in over a decade. The new regulations are intended to strengthen controls over the international transport of waste, limit its export outside the EU and contribute to the development of the circular economy.

The DIWASS system – mandatory digitisation of cross-border waste shipments

From 21 May 2026. All EU entities participating in the TPO are required to use the DIWASS system (English. Digital Waste Shipment System), which is used for the electronic transmission of all transport-related documentation. It is intended to streamline administrative procedures, increase the transparency of the waste shipment process and facilitate the work of the supervisory authorities, which will gain full access to the documentation.

The following must be submitted via the DIWASS system: documents submitted as part of the notification procedure (i.e. prior written notification and consent), as well as those relating to information procedures. The only part not yet covered by the digital system is Annex VII, which relates to the shipment of waste on the so-called ‘green list’. As reported by GIOŚ, Between 21 May and 31 December 2026, Annex VII may be submitted in paper form, whilst the creation of an electronic version of the document will remain optional. From 1 January 2027, all documentation relating to the transboundary shipment of waste will be maintained exclusively in electronic form.

New regulations enable the completion of proceedings initiated under Regulation (EC) No 1013/2006. Permits issued in accordance with the previous regulations remain valid for the period specified therein, provided that the final recovery of the waste is completed:

• until 20 May 2027, if the customer’s installation is not covered by a preliminary authorisation,
• until 20 May 2029, provided that the customer’s installation is covered by a preliminary authorisation.

Przemysław Kurowicki, an expert on transboundary waste shipments, provided a detailed explanation of the new rules on waste shipments and the operation of the DIWASS system during a free Interzero webinar:

Who is required to use the DIWASS system?

The obligation to register with and use DIWASS rests with all entities involved in TPO, namely:

• the party submitting the TPO,
• organiser of the movement,
• carrier,
• recipients,
• waste producers,
• the operator of a waste treatment plant.

Before submitting the first documents Entities subject to the obligation must register with the DIWASS system. During registration, they must provide their main identification number – the EORI number, or, if this is not available, their NIP – as well as the required registration numbers, in particular the REGON number and the BDO number. Registration requires approval by the Chief Inspector of Environmental Protection (GIOŚ).

It will be possible to submit data and documentation via the DIWASS system once the registration has been approved by GIOŚ.

The DIWASS system will also be used by authorities responsible for handling notifications and supervising TPO. Currently, in Poland, these powers are held by the Department for the Transboundary Movement of Waste at the Chief Inspectorate for Environmental Protection (GIOŚ). Access to all electronic documentation will also be granted to supervisory bodies, e.g. provincial environmental protection inspectorates, the Road Transport Inspectorate, the Border Guard, the National Revenue Administration and the Police – to the extent necessary to carry out the inspection.

What other changes does Regulation 2024/1157 introduce?

Regulation 2024/1157 not only strengthens controls on the movement of waste, but also introduces new restrictions on its export to third countries, including:

• a ban on the export of waste intended for disposal to third countries, with the exception of the EFTA countries,
• ban on the shipment of hazardous waste intended for recovery or disposal from EU Member States, OECD countries and Liechtenstein to third countries (the so-called ‘Basel ban’ amendment),
• export ban non-hazardous waste, including plastic waste to countries not covered by the OECD decision. An exception will be made for countries which have demonstrated their ability to manage such waste safely and have been included in the list maintained by the European Commission.

Read also: The EU is introducing duties on parcels from China. The new charges will apply from 1 July 2026. >>

 

Sources:

1. Regulation (EU) 2024/1157 of the European Parliament and of the Council of 11 April 2024 on the shipment of waste, amending Regulations (EU) No 1257/2013 and (EU) 2020/1056, and repealing Regulation (EC) No 1013/2006 (Text with EEA relevance)
2. Commission Implementing Regulation (EU) 2025/1290 of 2 July 2025 laying down rules for the application of Regulation (EU) 2024/1157 of the European Parliament and of the Council (EU) 2024/1157 as regards the requirements necessary to ensure interoperability between the central system enabling the electronic transmission and exchange of information and documents relating to the shipment of waste and other systems or software, as well as other technical and organisational requirements necessary for the practical implementation of such electronic transmission and exchange of information and documents

The latest consumer survey shows that purchasing decisions are increasingly being made at the packaging level. Consumers are no longer driven solely by price, product quality or brand sentiment - what the product is packaged in is becoming just as important, if not more important. If the packaging is not eco-friendly and does not meet their environmental expectations, they are ready to reach for an alternative without hesitation.

Recycling above all

The European Association of Carton and Cardboard Packaging Manufacturers Pro Carton conducted a study The Power of Packaging. What Makes European Consumers Trust, Stay, or Switch?, which provides an understanding of how European consumers perceive the environmental aspects of packaging and packaging materials. It shows that in 2026, the most important packaging features for consumers are:

• ease of recycling (64%),
• made from renewable raw materials (40%),
• resealable (39%),
• convenience of opening (35%).

This means that messages about recycling and the origin of raw materials on packaging cease to be a marketing add-on and start to determine consumers' everyday choices and have a real impact on brand image. However, this impact can be twofold, and its nature depends mainly on the reliability of the producer. Truly sustainable packaging builds trust in the product and increases customer loyalty (as declared by 66% respondents). Packaging greenwashing, on the other hand, can alienate consumers not only from the product itself, but also from the brand as a whole. Gen-Z is definitely at the forefront of this issue. one in three 17-29 year olds abandons a purchase if they suspect greenwashing[i].

Packaging more important than the product? The new reality in the B2C sector

As it turns out, many consumers judge an entire product by its packaging. However, this is not about aesthetics or design, but about ecology and sustainability. When reaching for a packaged product, as many as 85% of the 5,000 respondents think about its impact on the climate, and 15% say they do so at every opportunity. Consideration is also followed by action -. 37% respondents admitted that they had swapped the product they were currently buying for a competing brand precisely because of concerns about its packaging. Again, Gen-Z representatives were the most radical on this issue, with as many as 54% of them abandoning their purchase because of the packaging. The most common allegations were:

• packaging not recyclable (53%),
• excessive packaging (39%),
• use of plastic (33%).

Unrecyclable, excessive or plastic packaging can therefore directly reduce sales, and this even if the product itself meets all consumers' quality expectations.

Consumers and legislation are beginning to speak with one voice

The conclusions of Pro Carton's study clearly coincide with the direction of legislative changes introduced in recent years in the European Union -. packaging is to be minimised, easily recycled and made of sustainable materials. Thus, manufacturers are under increasing pressure and need to make green changes not only because of potential penalties for non-compliant packaging, but also because of the real risk of a loss of competitiveness and revenue.

In some cases, consumer expectations are ahead of legislation. A good example of this is the design of packaging with a view to later recycling - according to the PPWR, businesses only have to eco-design packaging from 1 January 2030, but according to consumers, they should be doing this now.

Beats plastic head-on and wins the hearts of end-users - 84% consumers choose paper

The data is clear - 84% of respondents prefer to buy a product wrapped in paper rather than the same product in plastic. This percentage increases with the age of the respondents, and is as high as 92% among seniors.

The popularity of paper is supported not only by its real environmental potential, but also by good PR. Significant This is because the majority of consumers (86-87%) believe that paper, cardboard and corrugated board packaging will indeed be recycled at the end of its life cycle. Respondents put less faith in glass (82%), paper cups (75%), metal (62%), rigid plastics (60%), plastic beverage cups (54%) and flexible plastics (53%).

Ecological packaging as a to be or not to be for the producer and his brand

In light of this data, eco-design of packaging is becoming a natural response to both market expectations and upcoming legislative requirements. Entrepreneurs are therefore faced with the challenge of reconciling multiple, sometimes conflicting functions in a single optimised package. In practice, this means switching to simpler material structures (and preferably monomaterials), reducing the use of additives and elements that make it difficult to recycle, and reducing the weight and volume of packaging to the minimum necessary for product protection. And all this while maintaining the distinguishing features of a manufacturer's packaging on the shop shelf, which seems difficult to achieve. Why?

PPWR Regulation may result in the standardisation and unification of packaging for products in the same category in terms of shape, colour, type of closure and type of label, among others. The minimisation of packaging alone will reduce the space previously devoted to the marketing function. At the same time, it is worth bearing in mind that space will shrink even further with the introduction of new mandatory segregation labels and digital product passports. Manufacturers who want to maintain sales levels in the future and remain competitive should therefore start work on eco-design as soon as possible - as long as long vacatio legis gives them plenty of time to implement new, more environmentally friendly packaging, consumers expect and even demand it today. If they do not receive them, they will unsentimentally switch to competitors' products.

Find out about our packaging eco-design service >>.

Check that your packaging is PPWR compliant >>

 

Sources:

1. Greenwashing? Not for Gen Z. Young consumers bet on transparency [SURVEY]., https://omnichannelnews.pl/2025/11/04/greenwashing-nie-dla-gen-z-mlodzi-konsumenci-stawiaja-na-transparentnosc-badanie/
2. Pro Carton, The Power of Packaging What Makes European Consumers Trust, Stay, or Switch?, https://www.procarton.com/wp-content/uploads/2026/03/Pro-Carton-Consumer-Study-2026-Final-Edit-1.pdf

The deposit system in Poland has raised many questions and controversies from the outset, especially among industries that found themselves in it „by the way”, so to speak. One of these was pharmacies and the HoReCa sector, which - although not typical beverage outlets - were covered by the obligations under the legislation. However, the draft amendment to the Packaging Act shows that the legislator is beginning to recognise the specificity of these entities and respond to their demands.

Pharmacies excluded from deposit scheme - latest change in bill

The appeals of the Supreme Pharmaceutical Chamber and representatives of the pharmaceutical industry have finally had an effect - it seems that the soon large pharmacies will no longer have to collect empty drinks containers. On 20 March 2026, the following was published on the website of the Government Legislation Centre an updated version of the draft amendment to the Packaging and Packaging Waste Act (UC100), which meets the expectations of pharmacists. In fact, Article 133(8) states excluding pharmacies, pharmacy outlets and pharmaceutical wholesalers from the obligation to participate in the deposit scheme in terms of:

• collection of packaging and packaging waste,
• return of deposits,
• to conclude contracts with any representative entity that wishes to do so.

If the aforementioned provision of the law is passed unchanged, all pharmacies will be officially excluded from the deposit scheme, including those with a sales area of more than 200 m². Pharmacies will, however, retain the right to participate voluntarily in the system and to run collection points.

Read also: A deposit system will increase the carbon footprint of PET bottles >>

How did pharmacies get into the bail system and how will they leave it?

With the launch of the deposit system in Poland, all pharmacies with a retail area of more than 200 m² have automatically become collection points for deposit packaging. Why? The assortment of each of them contained products recognised by the Act as packaged beverages, i.e. liquid food for special medical purposes, liquid dietary supplements or mineral water, thus making large pharmacies and pharmaceutical wholesalers meet the statutory definition of a retail and wholesale unit.

The original version of the bail law did not provide exemptions for pharmacies - As the Ministry of the Environment argued, the obligation to run a collection point covered a small number (maximum 20) of outlets across Poland. In addition, most of them were located in shopping centres, so, according to the ministry, pharmacists did not have to collect the bottles directly - they could use, for example, bottle machines. However, these explanations did not satisfy the pharmaceutical community. Industry representatives stressed that a pharmacy is a public health facility, not a shop. Furthermore, pharmacies contribute to the environment anyway by collecting unwanted and out-of-date medicines.

The Ministry of Climate and Environment remained adamant, justifying its position with the need to keep the bail-in system watertight. This only changed with the publication of the draft amendment, which responded not only to the needs of the pharmaceutical industry, but also of HoReCa.

HoReCa outside the bail system, but under certain conditions

The amendment to the bail law is also expected to simplify bail settlement operations in the HoReCa sector. Hoteliers, restaurateurs and catering owners selling beverages in containers covered by the deposit system will be able to waive the collection of security deposits, if they fulfil all of the following conditions:

• packaging will be opened on the premises,
• the drink will be consumed on the premises,
• empty packaging or packaging waste will be returned to the premises.

Ministerial the bill is currently in the early stages of legislative work - has already been submitted to the Joint Committee of the Government and Local Self-Government for its opinion, and will then go to the Committee of the Council of Ministers for Digitalisation. The course of the legislative process can be followed on the website of the Government Legislation Centre.

Read also: Glass bottles, however, outside the deposit system >>