EU Packaging and Packaging Waste Regulation (PPWR)
As of 12 August 2026, Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) is directly applicable throughout the EU, replacing the previous Packaging and Packaging Waste Directive. The European Commission published updated FAQs on 3 August 2026, complementing its June 2026 Guidance Document.
Although these documents are not legally binding, they provide an important indication of how the European Commission interprets the Regulation and may influence how national authorities approach enforcement.
The PPWR introduces a harmonised framework covering the entire life cycle of packaging, from design and manufacture through use, collection and recycling. Its scope is therefore considerably broader than consumer packaging and extends to industrial, transport and logistics packaging.
Key requirements include:
- Recyclability and minimum recycled content, particularly for plastic packaging;
- Reduction of unnecessary or excessive packaging;
- Restrictions on certain substances of concern, including PFAS in food-contact packaging;
- Increased re-use requirements and restrictions on certain single-use formats;
- New labelling and information requirements;
- Conformity assessment and technical documentation, including an EU Declaration of Conformity; and
- Extended Producer Responsibility (EPR), placing financial and organisational responsibility for packaging waste on relevant producers.
Who is the "manufacturer"?
One of the most important practical issues clarified by the Commission concerns the definition of the manufacturer.
Where packaging carries a company's name or trademark, that company may be considered the manufacturer, even if the packaging is physically produced or filled by another company. Similarly, for unbranded packaging, the company ordering the packaging and determining its design specifications may assume manufacturer responsibilities.
This means that companies cannot necessarily transfer PPWR responsibilities simply by outsourcing packaging production.
The updated FAQs also clarify the position for flexible transport packaging, such as stretch film and pallet wrap. The Commission considers such material to already constitute packaging when supplied on a roll. Consequently, the physical producer of the unbranded packaging is generally regarded as the manufacturer, rather than the company subsequently using the film to secure goods.
This interpretation is particularly relevant to industrial supply chains where packaging is sourced from specialist suppliers.
Transitional arrangements
The Commission has also provided limited transitional relief for packaging that was already manufactured and held in stock before 12 August 2026, but had not yet been placed on the EU market.
Such packaging does not automatically have to be destroyed, re-manufactured or re-labelled to meet the new manufacturer-identification requirements. However, businesses should retain appropriate documentation and make reasonable efforts to establish the relevant manufacturer information.
What does this mean for ESA and the sealing industry?
For ESA members, the PPWR should not be viewed solely as a regulation concerning consumer packaging. Industrial sealing products are frequently supplied in packaging, including cardboard boxes, plastic bags, films, pallets, protective materials and other transport packaging. Consequently, the Regulation may create several challenges for the sealing industry.
1. Packaging materials will need to be reassessed
ESA members may need to review the materials currently used to package its products. Particular attention should be given to plastic films, bags, foams, tapes and protective packaging, where recyclability and recycled-content requirements may become increasingly relevant.
2. PFAS and packaging requirements may overlap
The PPWR introduces restrictions concerning PFAS in food-contact packaging. While this does not automatically mean that PFAS-containing sealing materials are prohibited under the PPWR, it creates another regulatory interface between PFAS legislation and packaging legislation.
ESA should therefore continue to monitor how the PPWR interacts with the wider EU PFAS restriction process and other chemicals legislation.
3. Increased documentation and conformity obligations
Where ESA members are considered the manufacturer of packaging, they may face new requirements for technical documentation, conformity assessment, declarations of conformity and information management.
This could represent an additional administrative burden, particularly for companies purchasing packaging from several suppliers or operating across multiple EU markets.
4. Greater pressure on plastic packaging
The PPWR's objectives around recyclability, recycled content and reduction of virgin plastics are likely to accelerate the move towards more sustainable packaging solutions.
This could provide an opportunity for ESA members to investigate alternatives such as recyclable mono-material packaging, recycled-content materials, biodegradable/compostable solutions where technically and environmentally appropriate, and packaging optimisation.
5. Supply-chain responsibilities need clarification
ESA members should establish clearly who is considered the manufacturer, importer or producer of packaging within their particular supply chain. Branding, purchasing arrangements and contractual responsibilities can influence the allocation of PPWR obligations.
This is particularly important where packaging is manufactured by third parties.
6. Potential cost implications
Compliance may increase the cost of packaging through:
- alternative packaging materials;
- recycled-content requirements;
- redesign and testing;
- labelling;
- documentation and conformity assessment;
- EPR contributions; and
- potentially more complex supplier qualification and auditing.
These costs may ultimately affect the overall cost of sealing products.
Potential role for ESA
The PPWR could therefore become another relevant ESG and regulatory topic for ESA, alongside PFAS, the Drinking Water Directive, ESPR/Digital Product Passport and other EU sustainability initiatives.
ESA could consider:
- Monitoring the implementation and interpretation of PPWR at EU and Member State level;
- Assessing the packaging practices of ESA members to identify common challenges;
- Developing industry guidance or a practical checklist for sealing manufacturers;
- Clarifying the applicability of PPWR requirements to different types of sealing-product packaging;
- Exploring sustainable packaging solutions across the five ESA divisions;
- Sharing best practices on recyclable, recycled-content and reduced-plastic packaging; and
- Maintaining dialogue with relevant EU industry associations and authorities where the Regulation creates disproportionate or technically unclear requirements for industrial sealing products.
Conclusion
For the sealing industry, the immediate impact may be less about the sealing products themselves and more about how those products are packaged, labelled, documented and placed on the EU market.
ESA members should therefore review their packaging supply chains, contractual arrangements, branding practices and packaging materials rather than assuming that responsibility rests solely with their packaging suppliers.
From an ESA perspective, the PPWR also presents an opportunity: reducing packaging waste, plastic consumption and environmental impact can become part of the wider sustainability strategy of the European sealing industry.
Sandy Van den Broeck,
ESG Director, ESA