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PPWR 2026: new packaging obligations, new responsibilities and new ESG risks

Understanding the new regulatory responsibilities, ESG issues and the impacts on European supply chains
12 August 2026 by
Paulina Valorière


Since 12 August 2026, the European regulation on packaging and packaging waste (PPWR – Packaging and Packaging Waste Regulation) is applicable throughout the European Union. It gradually replaces the old directive 94/62/EC and establishes a harmonised legal framework for packaging and packaging waste within the European internal market. 

The objectives are clear: reduce packaging waste, improve recycling and accelerate the transition to a circular economy. 

For businesses, however, it is not just a new environmental regulation. The PPWR also becomes a topic of governance, regulatory compliance and ESG.

The PPWR concerns far more businesses than one might think

The regulation applies to all packaging placed on the European market, regardless of their material, origin or sector of activity. The following are particularly concerned:

Automotive and heavy goods sector

The regulation is particularly relevant for:

  • automotive parts manufacturers;
  • suppliers;
  • tier 1 and tier 2 suppliers;
  • the manufacturers of spare parts ;
  • the manufacturers of accessories ;
  • the companies specialising in custom parts ;
  • the suppliers of equipment for motorsport and off-road.

Other relevant sectors

  • mechanical engineering ;
  • electrical engineering ;
  • chemical industry ;
  • medical devices ;
  • construction materials and components ;
  • aerospace and space ;
  • consumer goods.

Trade and distribution

  • wholesale trade ;
  • retail trade ;
  • e-commerce ;
  • marketplace sellers ;
  • importers ;
  • fulfillment service providers ;
  • private label brands.

A new distribution of responsibilities

One of the most important aspects of the PPWR concerns the definition of roles and responsibilities within the supply chain.

The regulation notably distinguishes :

The manufacturer of the packaging (Manufacturer)

The manufacturer is responsible for the compliance of the packaging. They must ensure that it meets the applicable requirements before it is placed on the market. 

The producer under extended producer responsibility (Producer)

The producer is notably responsible for financing the collection, recovery, and management systems for packaging waste in the relevant member state. 

According to the adopted business model, these two roles can be assumed by a single entity or by different actors.

The European Commission clarifies the situation for shipping packaging

In its guidance documentation regarding the PPWR, the European Commission provides several important clarifications concerning the packaging used for the shipment of goods. [eur-lex.europa.eu]

A shipping label is not enough

The mere act of affixing a shipping label to a box does not automatically make the shipping company the manufacturer of the packaging. [eur-lex.europa.eu]

When a trader uses a standard neutral box without any brand or logo and only adds a shipping label, the manufacturer of the box remains, in principle, the manufacturer of the packaging in the sense of the regulation. [eur-lex.europa.eu]

Branded packaging can lead to new obligations

The situation may be different when the packaging bears:

  • the name of the company;
  • a logo;
  • a trademark;
  • a private label.

In this case, the company concerned may be considered the manufacturer of the packaging and may have to assume certain regulatory obligations. 

Filling materials do not automatically create new packaging

The Commission also clarifies that the use of multiple packaging components does not automatically lead to the creation of new packaging. 

This particularly concerns:

  • adhesive tape ;
  • the cushioning materials ;
  • the protective films ;
  • the stretch films ;
  • the pallets ;
  • the additional protective elements.

These operations generally do not transform the trader or the sender into a manufacturer of new packaging. 

Why the PPWR is also an ESG topic

At first glance, the PPWR seems to fall under environmental law. In reality, it touches on the three pillars of ESG.

E – Environmental

  • waste reduction ;
  • recyclability ;
  • use of recycled materials ;
  • circular economy ;
  • resource efficiency.

S – Social

  • transparency for consumers ;
  • supply chain transparency ;
  • product safety ;
  • responsible purchasing.

G – Governance

  • regulatory compliance ;
  • risk management ;
  • documentation of responsibilities ;
  • internal control ;
  • traceability of decisions.

ESG governance starts with identifying responsibilities

The PPWR perfectly illustrates the current evolution of regulatory requirements.

The question is no longer solely :

« Is our packaging compliant ? »

The question also becomes :

« Can we demonstrate who is responsible for what within our organisation and our supply chain ? »

Companies today must be able to identify and document :

  • the applicable regulatory roles ;
  • the internal responsibilities ;
  • the obligations of their suppliers ;
  • the control processes ;
  • the compliance monitoring mechanisms ;
  • the available evidence.

This capability becomes essential during :

  • audits ;
  • supplier assessments ;
  • ESG due diligences ;
  • funding requests ;
  • investments ;
  • regulatory checks.

ESG is not only about large companies

Even when a company is not directly subject to formal ESG reporting obligations, it may be required to provide detailed information to :

  • its banks ;
  • its investors ;
  • its industrial clients ;
  • its contractors ;
  • certification bodies.

The PPWR is a concrete example of this evolution.

A company that does not master its regulatory responsibilities will increasingly struggle to demonstrate the robustness of its governance and compliance framework.

Conclusion

The PPWR is much more than an environmental regulation.

It changes the distribution of responsibilities within supply chains, strengthens compliance requirements, and highlights the growing importance of ESG governance.

For manufacturers, equipment suppliers, importers, distributors, and e-commerce players, the ability to identify, document, and demonstrate regulatory responsibilities is becoming a true competitive factor.

The key question is therefore no longer just:

"Does our packaging meet the new requirements?"

But also:

"Are we able to clearly and documentably demonstrate who holds responsibility within our organisation and our supply chain?"

How TMWP can support you

TMWP EUwise Advisors supports companies in integrating regulatory requirements within their ESG and Compliance frameworks.

Our services include:

✅ ESG and Compliance assessments

✅ Analysis of responsibilities under the PPWR and extended producer responsibility (EPR)

✅ Mapping of regulatory responsibilities in the supply chain

✅ Support for manufacturers, importers, distributors, and e-commerce platforms

✅ ESG governance and documentation of responsibilities

✅ Preparation for audits, inspections, and due diligence

✅ Management of regulatory risks related to access to the European market

Get in touch with TMWP

Do you want to understand the impact of the PPWR on your business?

TMWP helps you identify your obligations, secure your internal processes, and build ESG governance tailored to the requirements of the European market.

Contact our team for a personalised ESG & Regulatory Readiness Check and discover how to turn new regulatory obligations into a competitive advantage.


Paulina Valorière 12 August 2026
Tags
Commission européenne Gouvernance ESG Responsabilité élargie du producteur (REP) Règlement sur les emballages et les déchets d'emballages (PPWR) Union européenne (UE)
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