PPWR in Poland: what companies need to know about EU packaging rules
PPWR has applied across the EU, including Poland, since 12 August 2026, with further packaging obligations phased in over time.
PPWR applies to all packaging and packaging waste in the EU, including Poland, regardless of the type of material used.
The total concentration of lead, cadmium, mercury and hexavalent chromium in packaging or its components must not exceed 100 mg/kg.
Food-contact packaging containing PFAS at concentrations equal to or above the limits set by PPWR may not be placed on the market.
Design-for-recycling criteria are to apply from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later.
Importers bringing packaged products into Poland from outside the EU should verify conformity assessment, technical documentation and the EU declaration of conformity.
A company’s PPWR role may vary by product
One organisation may act as a manufacturer, importer, distributor or producer for EPR purposes depending on the relevant packaging flow.
Complete packaging data is essential for compliance
Without a complete packaging database, businesses may struggle to assess current compliance and the scale of future changes.
PPWR compliance requires a phased approach
Businesses need to meet requirements already in force while preparing their packaging portfolios for obligations taking effect later.
Supplier documentation can affect market access
For importers, missing information from a foreign supplier may affect whether packaged products can be placed on the market.
The Packaging and Packaging Waste Regulation (PPWR) has, as a general rule, applied directly throughout the European Union since 12 August 2026. It covers all packaging and packaging waste, regardless of the material used. Companies operating in Poland should already verify their role in the supply chain, the composition of the packaging they use and the applicable compliance and documentation requirements. At the same time, PPWR is being implemented in stages, with further obligations concerning labelling, recyclability, recycled content, packaging minimisation and reuse becoming applicable in the coming years.
PPWR changes the way businesses need to approach packaging. It does not deal solely with waste management after a product has been used. It also covers packaging design, composition, labelling, documentation, placing packaging on the market, reuse and recycling.
For businesses with extensive product portfolios, this means treating packaging as a separate area of regulatory compliance involving not only environmental teams, but also procurement, logistics, product development, sales and legal functions.
In this article:
What is PPWR?
PPWR, or the Packaging and Packaging Waste Regulation, is Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste. It replaces the former Directive 94/62/EC.
The shift from a directive to a regulation has practical significance. PPWR is directly applicable in all EU Member States, including Poland, helping to make core packaging requirements more consistent across the EU market. The Regulation is primarily intended to reduce packaging waste, increase packaging reuse and recycling, and support the circular economy. Its scope is broad: PPWR applies to all packaging, regardless of the type of material used, and to all packaging waste.
Which PPWR requirements already apply to businesses?
Since August 2026, PPWR is no longer a regulation that businesses are preparing for solely as a future requirement. Some obligations already apply.
One important area is the chemical composition of packaging. The total concentration of lead, cadmium, mercury and hexavalent chromium resulting from the presence of these substances in packaging or its components must not exceed 100 mg/kg.
Specific restrictions also apply to PFAS in food-contact packaging. PPWR sets concentration limits for these substances. Packaging containing PFAS at concentrations equal to or above those limits may not be placed on the market.
Conformity assessment, technical documentation and the EU declaration of conformity are also becoming important compliance elements. For example, before placing packaging on the market, an importer should verify that the manufacturer has carried out the required conformity assessment and prepared the relevant documentation.
This does not mean that all requirements introduced by PPWR already apply in full. The Regulation follows a phased timetable extending over the coming years.
Phased application
PPWR: what applies now vs what is coming
PPWR applies directly across the EU, including Poland, since 12 August 2026 — but it is being implemented in stages. Some obligations already apply; others are phased in over the coming years.
Already in force
What applies now
Since 12 August 2026
Chemical composition limits
Lead, cadmium, mercury and hexavalent chromium — total concentration must not exceed 100 mg/kg.
PFAS restrictions
Food-contact packaging with PFAS at or above the PPWR limits may not be placed on the market.
Conformity assessment
Importers should verify that the manufacturer has carried out the required conformity assessment.
Technical documentation
Importers should verify that the manufacturer has prepared the required technical documentation.
EU declaration of conformity
Importers should verify that the manufacturer has drawn up the EU declaration of conformity.
Prepare your portfolio
What is coming next
Phased in over the coming years
Design-for-recycling criteria
From 1 January 2030, or 24 months after the relevant delegated acts — whichever is later.
Recycled-content minimums
Minimum recycled content phased in for certain plastic packaging categories.
Harmonised labelling
From 12 August 2028 or 24 months after the relevant implementing act enters into force, whichever is later.
50% empty-space ratio
Grouped, transport and e-commerce packaging — from 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later.
Reuse targets
Introduced for selected packaging categories.
Which companies and supply-chain roles are covered by PPWR?
PPWR applies to different economic operators involved in the packaging supply chain, including manufacturers, importers and distributors, as well as entities acting as producers for extended producer responsibility purposes. The key issue is to determine the company’s role in relation to each specific item of packaging.
| Role | What does it mean in practice? |
|---|---|
| Manufacturer | is responsible in particular for ensuring that packaging complies with the relevant PPWR requirements and for the related conformity assessment obligations |
| Importer | places packaging from a third country on the EU market and is required to verify its compliance |
| Distributor | makes packaging available on the market as a subsequent operator in the supply chain |
| Producer for EPR purposes | a role linked to the first making available of packaging in the territory of a particular country and to extended producer responsibility obligations |
A single organisation may perform more than one role, depending on the product, how the packaging is purchased, its country of origin and the market in which the product is sold. For international groups, a PPWR analysis should therefore not be limited to asking “does our company fall within the scope of PPWR?”. A more useful question is who is responsible for each item of packaging at every stage of its movement through the group and the supply chain.
PPWR IN POLAND | PACKAGING SUPPLY CHAIN ROLES
One company can hold several PPWR roles
For companies operating in Poland, Regulation (EU) 2025/40 makes it essential to determine who is responsible for each item of packaging at every stage of the supply chain.
Packaging under PPWR
Applies to all packaging and packaging waste, regardless of material
01
Manufacturer
Responsible for ensuring packaging complies with PPWR requirements and for the related conformity assessment obligations.
02
Importer
Places packaging from a third country on the EU market and is required to verify its compliance.
03
Distributor
Makes packaging available on the market as a subsequent operator in the supply chain.
04
Producer for EPR purposes
Linked to first making packaging available in a given country and to extended producer responsibility obligations.
A single organisation may act in more than one role, depending on the product, how packaging is purchased, its country of origin and the market in which it is sold.
What changes does PPWR introduce for packaging?
The scope of the Regulation extends well beyond individual restrictions on particular materials. Ultimately, PPWR affects how businesses design, source and use packaging.
How will packaging need to be designed for recycling?
PPWR provides for the gradual introduction of requirements under which packaging will need to meet specific design-for-recycling criteria. However, the detailed requirements did not become applicable at the same time as the Regulation generally started to apply.
The design-for-recycling criteria are to apply from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later.
How will PPWR increase the use of recycled materials?
PPWR also introduces minimum levels of recycled content for certain types of plastic packaging. The requirements vary depending on the packaging category and are being phased in over time.
For businesses, this means that the availability of appropriate recycled raw materials will need to be considered when planning future packaging projects.
How will PPWR limit excessive packaging?
One of the objectives of PPWR is to reduce situations in which packaging is larger or heavier than necessary for its intended function. A particularly important change concerns e-commerce.
The requirement to limit the maximum empty-space ratio to 50% in grouped packaging, transport packaging and e-commerce packaging will apply from 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later. PPWR also provides for specific exceptions, including for reusable packaging used within a reuse system.
What new packaging labelling rules will apply?
PPWR also provides for harmonised packaging labelling to help users sort packaging waste correctly. Harmonised labels providing information on material composition are to be introduced from 12 August 2028 or 24 months after the relevant implementing act enters into force, whichever is later.
How does PPWR regulate packaging reuse?
Another element of PPWR is the introduction of reuse targets for selected packaging categories. In practice, the Regulation may therefore affect not only the material and construction of packaging itself, but also reverse logistics, supplier relationships and the way product transport is organised.
Does PPWR also apply to importers bringing products into Poland?
Yes. Importers are one of the groups of economic operators on which PPWR imposes direct obligations. An importer may place on the market only packaging that complies with the applicable requirements.
Among other things, the importer should verify that the manufacturer has carried out the conformity assessment, prepared the technical documentation and drawn up the EU declaration of conformity. This is particularly important for businesses importing finished packaged products into Poland from outside the European Union.
In this model, a lack of appropriate information from a foreign supplier may become an issue affecting whether the product can be placed on the market, rather than merely an administrative documentation gap.
Foreign companies operating in Poland may also consider these obligations as part of broader legal advisory services in Poland.
How should companies in Poland prepare for PPWR?
Preparing for PPWR should not be limited to checking a single certificate issued by a packaging manufacturer.
As a first step, businesses should:
- identify all relevant packaging categories used by the company,
- determine the company’s role under PPWR for individual product flows,
- review documentation received from suppliers, including information on material composition,
- establish responsibility for technical documentation and conformity assessment,
- assess which packaging will need to be changed during subsequent stages of PPWR implementation,
- incorporate the new requirements into product design and negotiations with packaging suppliers.
In practice, the biggest challenge for large organisations may not be any single PPWR requirement, but the absence of one complete database containing information on packaging used across different companies, countries and product lines.
Without such data, it is difficult to assess both the current level of compliance and the scale of changes required in the coming years.
Preparing for PPWR in Poland
PPWR compliance: 6 steps for companies in Poland
Preparing for PPWR is not about checking a single certificate. For companies operating in Poland, compliance is an ongoing process across packaging categories, product flows and suppliers.
1
Map your packaging
Identify all relevant packaging categories used by the company.
2
Determine your role
Manufacturer, importer, distributor or producer for EPR purposes — assessed for each product flow.
3
Check supplier data
Review supplier documentation, including information on material composition.
4
Verify documentation
Technical documentation, conformity assessment and the EU declaration of conformity.
5
Assess which packaging will need changes
Recyclability, recycled content, labelling, empty space and reuse across the later PPWR stages.
6
Build PPWR into procurement and design
Incorporate the new requirements into product design and negotiations with packaging suppliers.
The biggest challenge
The absence of one complete packaging database
Without complete packaging data, it is difficult to assess both current compliance and the scale of the changes required in the coming years.
Do all PPWR requirements already apply?
No. PPWR is being applied in stages, and individual requirements have different application dates. This includes detailed recyclability criteria, labelling, recycled-content requirements, empty-space restrictions and reuse targets.
Businesses should therefore run two processes in parallel: ensure compliance with requirements that already apply and prepare their packaging portfolios for changes scheduled for the coming years.
PPWR is therefore not a one-off regulatory project. For businesses with large portfolios of packaged products, compliance will require regular updates to data, documentation and supplier-management procedures.
For businesses operating in Poland, getsix® can support the analysis of the legal and organisational aspects of doing business and their impact on company obligations. Contact getsix®.
Legal basis
This article was written by the getsix® Editorial Teamgetsix® provides accounting, tax advisory, HR and payroll, and business consulting services, supporting companies operating in Poland. The getsix® Editorial Team prepares practical information that makes Polish accounting, tax, and HR and payroll matters easier to understand.
If you have any questions regarding this topic or if you are in need for any additional information – please do not hesitate to contact us:
CUSTOMER RELATIONSHIPS DEPARTMENT
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