PPWR in Poland: what companies need to know about EU packaging rules

PPWR in Poland has, as a general rule, applied directly since 12 August 2026 and covers all packaging and packaging waste. Companies doing business in Poland already need to verify packaging composition, conformity and documentation, while further requirements concerning recycling, labelling, empty space and reuse will be phased in.

What does PPWR mean for companies in Poland?

The Packaging and Packaging Waste Regulation (PPWR) is Regulation (EU) 2025/40 and replaces Directive 94/62/EC. It is directly applicable throughout the European Union.

For companies operating or investing in Poland, PPWR reaches beyond waste management. It also covers packaging design, composition, labelling, documentation, placing packaging on the market, reuse and recycling.

Which requirements already apply?

The total concentration of lead, cadmium, mercury and hexavalent chromium in packaging or its components must not exceed 100 mg/kg.

Restrictions also apply to PFAS in food-contact packaging. Packaging containing PFAS at concentrations equal to or above the limits established by PPWR may not be placed on the market.

Conformity assessment, technical documentation and the EU declaration of conformity are also important. Before placing packaging on the market, an importer should verify that the manufacturer has carried out the required assessment and prepared the relevant documentation.

Which businesses are responsible?

PPWR covers manufacturers, importers, distributors and producers for extended producer responsibility (EPR) purposes.

A single organisation may perform several roles depending on the product, how packaging is sourced, its country of origin and the market where the product is sold. For companies importing finished packaged products into Poland from outside the EU, missing supplier information may affect whether the product can be placed on the market.

When will further PPWR requirements apply?

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.

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.

For grouped, transport and e-commerce packaging, the maximum empty-space ratio will be limited to 50% from 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later.

PPWR also introduces minimum recycled-content levels for certain plastic packaging and reuse targets for selected packaging categories.

How should companies prepare?

Businesses should:

• identify all relevant packaging categories,
• determine their PPWR role for individual product flows,
• review supplier documentation and material data,
• assign responsibility for conformity assessment and technical documentation,
• identify packaging that will need changes at later implementation stages,
• incorporate PPWR requirements into product design and supplier negotiations.

For companies developing business in Poland, PPWR should therefore be treated as an ongoing compliance process. Requirements already applicable need to be addressed while packaging portfolios are prepared for further regulatory stages.

Read the full article here: PPWR in Poland: what companies need to know about EU packaging rules.