The EU Packaging and Packaging Waste Regulation (PPWR) is changing the way packaging is designed, used and managed across the European Union.

For UK businesses selling packaged products into the EU, the regulation is particularly important.

In simple terms: if your UK business places packaged products on the EU market, PPWR may apply to the packaging you use. The regulation introduces requirements covering areas including packaging minimisation, recyclability, labelling, recycled content for certain plastic packaging, reuse and producer responsibility. PPWR generally applies from 12 August 2026, although many individual requirements are phased in over later dates.

For businesses using cardboard boxes, one of the most important themes is straightforward: avoid unnecessary packaging and use packaging that is appropriately designed for the product it protects.

This Q&A explains what UK businesses need to know and how choosing the right packaging now could help you prepare.

What is the EU Packaging and Packaging Waste Regulation (PPWR)?

The Packaging and Packaging Waste Regulation (EU) 2025/40, commonly known as PPWR, replaces the previous EU Packaging and Packaging Waste Directive.

Unlike a Directive, an EU Regulation applies directly across EU Member States.

The regulation aims to reduce packaging waste and move towards a more circular approach to packaging. It introduces requirements covering the design, composition, recyclability, reuse, labelling and management of packaging placed on the EU market.

When does PPWR start?

PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026.

However, this does not mean every PPWR requirement begins on the same day.

A number of important requirements, targets and implementation measures are phased in over subsequent years.

Businesses should therefore identify which provisions apply to their particular packaging and the dates on which those obligations take effect.

Does every PPWR requirement start on 12 August 2026?

No.

Although PPWR generally applies from 12 August 2026, individual requirements have different implementation dates.

For example, specific requirements relating to excessive packaging and empty space have later deadlines, while other provisions depend upon future implementing or delegated acts from the European Commission.

Businesses should therefore avoid treating PPWR as a single compliance deadline.

Does PPWR apply to UK businesses?

It can.

PPWR is an EU regulation, but UK businesses that place packaged goods on the EU market will need to comply with the applicable requirements.

UK Government guidance specifically advises UK exporters to review their obligations when selling packaged goods into the EU.

You should investigate your PPWR responsibilities if your business:

• Exports packaged products directly to customers in the EU.
• Supplies EU retailers or distributors.
• Sells packaged products into EU countries through online marketplaces.
• Manufactures or supplies packaging that will be placed on the EU market.
• Operates in or supplies relevant products into Northern Ireland.

If you only sell within Great Britain, PPWR does not automatically apply simply because your products use packaging. Separate UK packaging legislation, including Extended Producer Responsibility (EPR), may apply to your business.

Does PPWR apply in Northern Ireland?

PPWR will apply in part directly in Northern Ireland under the Windsor Framework.

Businesses placing products on the Northern Ireland market should therefore check the specific requirements that apply to them rather than assuming the position is identical to either Great Britain or the EU.

The Department of Agriculture, Environment and Rural Affairs (DAERA) provides dedicated guidance for Northern Ireland businesses.

Does PPWR apply to cardboard boxes?

Yes, where the packaging is within the scope of PPWR and is placed on the relevant market.

PPWR covers packaging broadly, including primary, secondary, transport and other packaging categories. UK Government guidance states that the regulation covers all packaging types when applicable.

Corrugated cardboard transit and e-commerce boxes therefore need to be considered as part of a business's overall PPWR review.

What are the main requirements of PPWR?

PPWR is extensive, but some of the areas most relevant to businesses include:

• Packaging recyclability.
• Packaging minimisation.
• Restrictions on unnecessary packaging.
• Empty-space requirements.
• Recycled-content targets for certain plastic packaging.
• Labelling requirements.
• Reuse and refill requirements for certain packaging.
• Extended Producer Responsibility.
• Restrictions relating to certain substances in packaging.

Not every requirement applies to every type of packaging or business, and different provisions have different implementation dates.

Does PPWR mean packaging must be recyclable?

PPWR introduces requirements intended to ensure packaging placed on the EU market becomes recyclable under the framework established by the regulation.

The requirements are phased in and include recyclability performance grades and recyclability-at-scale considerations.

For businesses, the important point is that packaging design will increasingly need to consider what happens to the packaging after use, rather than focusing solely on protecting the product during transport.

Is corrugated cardboard well placed for PPWR?

Corrugated cardboard can provide a strong starting point.

It is widely collected and recycled, and made-to-measure corrugated packaging can help businesses reduce unnecessary material and empty space.

However, compliance depends on the complete packaging specification, not simply whether the main material is cardboard.

Businesses should also consider components such as:

• Coatings.
• Laminates.
• Plastic windows.
• Tapes.
• Labels.
• Adhesives.
• Inserts.
• Other materials combined with the cardboard.

The complete packaging solution should therefore be reviewed.

Does PPWR ban oversized packaging?

PPWR specifically addresses unnecessary packaging and excessive empty space, although the relevant requirements are phased in.

Under Article 24, economic operators filling grouped, transport or e-commerce packaging will ultimately be required to ensure a maximum empty-space ratio of 50%, subject to the detailed rules and applicable date.

Importantly, materials used to fill empty space—including paper cuttings, air cushions, bubble wrap, foam and similar filling materials—are treated as empty space for this calculation.

There are also specific provisions and exemptions that businesses need to consider.

This makes right-sized packaging increasingly important.

When does the 50% empty-space requirement apply?

The 50% maximum empty-space requirement for grouped, transport and e-commerce packaging applies from 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later.

The European Commission is required to establish the methodology for calculating the empty-space ratio through implementing acts by 12 February 2028.

Businesses should therefore avoid assuming that the 50% requirement applies from August 2026.

What counts as empty space?

Under PPWR, empty space can include more than simply air inside a box.

For the relevant requirement, space occupied by filling materials such as:

• Paper cuttings.
• Air cushions.
• Bubble wrap.
• Sponge fillers.
• Foam fillers.
• Wood wool.
• Polystyrene or Styrofoam chips.

is considered empty space.

This is particularly relevant to businesses currently using oversized stock boxes and then filling the remaining space with protective materials.

How can made-to-measure cardboard boxes help?

This is where reviewing your packaging dimensions can make a significant difference.

A standard stock box may be substantially larger than the product being shipped.

That can result in:

• Unnecessary cardboard.
• More empty space.
• Greater use of void fill.
• More movement during transit.
• Increased storage requirements.
• Potentially higher shipping costs.

A made-to-measure cardboard box can be manufactured much closer to the dimensions of the product.

This can help businesses reduce unnecessary packaging while still providing the protection required during storage and transport.

At ASC Direct, custom cardboard boxes can be manufactured from just 25 units, allowing businesses to test and introduce right-sized packaging without committing immediately to thousands of boxes.

Does PPWR mean I should remove all empty space from my boxes?

No.

Packaging still needs to perform its primary function: protecting the product.

PPWR recognises that some products require space for protection or because of their characteristics.

The objective isn't simply to make every box as small as physically possible. Businesses need to balance packaging minimisation with product protection and functionality. Article 24 specifically provides for characteristics such as irregular shapes and products requiring protection when developing the calculation methodology.

A box that uses less cardboard but results in damaged products is unlikely to represent a sensible packaging solution.

Could custom-sized boxes reduce shipping costs as well?

Potentially, yes.

Many courier and parcel networks take parcel dimensions as well as weight into consideration.

Reducing unnecessary box volume can therefore have benefits beyond packaging compliance.

A better-fitting box may help businesses:

• Reduce void fill.
• Improve pallet utilisation.
• Use warehouse space more efficiently.
• Fit more parcels into transport vehicles.
• Reduce dimensional or volumetric shipping charges where these apply.

This means reviewing packaging size can make commercial sense independently of PPWR.

Is FSC® certification the same as PPWR compliance?

No. They address different issues.

PPWR establishes regulatory requirements relating to packaging and packaging waste placed on the relevant market.

FSC® certification relates to the responsible sourcing of forest-based materials and the Chain of Custody through which certified material passes.

ASC Direct manufactures cardboard boxes using FSC® Mix certified corrugated board under our FSC® Chain of Custody certification.

FSC® Licence Code: FSC® C218342.

The corrugated board used to manufacture ASC Direct boxes also contains a minimum of 70% recycled material.

These are important packaging credentials, but FSC® certification should not be interpreted as meaning that a particular packaging specification automatically complies with PPWR.

Is recycled cardboard automatically PPWR compliant?

No.

Using recycled material and complying with PPWR are not the same thing.

PPWR covers numerous aspects of packaging, including design, recyclability, minimisation, labelling and other requirements.

A business should therefore review the complete packaging specification and the particular PPWR provisions that apply to it.

Do small businesses need to comply with PPWR?

Businesses should not assume they are outside PPWR simply because they're small.

UK Government guidance states that businesses placing packaging on the EU market can fall within the regulation and notes that micro-enterprises may benefit from lighter rules in some areas while still being subject to core obligations.

The precise obligations depend on factors including the business's role in the supply chain, packaging type and market.

What is Extended Producer Responsibility under PPWR?

Extended Producer Responsibility, or EPR, places responsibilities on producers for packaging after it becomes waste.

UK exporters should pay particular attention to this because EPR requirements can involve registration and reporting in the EU countries where products are sold.

UK Government guidance advises exporters to investigate the relevant national EPR schemes, registration requirements, reporting obligations and whether an authorised representative is required.

This should not be confused with the UK's own packaging EPR system, which has separate requirements.

What should UK businesses do now?

If your business places packaged products on the EU market, now is the time to understand how PPWR affects you.

A practical starting point is to:

1. Identify where your packaged products are sold.
   Establish whether you're placing products on the EU or Northern Ireland markets.
2. Audit your current packaging.
   Record the materials, dimensions, weights and components used.
3. Look for unnecessary packaging.
   Identify oversized boxes, excessive void fill and unnecessary components.
4. Review recyclability.
   Consider the complete packaging specification, not simply its primary material.
5. Understand your EPR responsibilities.
   Requirements may differ between EU Member States.
6. Collect packaging data.
   Ensure you can access the information necessary for future reporting and compliance.
7. Speak to your packaging suppliers.
   Ask for relevant information about the materials and specifications you're purchasing.

UK Government guidance similarly recommends that exporters assess their packaging, understand their obligations, investigate applicable EPR schemes and ensure the necessary data is collected.

PPWR Timeline

11 February 2025

PPWR entered into force.

12 August 2026

PPWR generally starts to apply.

12 February 2028

The Commission is due to establish the methodology for calculating the relevant empty-space ratio.

2030 onwards

A number of significant packaging requirements and targets become applicable, subject to the dates and conditions set out in the regulation.

PPWR contains numerous individual deadlines, so businesses should check the requirements relevant to their particular packaging rather than relying on this simplified timeline.

How ASC Direct Can Help

PPWR places greater attention on how packaging is designed and how much packaging is actually necessary.

That's an area where made-to-measure cardboard boxes can offer a practical advantage.

Rather than adapting your products to fit an oversized stock box, ASC Direct can manufacture corrugated cardboard boxes around the dimensions you actually require.

Our customers benefit from:

• Custom-sized cardboard boxes from just 25 units.
• 1-Day Express, 3-Day Standard and 10-Day Economy production options.
• UK manufacturing.
• Single wall and double wall corrugated board options.
• Plain and printed packaging.
• FSC® Mix certified corrugated board.
• Corrugated board containing a minimum of 70% recycled material.
• Instant online pricing.

Whether you're reviewing packaging because of PPWR, trying to reduce void fill or simply looking for a better-fitting box, our team can help you find an appropriate packaging solution.

Frequently Asked Questions About PPWR

Does PPWR apply to UK companies?

PPWR can apply to UK companies that place packaged goods on the EU market. Businesses operating in or supplying relevant products into Northern Ireland should also check the specific PPWR provisions applying under the Windsor Framework.

When does PPWR come into effect?

PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026. Individual requirements have different implementation dates.

Does PPWR apply if I only sell in Great Britain?

PPWR does not automatically apply to a business simply because it uses packaging in Great Britain. However, separate UK packaging regulations, including EPR requirements, may apply.

Does PPWR apply to e-commerce packaging?

Yes, e-commerce packaging is specifically addressed within PPWR. Among other requirements, Article 24 introduces a future maximum empty-space ratio for relevant grouped, transport and e-commerce packaging.

Will PPWR stop businesses using oversized boxes?

PPWR introduces packaging minimisation and excessive-packaging requirements. For relevant grouped, transport and e-commerce packaging, a maximum empty-space ratio of 50% is due to apply from the date specified in Article 24.

Is cardboard automatically PPWR compliant?

No. The complete packaging specification and applicable regulatory requirements need to be considered. Using corrugated cardboard alone does not guarantee PPWR compliance.

Can custom cardboard boxes help with packaging minimisation?

Yes. Manufacturing a box closer to the dimensions of the product can reduce unnecessary material and empty space while maintaining the protection required for transport.

Reviewing Your Packaging for PPWR?

PPWR represents a significant change in how packaging is regulated within the EU.

For UK businesses exporting into Europe, the important message is not to panic—but don't ignore it either.

Understanding what packaging you're currently using, where your products are sold and which requirements apply to your business is an important first step.

For corrugated packaging users, reviewing box size, unnecessary empty space, materials and overall packaging design can also uncover opportunities to reduce waste and potentially lower costs.

ASC Direct specialises in made-to-measure cardboard boxes, allowing businesses to order packaging manufactured around their products rather than compromising with the nearest standard size.

And with custom boxes available from just 25 units, you don't need to commit to thousands of boxes to start improving your packaging.

Build your custom box with ASC Direct today.

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Important information

This article provides general information about the EU Packaging and Packaging Waste Regulation and should not be considered legal or regulatory compliance advice. PPWR is a detailed regulation with requirements that vary according to packaging type, economic operator and implementation date. Businesses should review the official legislation and relevant European Commission and UK Government guidance and obtain specialist advice where appropriate.

Last updated: August 2026

James Palfrey-Smith is the General Manager at ASC Direct with extensive experience in both operations and sales. James is passionate about solving packaging problems, delivering fast customer support, and building lasting relationships. Outside of work, he enjoys outdoor activities like hiking and skiing. A fan of real ale and business podcasts, he continuously seeks personal and professional growth. 

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