[Textile Industry] The EU’s Packaging and Packaging Waste Regulation (PPWR) Explained

Between 2010 and 2021, the amount of packaging waste generated per person in the European Union surged by 22.5%, reaching an alarming total of 84.3 million tons per year. It’s expected to rise another 19% if no action is taken. 

After nearly three decades of discussion on how to tackle this problem, the EU took decisive action in 2022. It led to the creation of the Packaging and Packaging Waste Regulation (PPWR), which was formally adopted on December 16, 2024. 

This is a crucial shift for footwear and apparel brands, as the regulation imposes new standards for packaging design, materials, and waste management, which will impact everything from product shipping to retail packaging. As sustainability becomes a priority for both consumers and regulators, the footwear and apparel industry must adapt swiftly to stay compliant and competitive.

Like the numerous upcoming regulatory initiatives, we’re taking a deep dive into the PPWR to fully explain how these emergent rules will impact your business.

What is the Packaging and Packaging Waste Regulation?

Originally introduced as the Packaging and Packaging Waste Directive in 1994, the framework was designed to ultimately prevent the production of packaging waste and ensure that packaging could be reused or recycled. However, as waste levels continued to climb, EU member states struggled to transpose the directive into national law. It was all too apparent that a stronger, more harmonized approach would be necessary to effectively reduce packaging waste.

In 2022, the EU launched a revision of the directive and introduced the Packaging and Packaging Waste Regulation to create clear, consistent standards across all Member States.

Objectives of the PPWR

The PPWR serves three main objectives:

• Minimizing Packaging Waste: By focusing on waste prevention, reducing over-packaging, and promoting the use of sustainable materials, the PPWR aims to curb the rapid growth of packaging waste.
• Harmonizing the Internal Market: While the regulation seeks to harmonize the different national approaches to packaging waste management, it does allow for some flexibility to encourage innovation in response to local challenges and gradual implementation. 

Contributing to the EU’s Growth Strategy: The regulation is integral to the EU’s ambition to achieve climate neutrality by 2050, with a long-term goal of decoupling economic growth from resource use and eliminating greenhouse gas emissions.

Who Needs to Comply?

The PPWR will apply to all businesses—B2B and B2C—that manufacture, import, or sell products within the EU. This means that apparel and footwear brands will need to ensure their packaging meets new standards for sustainability, recyclability, and waste reduction.

Companies will be required to use less packaging, minimize (and in some cases ban) the use of single-use plastics, and adopt more circular packaging solutions. That means everything from polybags to shoe boxes. The PPWR officially entered into force in December 2024, making compliance mandatory for all brands—whether operating within the EU or exporting to the European market—by mid-2026, following the 18-month transition period. 

Types of Packaging Covered Under the PPWR

The PPWR defines "packaging" broadly to encompass a wide range of materials and formats used for containment, protection, delivery, or presentation of products. This regulation impacts various packaging types based on their function, material, and design.

IMPORTANT: The PPWR applies to the entire lifecycle of the packaging. That means companies aren’t just responsible for the generation of packaging, but its disposal as well. This should encourage both the reduction of packaging and the use of more sustainable materials.

For the footwear and apparel industry, packaging covers everything from protective garment bags to e-commerce shipping materials. Let’s take a look at some examples:

1. Primary (Sales) Packaging - Refers to the packaging that directly contains and protects the product, typically until it reaches the consumer. This includes garment bags, protective tissue paper, and hang tags or labels.
2. Secondary (Grouped) Packaging – Used to group together multiple products, either to protect them or to facilitate handling and transport. Think: multi-pack box cartons for socks and accessories.
3. Tertiary (Transport) Packaging - Used for bulk handling, transport, and shipping. This can refer to either B2B packaging such as pallets and stretch wrap, or B2C cardboard boxes and envelopes. 

E-commerce packaging falls squarely under the scope of the PPWR, which will require companies to minimize excessive empty space in these packages. By 2030, the regulation will limit the empty space ratio in grouped, transport, or e-commerce packaging to 50%.

The above examples of packaging might be obvious, but the PPWR also encompasses use cases that you might not have considered. Packaging that’s intended to contain, support, or preserve the product throughout its lifetime, but isn’t actually integral to its function is considered waste. For example, supports that help maintain a shoe’s shape during shipping or storage.

There is, of course, an exception: any item that helps protect and preserve it throughout its lifetime is not considered packaging waste. For example, this could be a drawstring pouch for jewelry or other easily damaged accessories. 

Reduce, Reuse, Recycle – How Brands Must Comply with the PPWR

Now that we’ve defined packaging under the PPWR, it’s time to dig into how the regulation works. The rules encompass everything from labeling and environmental claims to recyclability and waste reduction. Here's how footwear and apparel brands can ensure compliance with these new standards.

1. Labeling Requirements & Environmental Claims

All packaging must now carry labels that provide detailed information on its material composition, in addition to labeling requirements for the product itself, which are specified in numerous textile labeling laws. Items like shoe boxes, polybags, and accessory packaging will need clear labeling on their recyclable content and destination.

Additionally, reusable packaging—such as durable garment bags—must bear a label informing consumers of its reusability, with more detailed information accessible via QR codes or other digital formats.

Under the PPWR, environmental claims can only be made if packaging exceeds the minimum regulatory requirements. For instance, you could advertise that your shipping materials are more recyclable than required by the regulation, so long as they adhere to the criteria and specify whether the claim refers to the packaging as a whole or only specific components.

2. Recyclability Standards

Starting January 1, 2030, all packaging must be recyclable, graded on a performance scale from A (95% recyclable or higher) to C (at least 70% recyclable).

The European Commission will establish specific Design For Recycling criteria by 2028, meaning companies will need to assess their packaging early to ensure compliance and avoid penalties, including higher fees under Extended Producer Responsibility (EPR) schemes.

3. Waste Prevention and Empty Space Ratio

One of the PPWR’s key goals is to prevent waste by reducing unnecessary packaging. For e-commerce and retail packaging, this means that the empty space ratio in boxes or other packaging must be no more than 50%. This is particularly relevant for e-commerce, where oversized boxes and excess padding are common. Brands will have to optimize packaging design to meet these new requirements and avoid unnecessary waste.

In terms of re-use and refill, there are a number of targets to be established in different sectors and packaging formats in upcoming Delegate Acts. These targets include reducing per capita packaging waste by 5% by 2030 and 15% by 2040, based upon 2018 levels. Additionally, it’s possible that EU Member States will introduce their own minimum reuse requirements. We will update our resources as this information comes available.

4. Recycled Content Requirements

From 2030 onward, any plastic packaging, such as polybags, hang tags, or plastic wrapping, will need to contain a minimum percentage of recycled content. By 2030, brands should meet these minimum requirements for recycled content in packaging:

• 30% for packaging where polyethylene terephthalate (PET) is the major component
• 10% for packaging made from plastic materials other than PET
• 35% for packaging other than those listed above

All recycled content must come from post-consumer waste, which should push brands to find more sustainable sourcing options for their plastic packaging. 

5. Reuse and Refill

The regulation encourages brands to implement reusable packaging wherever possible. For example, a footwear and apparel brand might introduce reusable shipping boxes or durable garment bags that can be returned and used multiple times. At least 40% of all transport and sales packaging in the EU must be reusable, with targets of 10% for grouped packaging.

6. Extended Producer Responsibility (EPR)

Under the PPWR, all packaging producers will be subject to Extended Producer Responsibility (EPR). This means that fashion brands will be responsible not only for the design and manufacturing of packaging but also for its entire lifecycle, including waste management and recycling.

EPR fees will be adjusted based on the recyclability of the packaging materials used. Learn more about Extended Producer Responsibility in our full write-up here.