From 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) generally applies across the European Union. This means that packaging placed on the EU market needs to meet the applicable requirements under the Regulation.
For the custom bag industry, the main impact of PPWR is generally not on the bag itself, but on the packaging materials used to pack, protect and transport finished bag products, including polybags, paper boxes, hangtags, stickers, shipping cartons and protective filling materials.
Europe is USL’s largest market, accounting for approximately 45% of our total business. Therefore, ensuring that the packaging materials used for our custom bags meet applicable PPWR requirements is becoming increasingly important.
In this article, we take a closer look at how PPWR may affect both bag manufacturers and brands selling products in the European market.
What Is PPWR?
PPWR stands for the Packaging and Packaging Waste Regulation.
Officially known as Regulation (EU) 2025/40, it replaces the previous Packaging and Packaging Waste Directive 94/62/EC (PPWD).
Compared with the previous Directive, PPWR introduces more harmonised and comprehensive requirements across the EU. Its objectives include reducing packaging waste, improving recyclability, increasing the use of recycled materials and supporting the transition towards a more circular packaging economy.
What Does PPWR Cover?
For businesses in the custom bag industry, several areas of PPWR are particularly relevant.
Restrictions on Certain Heavy Metals
The total concentration of lead, cadmium, mercury and hexavalent chromium present in packaging or packaging components must not exceed 100 mg/kg, subject to applicable exemptions.
Packaging Recyclability
Packaging placed on the EU market will progressively need to meet recyclability requirements.
PPWR introduces a phased approach to improving packaging recyclability, with increasingly strict Design for Recycling and recycling-at-scale requirements scheduled over the coming years.
For bag brands and manufacturers, this means that the structure and material combination of packaging will become increasingly important.
Minimum Recycled Content in Plastic Packaging
PPWR introduces minimum recycled-content requirements for certain plastic packaging, with the first major targets beginning from 2030 or according to the applicable implementing timetable.
For the bag industry, this may affect packaging such as:
- PE polybags
- Recycled PE bags
- Plastic sleeves
- Plastic protective films
For plastic packaging falling within the general “other plastic packaging” category, the current PPWR target is 35% post-consumer recycled plastic, subject to applicable calculation methods, exemptions and implementation rules.
Reduction of Excessive Packaging
PPWR requires businesses to reduce unnecessary packaging and minimise packaging weight and volume while still maintaining the necessary level of product protection and functionality.
For grouped packaging, transport packaging and e-commerce packaging, a maximum empty-space ratio of 50% will apply from 2030 or three years after the relevant implementing act enters into force, whichever is later.
For the bag industry, this means packaging sizes should be better matched to the actual size of the product.
For example, a small waist bag should not be packed in an unnecessarily oversized polybag and shipping carton.
Packaging Labelling
PPWR will also introduce more harmonised packaging labelling requirements to help consumers identify packaging materials and correctly sort packaging waste.
This will make accurate information about packaging composition increasingly important for brands selling in the EU.
More Detailed Technical Documentation
Manufacturers and other economic operators will need more detailed technical information to demonstrate compliance with applicable PPWR requirements.
For bag brands, this may result in increased requests to suppliers for information such as:
- Technical Data Sheets
- Material composition
- Packaging weight
- Recycled-content evidence
- Supplier declarations
- Supporting certificates or test documentation
Such information can also help brands meet their wider packaging reporting and Extended Producer Responsibility (EPR) obligations.
Will PPWR Affect Your Business?
The answer is yes.
From manufacturing and transportation to retail and e-commerce, packaging is involved throughout the supply chain.
As a result, PPWR may affect manufacturers, brands, retailers and other businesses in several ways. While it creates new compliance challenges and operational pressure, it may also create new opportunities for businesses with stronger packaging and supply-chain management capabilities.
Greater Compliance Pressure
To support PPWR compliance, European bag brands are likely to request more complete packaging information and technical documentation from their suppliers.
This may include:
- Technical Data Sheets
- Material composition
- Unit packaging weight
- Recycled-content information
- Supporting evidence
- Supplier declarations
As a custom bag supplier, manufacturers will increasingly need to collect and provide accurate upstream packaging information from their packaging suppliers.
A More Complex Custom Bag Development Process
Before PPWR, developing a custom bag typically focused on confirming:
- Bag design
- Materials
- Dimensions
- Logo
- Packaging method
Under the new regulatory environment, packaging specifications need to be considered much earlier in the product-development process.
Additional information may include:
- Polybag material
- Packaging weight
- PCR recycled-content percentage
- Carton material
- Packaging dimensions
- Supporting documentation
Packaging is therefore becoming part of the technical product specification rather than simply something decided at the end of production.
Fewer Options for Excessive Packaging
PPWR places greater emphasis on packaging minimisation.
Packaging characteristics such as unnecessary double walls, false bottoms and unnecessary layers may become increasingly difficult to justify when they exist mainly to increase the perceived size or presentation of a product.
For transport and e-commerce packaging, businesses will also need to pay greater attention to empty space and carton utilisation.
This may reduce the use of overly elaborate packaging systems that add material without providing meaningful product protection.
At the same time, brands will increasingly need to consider packaging structures that are easier to recycle and make more efficient use of materials.
Increased Costs
Compared with conventional virgin-plastic packaging, recycled-content packaging may sometimes involve higher sourcing costs.
Businesses may also incur additional costs related to:
- Packaging redesign
- Supplier documentation
- Material testing
- Technical documentation
- Compliance management
- Packaging data collection
Existing packaging stock that no longer meets customer or applicable regulatory requirements may also need to be replaced.
In addition, environmental claims such as “Eco-Friendly Packaging”, “Made from Recycled Material” or “100% Sustainable” should be supported by appropriate evidence rather than used as general marketing statements.
Higher Standards for Selecting Bag Suppliers
Under PPWR, brands may increasingly need more than a manufacturer that can simply produce a bag according to a specification.
They need manufacturing partners with stronger capabilities in:
- Quality control
- Material management
- Packaging supplier management
- Technical documentation
- Traceability
- Compliance support
A bag manufacturer capable of providing clear packaging specifications, material information and supporting documentation can therefore become a more valuable supply-chain partner.
How Can Businesses Prepare for PPWR?
Understanding PPWR and preparing early can help businesses reduce compliance risks, avoid unnecessary delays and better manage future packaging requirements.
Review Your Current Packaging
Businesses should first identify all packaging components currently being used and collect information such as:
- Material type
- Dimensions
- Unit weight
- Recycled content
- Supplier
- Supporting documentation
They should also review whether unnecessary packaging or excessive empty space can be reduced.
Build a Packaging Database
Instead of collecting packaging information only when a customer requests it, manufacturers should consider creating an internal packaging database.
A typical database may include:
Packaging Code → Supplier → Material → Dimensions → Weight → Recycled Content → Certificates → Technical Documentation
This makes it much easier to respond to customer requests and maintain consistent packaging specifications across different orders.
Develop Recycled and More Recyclable Packaging Alternatives
Where appropriate, businesses can work with packaging suppliers to identify alternatives such as:
- PCR recycled PE polybags
- Recycled paper packaging
- FSC-certified paper options
- More recyclable mono-material packaging
- Reduced-plastic packaging solutions
The objective should not simply be to eliminate plastic, but to use the minimum amount of appropriate packaging necessary to protect the product while improving recyclability and material efficiency.
Understand Your EPR Responsibilities
Brands and businesses placing packaged products on EU markets should determine whether they qualify as a “producer” under the applicable PPWR and national EPR rules.
Where applicable, businesses may need to complete producer registration, packaging reporting and other EPR obligations.
Manufacturers should also be prepared to provide customers with accurate packaging material and weight information to support these reporting requirements.
Continue Monitoring the PPWR Timeline
PPWR is not a one-time change.
Although the Regulation generally applies from August 2026, important requirements relating to recycled content, recyclability, packaging minimisation and other areas are being introduced progressively.
Businesses should therefore continue monitoring EU implementing acts, delegated acts and customer-specific requirements.
How USL Is Preparing for PPWR
As a bag manufacturer committed to sustainable development, USL is integrating the key principles and future direction of PPWR into our ESG strategy.
We are strengthening communication and cooperation between our packaging suppliers, certification partners and customers to improve packaging transparency and technical-documentation support.
Our ongoing initiatives include:
- Introducing more sustainable PE packaging alternatives
- Reducing unnecessary packaging materials
- Optimising shipping carton dimensions and weight
- Developing recycled-content packaging solutions
- Promoting FSC-certified paper packaging options
- Improving packaging material and technical-data management
For us, PPWR is not simply a regulatory requirement. It is also an opportunity to improve packaging efficiency, reduce unnecessary material use and provide better supply-chain support to our European customers.
Looking for a PPWR-Ready Custom Bag Solution?
If you are developing custom bags for the European market and need support with product packaging, material selection or packaging documentation, contact USL today.
Our team can work with you to develop custom bag solutions while supporting the packaging information and documentation required for your EU projects.