The PPWR (Packaging and Packaging Waste Regulation), the new EU Packaging Regulation, establishes a new foundation for packaging-related requirements across the EU. As the PPWR has been adopted in the form of a regulation, it is directly applicable in all Member States without the need for national transposition. Consequently, it imposes direct obligations on Hungarian companies as well – initially from 12 August 2026.

Objectives of the regulation:

• reduction of packaging use,
• promotion of recycling and reuse, and the gradual phase-out of hazardous and harmful substances,
• creation of a harmonised and predictable framework within the EU internal market.

Scope of the PPWR

The new rules apply to packaging and packaging waste placed on the EU market, regardless of:

• type,
• material,
• or whether it is used or generated in industrial, retail, wholesale or household environments.

The regulation does not only address waste management, but the entire lifecycle of packaging. It includes requirements for packaging design, material composition, recyclability, reusability, labelling and related documentation.

Who is affected?

The regulation does not only apply to packaging material manufacturers. It affects all businesses that manufacture, import, place on the market, or sell packaged products within the European Union, including Hungary. This includes:

• packaging material manufacturers,
• producers,
• importers,
• distributors,
• webshops,
• brand owners,
• logistics operators, as well as
• the hospitality sector, and
• the retail sector.

In general, the regulation applies not only to large enterprises but also to micro- and small enterprises and extends to third country (non-EU) businesses as well.

When and what requirements apply?

The PPWR entered into force on 11 February 2025, with a phased implementation.

First phase: 12 August 2026

From this date, packaging placed on the EU market must comply, among others, with the following:

• compliance with sustainability and safety requirements set out in the EU Packaging Regulation,
• availability of conformity assessment and documentation, as well as manufacturer registration,
• compliance with so-called minimisation requirements.

In addition, from 12 August, food-contact packaging containing per- and polyfluoroalkyl substances (PFAS) above defined concentration levels may not be placed on the market – even if manufactured before that date (e.g. greaseproof paper, pizza boxes, bakery packaging, microwave containers, etc.).

Hospitality sector preparing: February 2027

Following February 2027, changes related to takeaway packaging will also affect the hospitality sector and retail stores exceeding a defined sales area (with certain exceptions for small businesses), including businesses operating in Hungary.

Labelling and information: from 2028

The next major compliance package will arrive in 2028, focusing primarily on labelling and information requirements. Harmonised markings and consumer sorting information will gain increased importance.

Additional rules

Further requirements related to recyclability and mandatory recycled content are expected between 2030 and 2040.

Relationship between the PPWR and EPR

The EU Packaging Regulation is expected to introduce additional data collection, reporting and administrative requirements for businesses, particularly those operating in multiple countries, including Hungarian companies. At the same time, changes in packaging compliance may have indirect effects on:

• corporate packaging records,
• data reporting,
• and related cost models,

therefore it is advisable to assess impacts on EPR processes in a timely manner.

The regulation introduces new concepts (e.g. producer, manufacturer, end user) and a harmonised EU methodology, which may result in changes regarding the EPR obligated party and the subject of EPR fees. Such changes may include:

• EPR and PPWR obligations do not necessarily apply to the same market participant,
• unlike before, empty packaging may also become subject to EPR obligations,
• the EPR obligated status may shift earlier in the value chain,
• with the definition of “end user”, it may arise that companies acting as such – unpacking imported goods for own use – will no longer qualify as EPR obligated parties.

Therefore, businesses in Hungary and across the EU should not treat packaging compliance and EPR separately, but as interconnected elements of a unified PPWR-based obligation system.

Through eco-modulation, the EU Packaging Regulation is also expected to affect the level of EPR fees. Accordingly, fees will be aligned with the environmental impact of products, better recyclable packaging will result in lower fees and more problematic materials will be subject to higher charges. (It should be noted that recent governmental plans in Hungary also indicate an intention to reduce EPR fees.)

Sanctions

Non-compliant packaging may be subject to fines, market restrictions, recalls, and in extreme cases even criminal sanctions. Such products may, with certain exceptions, be rejected at EU borders.

R&D and funding opportunities

Compliance with the new requirements may encourage R&D activities through the development of new products and manufacturing technologies. Affected businesses, including Hungarian companies, should review their production processes from this perspective to benefit from both tax and non-tax incentives.

The regulation significantly tightens packaging requirements in several areas, clearly promoting more sustainable and circular packaging practices. At the same time, it entails substantial preparation efforts for businesses in terms of compliance, internal processes and product structures.

If a more detailed review of the EU Packaging Regulation or an assessment of its impact on your business operations in Hungary is relevant, our experts are available to assist you in answering your questions and supporting your preparation.

This article is for general information purposes only and should not be considered as advice.