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

PPWR in Poland has, as a general rule, applied since 12 August 2026. It covers all packaging and packaging waste. Businesses already need to verify chemical composition, conformity and documentation, while further rules on labelling, recyclability, recycled content, empty space and reuse will apply in stages.

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Which PPWR requirements already apply?

PPWR in Poland, the Packaging and Packaging Waste Regulation, is Regulation (EU) 2025/40 and replaces Directive 94/62/EC. It covers packaging design, composition, labelling, documentation, placing packaging on the market, reuse and recycling.

The total concentration of lead, cadmium, mercury and hexavalent chromium in packaging or its components must not exceed 100 mg/kg. Food-contact packaging containing PFAS at concentrations equal to or above the PPWR limits may not be placed on the market.

Conformity assessment, technical documentation and the EU declaration of conformity are also relevant. An importer should verify that the manufacturer completed the required assessment and prepared the necessary documentation.

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Which supply-chain roles are covered?

PPWR covers manufacturers, importers, distributors and producers for extended producer responsibility (EPR) purposes. One organisation may perform several roles depending on the product, packaging source, country of origin and sales market.

Companies therefore need to determine who is responsible for each item of packaging at each stage of the supply chain. For importers of finished packaged products from outside the EU, missing supplier information can affect whether a product may be placed on the market.

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Which requirements will apply later?

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 is to 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 categories.

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How should companies prepare for PPWR?

Key steps include:

• identifying relevant packaging categories,
• determining the company’s PPWR role for individual product flows,
• reviewing supplier documentation and material-composition data,
• assigning responsibility for technical documentation and conformity assessment,
• identifying packaging that will require later changes,
• incorporating new requirements into product design and supplier negotiations.

For larger organisations, a major challenge may be the absence of a complete packaging database covering different companies, countries and product lines. Businesses should therefore meet requirements already in force while preparing their packaging portfolios for later PPWR stages.

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If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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