For years, eCommerce businesses selling internationally have concentrated much of their compliance effort on what is inside the parcel: product descriptions, commodity codes, values, country of origin, VAT and customs declarations. Increasingly, businesses also need to think about the parcel itself.
From 12 August 2026, the initial requirements of the EU’s Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40) apply across the European Union.
PPWR replaces the previous Packaging and Packaging Waste Directive (PPWD) and introduces a new framework designed to reduce packaging waste, improve recyclability and increase the use of recycled materials. Requirements are being introduced progressively, with further measures coming into application through to 2040.
For UK eCommerce businesses selling packaged goods to EU consumers, this should therefore be viewed as more than an environmental initiative. It forms part of a much wider change in what businesses need to consider when placing goods on international markets.
What does PPWR mean for UK exporters?
PPWR applies broadly to businesses placing packaging on the EU market, including manufacturers, importers, distributors and retailers. It covers packaging types throughout the supply chain, including primary, secondary, tertiary and service packaging.
For an eCommerce retailer, that means compliance considerations can extend beyond the packaging immediately surrounding the product to other packaging used to prepare and transport an order.
Among the requirements applying from 12 August is a restriction on the concentration of lead, cadmium, mercury and hexavalent chromium within packaging or packaging components. Their combined concentration must not exceed 100 mg/kg. Specific restrictions also apply to PFAS in food-contact packaging.
The regulation also establishes recyclability requirements for packaging, although many of the more detailed measures – including future recyclability performance criteria, recycled-content targets, labelling requirements and measures designed to reduce unnecessary packaging – are being introduced progressively.
This is therefore not a single regulatory deadline. 12th August 2026 marks the beginning of a much longer transition in the way packaging placed on the EU market is designed, documented and managed.
The bigger issue for cross-border eCommerce
PPWR highlights something increasingly important for international retailers: customs compliance and wider market compliance cannot always be considered separately.
A shipment can contain accurate customs data, the correct commodity codes and values, and the appropriate VAT arrangements, but that does not automatically mean everything associated with placing those goods on the EU market is compliant. That distinction matters.
UK Government guidance specifically warns exporters that failure to comply with PPWR could result in goods being rejected at EU borders.
For eCommerce businesses accustomed to thinking of the border primarily as a customs checkpoint, this requires a broader compliance mindset.
Getting the customs declaration right remains essential – but it is only one part of successfully placing a product onto an increasingly regulated international market. Packaging compliance is becoming a data challenge too
There is another important parallel with the changes we are already seeing across customs. Businesses are increasingly expected to know more about their products and provide better-quality, more granular information about them. Packaging is heading in a similar direction.
UK Government guidance advises exporters to collect and maintain relevant PPWR and Extended Producer Responsibility (EPR) data. EPR requirements can involve information including packaging type, weight, recyclability and recycled content.
For retailers with hundreds or thousands of products, this raises an important operational question:
How much do you actually know about the packaging travelling with each product?
It may no longer be sufficient for this information to sit solely with a procurement team or packaging supplier. Businesses selling crossborder increasingly need reliable access to packaging specifications, supplier evidence and relevant compliance documentation.
That turns packaging compliance into a supply-chain data issue as much as a sustainability issue. And, as customs and regulatory systems become increasingly data-led, the ability to retrieve accurate information quickly is becoming an important part of keeping goods moving.
What should UK eCommerce businesses be doing now?
The first step is understanding the packaging being placed on the EU market.
Businesses should consider auditing packaging used for EU orders and speaking to packaging manufacturers and suppliers to establish whether the relevant requirements are being met.
Documentation is particularly important. UK Government guidance advises businesses to prepare a Declaration of Conformity for each packaging type being placed on the market from 12 August 2026 and to ensure that the necessary technical documentation is available to demonstrate compliance with the applicable requirements.
Businesses should also establish who within their supply chain is responsible for providing, maintaining and accessing this information.
Alongside PPWR itself, UK exporters should review their Extended Producer Responsibility (EPR) position in the EU countries in which they sell. This can involve registering with relevant national EPR schemes, reporting packaging data and paying applicable fees. Businesses should also establish whether an authorised representative is required to manage obligations locally.
Micro-enterprises are not automatically outside the regulation either. Although lighter requirements can apply in some circumstances, the UK Government guidance makes clear that they remain subject to core PPWR obligations.
Most importantly, businesses should avoid treating packaging compliance as an isolated project. Procurement, sustainability, compliance, logistics, eCommerce and customs teams may all hold different pieces of the information required. Connecting those pieces is likely to become increasingly important.
Customs arrangements don’t remove packaging obligations
It is also important to separate packaging compliance from the mechanism’s businesses use to manage VAT, duty and delivery. IOSS, DDP and DAP/DDU arrangements may influence how VAT, duties, risk and customs clearance are managed, but they do not remove a business’s packaging obligations when placing packaged goods on the EU market.
A retailer can therefore have an effective IOSS arrangement, accurate customs declarations and a well-structured international delivery solution and still have separate PPWR and EPR responsibilities to address.
This is why looking at cross-border compliance as a complete journey, rather than simply a customs declaration, is becoming increasingly important.
Compliance is moving beyond the customs declaration
PPWR is another example of a wider trend affecting cross-border eCommerce.
From increasingly detailed customs data requirements to product, environmental and packaging regulation, authorities are demanding greater transparency, traceability and accountability from businesses placing goods onto international markets.
For retailers, the question is therefore becoming broader than simply:
“Can we clear this parcel through customs?”
The better question is:
“Do we have the information, processes and evidence needed to place this product – and everything travelling with it – on the destination market compliantly?”
That is a much bigger conversation.
At UKP Worldwide, our role is to help businesses navigate the customs and cross-border elements of that journey, ensuring international delivery and customs processes are structured correctly as regulatory requirements evolve. Packaging manufacturers and specialist compliance advisers should be used where businesses require confirmation that packaging itself meets the applicable technical requirements.
PPWR will continue to evolve as further requirements are introduced over the coming years. For businesses selling into the EU, the important step now is to make packaging part of the wider cross-border compliance conversation – rather than waiting until a compliance issue interrupts the movement of goods.
Further information
UK businesses can find guidance on PPWR, EPR requirements and recommended actions through the UK Government’s Business.gov.uk service:
UK Government – EU Packaging and Packaging Waste Regulation (PPWR)
https://www.business.gov.uk/campaign/europe/european-union-eu-regulations/eu-packaging-and-packaging-waste-regulation-eu-ppwr/
The full legislation is available through EUR-Lex:
Regulation (EU) 2025/40 – Packaging and Packaging Waste
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040
This article provides general information on regulatory developments and should not be considered legal or packaging-compliance advice. Businesses should seek specialist advice regarding the obligations applicable to their products, packaging and supply-chain structure.