The EU Packaging and Packaging Waste Regulation 

Your hangers are now packaging. So are your dust bags, your sticky labels, and that tissue paper you wrap orders in. From 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) redefines what counts as packaging across the entire fashion supply chain, and there’s no small-business exemption waiting to save you.

Yes, it sounds daunting, but we will guide you through. Let’s break down what’s actually changing, what it means for a (small) sustainable brand or store, and exactly what to do about it.

What is the EU Packaging and Packaging Waste Regulation?

The PPWR (Regulation (EU) 2025/40) replaces the old Packaging and Packaging Waste Directive, which EU countries implemented differently. Because it’s an EU regulation, it applies to all EU countries simultaneously. It entered into force on 11 February 2025 and becomes generally applicable on 12 August 2026, with several obligations phasing in through 2040. Unlike a directive, a regulation applies directly and identically in every member state. That means there is no more patchwork of national rules to track if you sell across the EU.

The European Commission’s own framing is blunt about why this exists: packaging is one of the fastest-growing waste streams in Europe, plastic packaging alone accounts for roughly 40% of all plastics used in the EU, and packaging makes up around half of marine litter. The regulation’s stated goal is to make all packaging on the EU market recyclable in an economically viable way by 2030, reduce reliance on virgin materials, and put packaging design on a genuine circular-economy footing.

For fashion, this isn’t a footnote regulation about cardboard boxes. It touches design, sourcing, e‑commerce fulfilment, and your relationship with suppliers.

How the PPWR redefines ​“packaging” for fashion

Here’s the part that catches most fashion SMEs off guard: the PPWR’s definition of packaging is far broader than most brands assume. Under the new rules:

• Garment hangers count as packaging if sold together with the item (sold separately, they don’t).
• Sticky labels on clothes and shoes are packaging.
• Hang Tags and their safety pins.
• Dust bags supplied with footwear or accessories are packaging.
• Textile bags, natural or synthetic, are now a listed packaging material.
• Shipping boxes and shipping box protective parts

Each of these now has to be registered, assessed for recyclability, and reported under Extended Producer Responsibility (EPR) schemes. That is the system that makes producers financially responsible for what happens to their packaging once it becomes waste.

On top of the redefinition, several concrete design rules apply:

• Recyclability grading. From 2030, packaging is graded A (≥95% recyclable by weight), B (≥80%) or C (≥70%). Anything below Grade C becomes illegal to sell into the EU. By 2038, only Grades A and B remain permitted.
• Recycled plastic content minimums. The PPWR actually splits plastic packaging by function: ​“contact-sensitive” packaging (anything touching food, cosmetics, or pharmaceuticals, where hygiene and safety matter) versus everything else. A mailer, polybag, or garment bag wrapped around a t‑shirt isn’t contact-sensitive by that definition, so it falls into the ​“other plastic packaging” category, regardless of what it is made from. That category needs at least 35% post-consumer recycled content by 2030, rising to 65% by 2040. 
• The empty-space rule. From 2030, transport and grouped packaging can contain no more than 50% empty space. Oversized boxes stuffed with bubble wrap for ​“unboxing experience” purposes will simply be non-compliant. (Think Barbies in big boxes, making them more desirable as Christmas Gifts to some people.)
• Harmonised labelling. From 12 August 2028, standardised EU recycling pictograms become mandatory to help consumers sort waste correctly. Reusable packaging (e.g., Repack or the bags you give to clients in physical stores) needs scannable QR codes carrying reuse and material data from February 2029.
• Substance restrictions. Combined lead, cadmium, mercury and hexavalent chromium in packaging cannot exceed 100 mg/​kg, which means the inks, dyes and adhesives on your labels and boxes need checking, not just the cardboard itself.
• Ecomodulated EPR fees. Producer responsibility fees will scale with how recyclable and how rich in recycled content your packaging is. Poorly designed packaging will simply cost more to bring to market. Plastic and single-use packaging have higher fees than paper, for example. The downside of the EPR fees, however, is that you need to pay in every country where you sell and/​or where you ship goods to; no matter if you send one or ten thousand parcels. Read on for more details. 

Selling only in your own country doesn’t reduce your obligations

If you only ship within your home market (no cross-border sales at all), it’s tempting to assume the PPWR is someone else’s problem. It isn’t. The regulation covers anything placed on the EU market, and your own country is part of that market. There’s no domestic-only carve-out.

Take Germany as the worked example, since it’s one of the stricter national systems. Germany already ran one of the EU’s most rigorous packaging laws before PPWR existed: the Verpackungsgesetz (VerpackG), which requires anyone placing packaged goods on the German market to register in the LUCID register (registration is free and does not take much time), run by the Central Agency Packaging Register (ZSVR), and join a licensed take-back scheme; a ​“dual system” such as Der Grüne Punkt or Interseroh+. As of 12 August 2026, VerpackG is being replaced by a new implementing law (the VerpackDG), but LUCID registration and dual-system participation remain mandatory. PPWR sits atop the national system rather than removing it.

Two details matter here for a small, domestic-only brand:

• There’s no minimum-volume threshold. The obligation applies from your first parcel, whether you ship one order a month from your own studio or run a full warehouse. This includes sales made through marketplaces, which must verify that sellers hold a valid LUCID registration before allowing them to trade. Sending 100 smaller parcels per year (20kg of cardboard and paper packaging) could cost around 17 €; for 1000 smaller parcels (200kg), it would be around 60 €; 10 000 smaller parcels (2000kg) would cost up to 560 €. These numbers are calculated using the calculator of Reclay, the cheapest German solution we found for small brands.
• Penalties are real. Missing registration or system participation in Germany can trigger fines reported up to roughly €200,000 depending on the breach, plus a sales ban, not just a warning letter.

The same logic applies wherever you’re based: France runs its own scheme (Citeo, under the AGEC law), Belgium runs Fost Plus, and so on. PPWR standardises the substance and design rules across all of them, but it doesn’t replace the national registration systems: so ​“domestic only” still means ​“register with your own country’s scheme,” not ​“exempt.”

What this means for your business, not just your bin

Here’s the honest part: the PPWR does not carve out a general exemption for small or micro businesses. If you place packaging on the EU market, as a brand, importer, or retailer, the core obligations apply to you, whatever your headcount.

That said, ​“no exemption” doesn’t mean ​“identical burden”, but it’s worth being precise about exactly where the relief applies, because this is the point most micro-enterprises get wrong. If your business qualifies as a micro-enterprise under EU Recommendation 2003/361/EC (fewer than 10 employees and annual turnover or balance sheet total at or below €2 million, measured across your whole group, not just EU sales) and your packaging supplier is EU-based in the same member state as you, that supplier takes on the technical documentation and Declaration of Conformity for the packaging design. You don’t have to prove the box itself meets recyclability and substance requirements; your supplier does.

Unfortunately, it does not exempt you from EPR registration. Even as a small brand, you need to register with the national packaging register in every country you ship to (LUCID in Germany, Citeo in France, Fost Plus in Belgium, and so on) and report your packaging volumes in each country to a local authority, whether you are sending to a shop or a customer. It doesn’t matter that you bought your packaging material locally, whether your boxes are secondhand, or whether you’re the smallest studio in your city: if you’re the one shipping a packaged product to a customer, you’re the ​“producer” for registration purposes.

The good news if you already ship in secondhand boxes

Most eco-fashion brands already reuse cardboard instead of buying new mailers, and choose plastic-free options like paper for wrapping. If that’s you, you’re closer to compliant than most of the industry. 

What’s working in your favour: Cardboard usually scores well in recyclability grading (A – C) without any redesign, since its recycling infrastructure is already solid across the EU. No filler means you’re close to the 50% empty-space rule (from 2030), with zero extra work.

What still needs your attention:

• You still need to register for EPR and report your volumes, whether the box is new or reused. Shipping it makes you the one ​“placing packaging on the market”; that doesn’t change with reuse. To get around it, you would need to prove that someone else had registered that box already (which is nearly impossible).
• You still need to declare the box as a ​“cardboard box” in the registration process, no matter if reused or new.
• Check what’s on the box. Old ink, tape, or labels from its first life can affect substance limits, and heavily printed cardboard recycles less cleanly than plain kraft. Rather choose plain and take off all old stickers.

One thing to watch if you’re marketing this: For EmpCo regulation, quoting ​“We ship in reused boxes” is a strong, specific sustainability claim; genuinely better than a vague ​“eco-friendly packaging” line, because it’s concrete and checkable. Just make sure it’s true consistently, not just sometimes, and don’t let it stretch into a broader claim like ​“our packaging is sustainable” that covers items it doesn’t actually apply to (your labels, hangers, or dust bags might tell a different story).

Your PPWR to-do list

Work through these in order. None of them requires a legal department; most require a Tuesday afternoon and an email to your suppliers.

1. Create a table mapping every packaging item that touches your product. Hangers, dust bags, polybags, tissue paper, mailer boxes, tape, stickers, care labels. If it wraps, protects, holds, or presents your product, list it.

2. Check your role. Most fashion brands are ​“manufacturers” under PPWR, even if a supplier makes the boxes. The PPWR defines four roles, and which one applies determines who’s legally on the hook:

• Manufacturer: makes the packaging itself, or has it designed or made under its own name or trademark. This is the one that catches most COSH! members by surprise: if you order branded boxes, hangers, or dust bags with your logo on them, you’re the manufacturer for PPWR purposes, even though a print shop or packaging supplier physically produced them.
• Importer: brings packaging, or packaged goods, into the EU from outside the EU.
• Distributor: makes packaging or packaged goods available on the market without being the manufacturer or importer (e.g. a multi-brand store stocking someone else’s branded items).
• Micro-enterprise exception: if you have fewer than 10 employees and annual turnover or balance sheet total at or below €2 million (calculated across your whole company group worldwide, not just EU sales), and your packaging supplier is based in the EU in the same member state as you, the supplier takes on the manufacturer’s documentation duties instead of you. That is: proving the packaging design is compliant. This exception disappears if your supplier is outside the EU! Sourcing your hangtags, or branded boxes from outside Europe puts the manufacturer role straight back on you, regardless of your size. It does not affect EPR registration: you still have to register and report as a producer yourself, even if you are a micro-enterprise buying local. 

Do this per packaging table per product group, not once for the whole business. You might be the manufacturer for your own-label packaging and a distributor for third-party items you stock. The same company can hold different roles for different SKUs.

3. Ask your suppliers for recyclability and recycled-content data now. Recycled plastics and compliant materials are already tightening in supply, so don’t wait until 2029 to start the conversation.

4. Right-size your e‑commerce packaging. Audit for empty space in shipping boxes. If you’re using padding to fill a too-large box, you need a smaller box, not more padding.

5. Register for EPR in every EU country you sell into – this step has no micro-enterprise exemption. Confirm whether you need an authorised representative if you’re based outside the EU or outside a given member state. This applies even if you’re a one-person studio, buying from a local supplier, and shipping in secondhand boxes: none of that removes the registration obligation. 

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6. Review inks, adhesives and finishes on labels and boxes against the heavy-metal and PFAS thresholds, including on reused boxes, since old branding and tape residue count too.

7. Build a labelling and QR-code timeline for 2028 – 2029 so that harmonised recycling symbols and reuse QR codes aren’t a last-minute scramble.

9. Document everything. Even with simplified obligations for micro-enterprises, you’ll need records showing you assessed your packaging and know where responsibility sits.

Turning compliance into an advantage

Some businesses are already treating the PPWR as a design brief rather than a burden. Brands moving early to mono-material mailers, FSC-certified boxes with minimal print, and reusable garment bags aren’t just avoiding future fines. They’re positioning themselves for lower ecomodulated EPR fees once those kick in, and for a retail story that’s actually backed by design decisions rather than a label.

At COSH!, we see this as the same pattern we track across EU sustainability legislation: the businesses that treat regulation as the floor, not the ceiling, end up ahead of both their compliance deadlines and their competitors’ marketing claims. The PPWR won’t wait for you to be ready. 

Need a second pair of eyes on your packaging audit, or want to know how PPWR interacts with the green claims you’re already making about your materials? Get in touch with the COSH! team! This is exactly the kind of practical, unglamorous groundwork we help our members work through.

Frequently Asked Questions

Q: What is the EU Packaging and Packaging Waste Regulation (PPWR) and when does it apply? 

A: The PPWR (Regulation (EU) 2025/40) is an EU-wide law replacing the old Packaging and Packaging Waste Directive. It entered into force on 11 February 2025 and becomes generally applicable on 12 August 2026, with further requirements, such as recyclability grades, recycled-content minimums, and labelling rules, phasing in through 2040.

Q: Does the PPWR apply to small fashion brands and micro-enterprises? 

A: Yes, with no general exemption. Every business placing packaging on the EU market must comply, regardless of size. Micro-enterprises (fewer than 10 employees, turnover or balance sheet under €2 million) get relief on one specific thing: technical documentation for the packaging design, which shifts to an EU-based supplier in the same member state. But EPR registration and reporting remain the brand’s own obligation, with no size-based exemption.

Q: What counts as ​“packaging” under the new rules for fashion products? 

A: The definition is broader than most brands expect. Hangers sold with a garment, sticky labels on clothing or footwear, dust bags supplied with products, and textile bags are all now classified as packaging and must be assessed for recyclability and reported through Extended Producer Responsibility schemes.

Q: What should a fashion SME do first to prepare for PPWR compliance? 

A: Start by mapping every item that touches your product: hangers, labels, dust bags, mailers, tape. Then determine your role (manufacturer, importer, distributor, or micro-enterprise) for each product line, and contact suppliers about recyclability and recycled-content data. Registering for EPR in every EU country you sell into is a parallel, non-negotiable step.

Q: Is compliance with the PPWR only a cost, or can it benefit small sustainable brands? 

A: It’s both. Compliance requires real investment in supplier relationships and packaging redesign, but the regulation’s ecomodulated EPR fees mean well-designed, minimal, genuinely recyclable packaging will cost less to bring to market than wasteful packaging over time; turning early action into a competitive advantage rather than a pure compliance cost.

Q: Does shipping in secondhand cardboard boxes mean a brand is already PPWR-compliant? 

A: Not automatically, but it’s a strong starting position. Cardboard boxes are exempt from the PPWR’s binding reuse targets, and shipping them without extra filler helps meet the 50% empty-space rule without any redesign. However, EPR registration, a Declaration of Conformity for the packaging type, and substance checks on inks and tape still apply, regardless of whether the box is new or reused.

Q: Does the PPWR apply if I only sell within my own EU country, like Germany? 

A: Yes. The PPWR covers any packaging placed on the EU market, and domestic sales within a member state count as part of that market. There’s no exemption for staying local. In Germany specifically, brands must also register in the national LUCID register and join a licensed take-back scheme, obligations that run alongside PPWR rather than being replaced by it.

Sources: European Commission, Directorate-General for Environment (environment​.ec​.europa​.eu); EUR-Lex Regulation (EU) 2025/40; European Commission PPWR guidance and FAQs (March and August 2026); Greenberg Traurig LLP; Coolset Academy; GreenStitch​.io; Pack Declare. This article is for general information and does not constitute legal advice; consult a compliance professional for guidance specific to your business.