Brussels is tightening the screws on packaging waste, introducing new rules that mark the beginning of an era in which the packaging around a product can be just as important as the product itself.
On Aug 12, the EU’s Packaging and Packaging Waste Regulation (PPWR) took effect, the opening salvo in a nearly decade-long rollout of measures to be phased in from now until 2035.
For Thai businesses that export to Europe — and potentially those supplying companies that do — the message is clear: packaging can no longer be treated simply as a matter of design, cost and convenience. It is becoming a key part of market access and supply chain competitiveness.
Reasons for the rule
The scale of Europe’s packaging waste problem helps explain the push for tougher regulation.
Europeans generate as much as 180 kilogrammes of packaging waste per person each year. Packaging also accounts for a substantial share of the EU’s consumption of raw materials, including around 40% of plastic and 50% of paper, according to European Commission data.
The commission warned that without additional measures, packaging waste could increase by 19% by 2030, while plastic packaging waste could rise by as much as 46%.
The EU introduced the PPWR in response to that trend under Regulation 2025/40, adopted on Dec 19, 2024. The regulation entered into force on Feb 11, 2025 and began to apply on Aug 12, 2026, with some requirements coming into effect later.
Unlike many national environmental rules, the PPWR is directly applicable across EU member states.
The regulation forms part of the European Green Deal and the New Circular Economy Action Plan, shifting the EU’s approach from simply managing waste towards preventing it and keeping materials in circulation for longer.
Reduce, reuse and recycle
The PPWR covers all types of packaging — primary, secondary and tertiary — in the EU market, regardless of whether the packaging is produced inside the bloc or imported from elsewhere.
All packaging placed in the EU market must be recyclable. Requirements for Design for Recycling apply from Jan 1, 2030, or 24 months after the relevant implementing legislation takes effect, whichever is later.
Requirements for recyclability at scale follow from Jan 1, 2035, or five years after the relevant implementing legislation takes effect, whichever is later.
Reuse targets apply only to certain types of packaging and specific business sectors.
The PPWR is built around three objectives: reduce, reuse and refill, and recycle — aiming to deliver measurable environmental benefits.
The EU set targets to reduce packaging waste generated per person from 2018 levels by 5% in 2030, 10% in 2035 and 15% in 2040.
The measures are expected to reduce packaging waste in the EU by 37% compared with a baseline scenario in which no additional measures are implemented.
Initial changes
From Aug 12, food-contact packaging containing per- and polyfluoroalkyl substances (PFAS) above specified limits may no longer be placed in the EU market for the first time.
Food-contact packaging includes fast-food containers, pizza boxes, microwave popcorn bags, and single-use paperboard plates and bowls. Such packaging is allowed in the EU market as long as PFAS levels remain within the limits prescribed by law.
The PPWR also introduces a range of requirements covering packaging recyclability, including Design for Recycling, recyclability at scale and minimum recycled-plastic content.
The regulation prohibits certain types of single-use plastic packaging and introduces harmonised labelling requirements.
For example, all packaging in the EU market must be designed to be recyclable, while minimum recycled-content requirements apply to plastic packaging. Certain types of single-use plastic packaging are prohibited from Jan 1, 2030.
The PPWR represents a significant shift in the EU’s approach to packaging, moving towards a circular economy model that places greater responsibility on businesses to reduce packaging use, improve packaging design, increase the use of recycled materials and develop reusable packaging solutions, according to the Department of International Trade Promotion (DITP).
Thai impact
For Thailand, the implications are potentially significant. Krungsri Research said the new regulation will affect Thai businesses trading with the EU across two broad categories — packaging manufacturers and exporters of packaged products — extending across virtually every industry.
Packaging manufacturers, particularly those producing plastic packaging, face direct exposure. Exporters of packaged goods, especially food and beverages, consumer products, electrical appliances and electronics, will need to assess whether their packaging complies with the new requirements.
The food and beverage sector is par- ticularly exposed because of its heavy reliance on packaging and its links to the European market, noted the think tank.
Meat products, including chilled and frozen chicken, have the highest reliance on the EU market at 17.3%, according to Krungsri Research. Processed fruit and vegetables follow at 11.1%. Products such as canned fruit, sauces and seasonings can also be particularly packaging-intensive, often relying on plastic or glass containers.
For these exporters, compliance could mean higher operating costs as companies redesign packaging, source recycled materials, change labels, conduct testing and prepare additional documentation.
The challenge is not only the cost of compliance. Companies that cannot meet the new requirements could ultimately find themselves unable to export to the EU market, noted Krungsri Research, meaning PPWR is more like a non-tariff barrier than an environmental regulation.
The EU is Thailand’s fourth-largest export market after Southeast Asia, the US and China, making the potential impact substantial for Thai exporters. The consequences could extend beyond Europe.
“Over the longer term, businesses that fail to comply may also be excluded from supply chains in both the EU and other markets, as buyers switch to alternative suppliers whose packaging already meets the required standards,” said the think tank.
Thai packaging manufacturers could also face indirect pressure if they supply companies in other countries whose products are ultimately exported to the EU. In that scenario, compliance with European packaging standards could become a requirement imposed by customers even when the Thai supplier does not export directly to Europe.
Steps for local companies
For Thai manufacturers and exporters, Krungsri Research recommends preparing along three main fronts: redesign, recheck and review.
Businesses should begin by assessing their existing packaging against PPWR requirements, particularly those covering recyclability and recycled content. This effort may require redesigning packaging, securing reliable supplies of post-consumer recycled material, updating labels and screening materials for substances subject to restrictions.
Packaging producers and brand owners can work together more closely on sustainable packaging solutions.
Collaboration can help ensure that new designs are not only technically compliant, but also practical for the products they contain and acceptable to consumers, noted the think tank.
Compliance also requires stronger documentation. Businesses should prepare or verify technical evidence for their packaging, including information on material composition and the proportion of recycled content.
Companies selling directly to EU consumers online may face additional obligations, including registration under national Extended Producer Responsibility (EPR) systems, or the appointment of an authorised representative, particularly where there is no importer acting as an intermediary.
For exporters, keeping accurate and accessible packaging data will therefore become increasingly important.
Perhaps the biggest challenge is the regulatory picture is still evolving. Businesses should monitor further technical requirements expected to emerge during 2026-2028, particularly the detailed criteria for Design for Recyclability and rules concerning bioplastics.
Businesses must also keep track of similar legislation in other major export markets, including the UK, South Korea, Japan and China, as well as Thailand’s own recycling and packaging-related regulations, said Krungsri Research.
The PPWR is part of a broader wave of sustainability rules sweeping across global markets, noted the think tank.
A single business may face requirements under multiple regulations at the same time. While the details may vary, these rules share a common thread: placing greater emphasis on sustainability across every stage and component of business operations.
Businesses should move quickly to gather data, assess sustainability across their entire supply chain and identify potential compliance gaps.
Building this readiness now will help them navigate the evolving regulatory landscape and turn these challenges into long-term opportunities, according to Krungsri Research.