The last six months have been pivotal for packaging compliance in Europe and the UK. With the EU Packaging and Packaging Waste Regulation (PPWR) now in force, the UK finalising EPR base fees and recyclability assessment rules, Denmark preparing for its new EPR system, and France extending obligations to industrial packaging, the landscape is shifting rapidly.
This blog provides a detailed update on developments between February and August 2025 and explains what they mean for compliance professionals.
1. PPWR Enters Into Force (February 2025)
The PPWR (Regulation (EU) 2025/40) entered into force on 11 February 2025, replacing the Packaging and Packaging Waste Directive.
- Applicability date: 12 August 2026
- Direct regulation: applies automatically in all EU Member States, removing the patchwork of national transpositions.
Key early obligations:
- Producers selling cross-border within the EU must appoint authorised representatives in each Member State of sale.
- Fulfilment service providers will need to verify their clients’ registration and reporting and suspend services if data is incomplete or inaccurate.
Source: EUR-Lex – Regulation (EU) 2025/40
2. UK EPR Fee Updates (June 2025)
In June 2025, the UK government published final base fees for 2025/26. Compared to previous estimates, most materials saw reduced rates:
| Material | New Rate (£/tonne) | Previous Rate (£/tonne) |
|---|---|---|
| Glass | 192 | 240 |
| Plastic | 423 | 485 |
| Aluminium | 266 | 435 |
| Paper/Card | 196 | 215 |
| Fibre-based composite | 461 | 455 |
The bad-debt contingency was reduced from 6% to 4%.
Source: GOV.UK – 2025 Base Fees
3. Recyclability Assessment Methodology (RAM)
The UK also published RAM v1.1 (April 2025), requiring household packaging to be assessed as:
- Green – recyclable, lowest fees
- Amber – partly recyclable, base fees
- Red – not recyclable, highest fees
Key dates:
- 1 October 2025 – first RAM reporting deadline (for Jan–Jun 2025 data)
- 2026 onwards – fee modulation linked to recyclability performance
Source: GOV.UK – RAM guidance
4. Denmark’s EPR System Launch (October 2025)
Denmark’s long-awaited packaging EPR system goes live on 1 October 2025.
- Producers had to register with the Danish Producer Register (DPA) by 31 August 2024
- Join a Producer Responsibility Organisation (PRO) by 14 January 2025
- Register reusable packaging by 1 February 2025
By early 2025, nearly 5,000 entities had already registered.
Source: DPA – Packaging EPR
5. France Extends EPR Scope (2025)
France extended its EPR system to industrial and commercial packaging in 2025, significantly broadening coverage.
In parallel, the AGEC Law requires companies with turnover above €10 million to inform customers about the environmental properties of certain products, including packaging.
6. Upcoming Milestones
Here is a visual roadmap of the most critical compliance dates:
- Aug 2026: PPWR becomes fully applicable; AR/FSP obligations begin
- Oct 2025: First UK RAM reporting deadline
- Aug 2028: Harmonised EU packaging labels required
- Feb 2029: QR/digital carriers required on reusable packaging
- Jan 2030: Recycled content thresholds (10–35%); reuse targets for transport packaging; recyclability grades A–C
- 2038: Packaging must reach recyclability grades A–B
7. Penalties and Compliance Risks
National penalties are significant. For example, in Germany, fines under the VerpackG can reach up to €200,000 per violation, and non-compliant products may be barred from sale.
8. Next Steps for Businesses
To stay ahead, companies should:
- Conduct packaging portfolio audits against PPWR and RAM criteria
- Secure access to recycled materials ahead of 2030 thresholds
- Prepare to update labelling systems by 2028
- Appoint authorised representatives for EU cross-border operations
- Ensure supply chain partners (including fulfilment providers) are aligned with compliance obligations
Conclusion
The last six months have reshaped the regulatory landscape for packaging in Europe and the UK. With the PPWR now in force, UK EPR fees finalised, Denmark’s system launching, and France expanding obligations, compliance is no longer optional or delayed.
The message is clear: businesses must prepare now. Early action will minimise disruption, reduce costs, and secure continued market access as we move into the next phase of packaging regulation.