New EU packaging rules apply from 12 August 2026: what it means for circular economy operators

The EU Packaging and Packaging Waste Regulation (PPWR) entered into force in February 2025, and its first obligations became applicable across the EU on 12 August 2026. It replaces the old Packaging and Packaging Waste Directive with directly applicable rules on packaging design, recyclability, minimisation, and restricted substances, including a ban on PFAS in food-contact packaging.

What it means for CRNI members: the PPWR places obligations on “producers” – broadly, whoever first places packaging on the market, including brand owners, fillers and importers. As most of our members are second-hand and reuse sellers, they’re generally not the producer of packaging that’s already on goods you’re reselling. That responsibility belongs to whoever placed it on the market originally.

However, it’s worth checking your own position if your organisation:

• Sells goods in your own branded packaging e.g. your own bags, boxes or labels, which can bring producer obligations even if a third party made the packaging.
• Sells or serves food: food-contact packaging now faces stricter substance rules, including the PFAS restriction.

For most members, the practical first step isn’t full compliance, it’s simply determining whether these rules apply to you at all. If neither of the above applies, you’re likely outside scope for now.

If either does, it’s worth reviewing your packaging, but note that formal registration with Repak, Ireland’s approved compliance scheme, is only required above a fairly high threshold (annual turnover over €1 million and more than 10 tonnes of packaging placed on the market per year).

Being a “producer” in principle doesn’t automatically mean joining Repak; most small members will remain below this threshold even where the basic producer rules technically apply to them.

We’ll continue to share updates for members as implementation develops.

• September 23, 2026