The EU’s Packaging and Packaging Waste Regulation | Seafish

The EU’s Packaging and Packaging Waste Regulation

We have produced guidance for the UK seafood sector on the EU's Packaging and Packaging Waste Regulation.



From 12 August 2026, the EU’s Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40) will apply to UK businesses that export packaged fish and seafood to the EU. The regulation sets common EU rules on how packaging must be designed, labelled, and reported.

If you export products such as vacuum-packed salmon, frozen prawns in bags, or fresh fish in insulated boxes, these rules will affect your EU trade.

Who is affected?

  • Great Britain (GB): The PPWR does not apply to sales within GB. However, it does apply to products you export to the EU. Compliance is usually handled together with your EU importer.
  • Northern Ireland (NI): The PPWR applies to packaged fish and seafood moved from NI to the EU. Under the Northern Ireland Protocol, many EU goods rules also apply domestically in NI. Businesses placing packaged seafood on the NI market should expect the PPWR to be directly relevant (subject to final implementation details under the Windsor Framework).

In summary, GB exporters must comply when selling into the EU; NI businesses may be more directly in scope.

1. Packaging must be recyclable by design

From August 2026, packaging placed on the EU market must be capable of being collected, sorted, and recycled within EU systems.

Commonly used forms of seafood packaging that will need to meet the recyclability requirement include:

  • Vacuum packs for smoked salmon
  • Flexible plastic bags for frozen prawns or seafood mixes
  • Rigid trays used in modified atmosphere packs for fresh fish
  • Insulated boxes used to transport chilled fish

What matters is the material structure of each item (for example, whether it is single-material plastic or a complex laminate). Exporters should obtain recyclability information and supporting documents from packaging suppliers.

2. Packaging must not be excessive

The PPWR requires packaging weight and size to be limited to what is necessary to protect the product and maintain food safety.

For seafood, this usually means reviewing:

  • Ice levels in fresh fish boxes
  • Absorbent pads in fresh fillet packs
  • Secondary retail cartons
  • Pallet wrap and stabilisation materials

Keep a short, written explanation of why each packaging element is needed.

3. Chemical rules (including PFAS)

From 12 August 2026, limits apply to intentionally added PFAS in food-contact packaging. Existing heavy metal limits also remain.

Affected seafood packaging components may include:

  • Barrier films
  • Coated papers
  • Functional pads or liners

Exporters should request up-to-date compliance statements from packaging suppliers.

4. Labelling and information

The PPWR requires additional recycling information to be included on packaging. Some seafood packs may need to be updated accordingly, for example:

  • Vacuum pack back labels
  • Frozen seafood bags
  • Cardboard sleeves and outer cartons

Detailed label formats required under the PPWR are still being finalised.

5. Relationship with national plastic packaging taxes

Some EU countries (e.g., Spain) operate national plastic packaging taxes. These continue alongside the PPWR.

  • PPWR: sets EU-wide rules on packaging design, recyclability, and information.
  • National plastic packaging taxes: set country-specific reporting requirements and levies.

Generally, it is the EU importers of packaged fish and seafood – rather than UK exporters of these products – that must account for these taxes. However, UK exporters must liaise with their EU customers to confirm responsibilities and the information that they need to supply so that any national taxes can be properly accounted for.

6. Extended Producer Responsibility (EPR)

Packaging placed on the EU market must be reported under national EPR schemes, which require businesses to report packaging weights by material and sometimes pay waste disposal fees. As with national plastic packaging taxes, the EU importer will often take the necessary steps to comply; however, UK exporters must clearly agree that this will happen with their EU customers and provide those customers with any required information about the packaging so that they can comply with national EPR schemes.

Practical steps for UK seafood exporters to the EU to take before 12 August 2026

  • Produce lists of all the packaging used for seafood products
  • Obtain supplier declarations (in relation to considerations like recyclability and PFAS/heavy metal content)
  • Document why particular packaging levels are necessary
  • Monitor EU recycling label developments
  • Confirm national plastic packaging tax and EPR scheme responsibilities with your EU customers
  • Keep technical records ready for your EU customers

Summary

From 12 August 2026, the PPWR introduces harmonised EU packaging rules that UK seafood exporters must meet when selling into the EU. GB businesses are affected when exporting; Northern Ireland businesses may be more directly in scope. National plastic packaging taxes and EPR fees will continue to operate alongside the new EU framework.

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