The EU’s Packaging and Packaging Waste Regulation
The EU’s Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40) applies from 12 August 2026. It sets common EU rules for packaging and packaging waste.
The requirements apply in stages. Some apply from 12 August 2026. Others apply from later dates.
If you export packaged seafood to the EU, or place packaged seafood on the Northern Ireland (NI) market, you will need to consider the PPWR requirements that apply to your packaging.
Who is affected? – Great Britain (GB)
The PPWR does not apply to sales within GB. It does apply when a GB business places packaged products on the EU market.
Producer
Where a GB seafood business exports packaged seafood to an EU customer and the EU customer is the Importer of Record, the EU customer will normally be the Producer responsible for registration and Extended Producer Responsibility (EPR).
A GB business may itself be the Producer where it acts as the Importer of Record – for example, when selling under DDP (Delivered Duty Paid) Incoterms – or where it sells packaged seafood directly to EU end users without an EU importer taking on that role.
If you are unsure, check with your EU customer who is the Importer of Record and who will take responsibility for Producer registration and EPR.
Manufacturer
Producer and Manufacturer are different roles under the PPWR. For some packaging, the seafood business may be the Manufacturer. For other packaging, the packaging supplier may be the Manufacturer. Businesses should establish this with their packaging suppliers.
The Manufacturer must show that the packaging meets the relevant PPWR requirements. The Manufacturer must also prepare an EU Declaration of Conformity (DoC) and supporting technical documentation.
Where the packaging supplier is the Manufacturer, the seafood exporter should obtain the DoC and pass it on to its EU customer.
Who is affected? – Northern Ireland (NI)
The PPWR applies to packaged fish and seafood moved from NI to the EU. Because of the Windsor Framework, the PPWR also applies domestically in NI – with some exceptions, notably in relation to EPR.
Businesses placing packaged seafood on the NI market will need to comply with many PPWR requirements. For example, the PPWR limits on PFAS in food-contact packaging apply in NI. However, the PPWR’s EPR requirements do not apply domestically in NI. NI remains part of the UK’s packaging EPR scheme.
Where an NI business exports packaged seafood to the EU, the same considerations around Producer registration apply as for a GB exporter. Where the EU customer is the Importer of Record, the EU customer will normally be the Producer.
Who is affected? – summary
GB businesses must comply with relevant PPWR requirements when exporting packaged seafood to the EU. NI businesses are directly in scope of many PPWR requirements because of the Windsor Framework.
What are the main PPWR requirements for seafood businesses?
The sections below explain the main PPWR requirements for seafood businesses. Some apply from 12 August 2026. Others apply from later dates.
1. Chemical rules, including PFAS
From 12 August 2026, limits apply to PFAS in food-contact packaging. Existing limits for lead, cadmium, mercury and hexavalent chromium also continue to apply.
Affected seafood packaging may include:
- Barrier films
- Coated papers
- Functional pads or liners
Seafood businesses should ask their packaging suppliers for up-to-date information showing that their food-contact packaging meets these requirements.
2. Declaration of Conformity and supporting documentation
From 12 August 2026, Manufacturers must show that their packaging meets the PPWR requirements that apply to it. Manufacturers must prepare technical documentation and an EU Declaration of Conformity (DoC).
A seafood business should establish with its packaging supplier which business is the Manufacturer for each type of packaging.
Where the packaging supplier is the Manufacturer, the seafood business should obtain the DoC and pass it on to its EU customer. Where the seafood business is the Manufacturer, it must prepare the DoC and supporting technical documentation itself.
The PPWR sets out what the DoC should contain. In simple terms, this includes:
- Packaging identification: enough information to identify the packaging covered.
- Manufacturer details: the name and address of the PPWR Manufacturer.
- Statement of responsibility: confirmation that the Manufacturer takes responsibility for the DoC.
- Statement of conformity: confirmation that the packaging meets the relevant EU requirements.
- Standards and specifications: relevant standards or technical specifications used to show compliance.
- Supporting information: other relevant information, including details of independent assessment where required.
- Sign-off: the place and date of issue and the name, role and signature of the person signing for the Manufacturer.
The Manufacturer must support the DoC with technical documentation showing how the packaging meets the relevant requirements. This may include specifications, test results and supplier declarations.
The DoC is a compliance document. It does not need to be physically attached to each item of packaging.
GB businesses moving packaged goods to NI should also consider these requirements. The PPWR’s conformity requirements apply in NI under the Windsor Framework. A DoC may therefore also be needed for packaging placed on the NI market. GB businesses should check who is the Manufacturer and make sure the necessary conformity information is available.
Businesses should review their conformity documentation when packaging materials, specifications or suppliers change.
3. Packaging must not be excessive
The PPWR introduces requirements to reduce unnecessary packaging. These requirements do not apply from 12 August 2026.
From 12 February 2028, businesses filling sales packaging must reduce empty space to the minimum needed to protect the product and allow the packaging to perform its function.
From 2030 or later, businesses filling grouped, transport or e-commerce packaging must keep the empty-space ratio to a maximum of 50%. The exact date will depend on when the EU introduces the detailed rules.
From 2030, Manufacturers must also design packaging so that its weight and volume are reduced to the minimum needed.
For seafood, businesses should consider these future requirements when reviewing:
- Ice levels in fresh fish boxes
- Absorbent pads in fresh fillet packs
- Secondary retail cartons
- Pallet wrap and stabilisation materials
Businesses do not need to meet these new PPWR packaging minimisation requirements from 12 August 2026. They should consider the future requirements when reviewing or changing packaging.
4. Packaging must be recyclable
The PPWR introduces new recyclability requirements. These requirements do not apply from 12 August 2026.
From 2030 or later, packaging placed on the EU market will need to meet EU design-for-recycling requirements.
Further requirements will apply from 2035 or later. These will consider whether packaging is recycled at scale.
Common seafood packaging affected by the future requirements includes:
- Vacuum packs
- Flexible plastic bags
- Rigid trays
- Insulated fish boxes
The materials used in the packaging will be important. For example, packaging made from several materials can be harder to recycle.
Businesses do not need to meet the new PPWR recyclability requirements from 12 August 2026. They should discuss future compliance with their packaging suppliers when reviewing or changing packaging.
5. Labelling and information
The PPWR introduces harmonised EU packaging labels. These labels will give information about packaging materials and help consumers sort packaging waste.
These new labels are not required from 12 August 2026.
The main harmonised packaging labelling requirement will apply from 12 August 2028 or later, depending on when the EU introduces the detailed rules.
Seafood businesses should be aware that they may need to update packaging such as vacuum packs, frozen seafood bags, cardboard sleeves and outer cartons.
Businesses should keep the requirements under review as the EU finalises the detailed labelling rules.
6. Producer registration and Extended Producer Responsibility (EPR)
From 12 August 2026, UK seafood businesses that are classed as Producers may need to register and meet EPR requirements in the EU Member States where they are the Producer. This can include reporting packaging and paying towards the cost of managing packaging waste.
As explained above, where an EU customer is the Importer of Record, it will normally be the Producer. A UK business should check its own position where it acts as the Importer of Record – including when using DDP Incoterms – or sells directly to EU end users without an EU importer taking on the Producer role.
Where a UK business is the Producer, it should check the registration and EPR requirements in each relevant EU Member State. It should also check whether it needs to appoint an Authorised Representative for EPR in that country.
Companies that provide EPR and packaging compliance services may also provide Authorised Representative services. They can help with registration, reporting and other EPR requirements. Businesses should check the services and costs before appointing a provider.
The EU PPWR’s EPR requirements do not apply domestically in NI. NI remains part of the UK’s packaging EPR scheme.
What should UK seafood exporters do about the requirements applying from 12 August 2026?
UK seafood exporters should:
- Make a list of the packaging used for their seafood products.
- Ask packaging suppliers who is the PPWR Manufacturer for each type of packaging.
- Where the packaging supplier is the Manufacturer, obtain the relevant DoCs and supporting compliance information.
- Ask packaging suppliers for evidence that food-contact packaging meets the PFAS limits and other relevant chemical requirements.
- Pass relevant conformity information on to EU importers and distributors.
- Where the UK business is the Producer, check the registration and EPR requirements in each relevant EU Member State. The business should also check whether it needs an AuthorisedRepresentative for EPR.
- Review packaging and conformity documentation when materials, specifications or suppliers change.
- Businesses should also prepare for further PPWR requirements that apply from later dates.
Summary of PPWR requirements applying from 12 August 2026
Various PPWR requirements apply from 12 August 2026. UK seafood exporters must meet the relevant requirements when placing packaged seafood on the EU market.
These include limits on PFAS in food-contact packaging and requirements for conformity assessment and documentation. UK businesses that are classed as Producers may also need to register and meet EPR requirements in the relevant EU Member States.
GB businesses are affected when they export packaged seafood to the EU. NI businesses are directly in scope of many PPWR requirements because of the Windsor Framework.
Not all PPWR requirements apply from 12 August 2026. Important requirements on packaging minimisation, recyclability, labelling, recycled content and reuse apply from later dates.
What PPWR requirements apply from later dates?
The EU will introduce further PPWR requirements in stages. Key changes for seafood businesses include:
- From 2028: businesses will need to reduce empty space in sales packaging. Harmonised EU packaging labelling requirements will also start to apply, although the exact timing depends on the EU introducing the detailed rules.
- From 2030: plastic packaging will become subject to minimum recycled-content requirements. Packaging minimisation requirements will also apply.
- From 2030 or later: packaging will need to meet design-for-recycling requirements.
- From 2030: reuse requirements will apply to some types of packaging. Businesses using pallets, crates, boxes and other transport packaging should consider how these requirements may affect them.
- From 2035 or later: further recyclability requirements will apply, including requirements on whether packaging is recycled at scale.
The timing of some requirements depends on the EU adopting further detailed rules. Businesses should keep these requirements under review.
National plastic packaging taxes
National plastic packaging taxes are separate from the PPWR.
Some EU countries, including Spain, have their own taxes on plastic packaging. These taxes continue to apply alongside the PPWR.
Where the EU customer is responsible for importing the packaged seafood, it will usually deal with any relevant national plastic packaging tax. UK exporters should confirm responsibilities with their EU customers and provide the packaging information they need.
Complying with the PPWR does not necessarily mean that a business has met all national packaging requirements in the EU country where its products are sold.
Further information
For further information and guidance, please contact the regulation team by emailing regulation@seafish.co.uk