The PPWR — Regulation (EU) 2025/40 on packaging and packaging waste — replaces the 1994 Packaging Directive and applies generally from 12 August 2026. It is a regulation, not a directive: it needs no national transposition and binds businesses directly. It does not decide who pays for packaging waste — EPR already does that — it decides what the packaging itself may look like. Same box, two different questions.
- The general application date is 12 August 2026. Heavy-metal limits and the PFAS restriction on food-contact packaging start on that date.
- The heavy product requirements come later: harmonised labelling in 2028, and recyclability grades A/B/C, recycled content and the 50% void-space cap in 2030.
- Filler material counts as void space. Switching from plastic to paper cushioning does not help you meet the void-space rule — only a smaller box does.
- The PPWR contains EPR rules of its own (Articles 44–45): producer registration, distance sellers and the authorised representative.
- From 12 August 2026 online marketplaces must obtain your EPR registration number for the consumer's Member State before allowing you to sell.
What the PPWR is, in one minute
The PPWR replaces Directive 94/62/EC on packaging. That difference matters in itself: a directive had to be transposed into national law by each Member State, whereas a regulation is directly applicable — it applies regardless of how well the national rules have caught up with it.
The regulation entered into force on 11 February 2025 and applies generally from 12 August 2026. Most of the concrete product requirements are tied to later dates, but preparation cannot be postponed to 2029: the recyclability and void-space rules affect how packaging is designed, which takes years to work through supplier contracts and production lines.
The PPWR concerns everyone who places packaged goods on the EU market — manufacturers, importers, distributors, webshops and online marketplaces alike — but in different roles and with different obligations.
The deadlines that matter
- 12 August 2026 — general application. Heavy-metal limits and the PFAS restriction on food-contact packaging apply. Hungarian law (the Waste Act and Government Decree 442/2012) is aligned to the PPWR from the same day.
- 12 February 2027 — take-away: hospitality must allow consumers to be served in their own container.
- 12 February 2028 — void-space minimisation starts to apply to consumer packaging.
- 12 August 2028 — harmonised material labelling on packaging and waste receptacles.
- 1 January 2029 — mandatory deposit-return systems with a 90% separate collection target for the bottles and cans concerned.
- 1 January 2030 — the big one: recyclability grades A/B/C, mandatory recycled content in plastic packaging, void space capped at 50%, and the first reuse targets.
- 2035 · 2038 · 2040 — 2035: „recycled at scale”. From 2038 only grade A or B packaging may be placed on the market. From 2040, higher recycled-content targets.
PPWR and EPR: same box, two different questions
The most common misunderstanding is that the two are the same thing. They are not — but they are closely connected and they run on the same data.
EPR asks: who pays for the waste?
In Hungary this is governed by the Waste Act and Government Decree 80/2023: registration in OKIR, the MOHU relationship, quarterly reporting by material type and weight, and payment of the extended producer responsibility fee. A foreign seller must appoint a Hungarian authorised representative. This regime has been live since 1 July 2023.
PPWR asks: what may the packaging be like?
Material composition (heavy metals, PFAS), recyclability (A/B/C) and recycled content, void-space limits and packaging minimisation, harmonised labelling and technical documentation, plus reuse and refill targets.
And here is where they meet
1. The same data feeds both. Your EPR report already requires packaging to be recorded by material type and weight. That is precisely the dataset from which the PPWR questions on recyclability, void space and labelling can be answered. If your EPR records are in order, you are halfway through your PPWR preparation. If they are not, you now have two things to fix at once.
2. The PPWR itself contains EPR rules. Articles 44–45 deal with extended producer responsibility: entry in the producer register, the obligations of distance-selling producers, and the institution of the authorised representative. The PPWR does not „replace” EPR — it reinforces it at EU level.
3. On marketplaces, the two converge. From 12 August 2026 an online platform may not let a producer sell without the EPR registration number of the consumer's Member State. In plain terms: because of the PPWR, anyone selling into Hungary will need Hungarian EPR registration immediately.
Six traps most companies fall into
1. The „manufacturer” is not the „producer”
The PPWR uses two distinct roles that many languages blur into one. The manufacturer carries product responsibility: the requirements of Articles 5–12, labelling and the technical documentation. The producer carries the EPR obligations of Articles 44–45. Read as a single concept, you will either fulfil the wrong obligation or take on far more than you need to.
2. Paper cushioning will not save you from the void-space rule
This is the most expensive misunderstanding. Under Article 24(3), space filled with filler material counts as empty space — crumpled paper, bubble wrap, air pillows and polystyrene alike. So swapping plastic cushioning for paper in an oversized box does not bring you any closer to the 50% void-space limit that applies from 2030. Only a smaller box does.
3. E-commerce packaging is not exempt from labelling
A widespread (and incorrect) reading is that transport packaging needs no harmonised label. Plain transport packaging indeed does not — but e-commerce packaging does, under Article 12(1). As a webshop, this applies to you even if the box is „only for shipping”.
4. You do not have to know what the box is made of — but you do have to ask
As a webshop you have no laboratory and no materials engineer. You do not need one: under Article 16 the supplier is obliged to provide the manufacturer with all documentation needed to demonstrate compliance. Your job is to request it, in writing, as part of your procurement process. Build it into your supplier terms now and the later deadlines will not come as a shock.
5. Cardboard boxes are exempt from the 40% reuse target
Good news for webshops: under Article 29(4)(d), cardboard boxes are exempt from the reuse target for transport packaging. You do not need to switch to returnable plastic crates to comply — your paper-based box is not a risk on this particular point.
6. National concepts are being rewritten underneath you
From 12 August 2026 the Hungarian concept of „packaging material” (csomagolószer) is repealed from Government Decree 442/2012 and replaced by PPWR concepts. Several national provisions still refer to the old terminology. If your business model relies on a Hungarian exemption — for example the EPR exemption for reusing used packaging — it is worth re-checking that the exemption still says what you think it says.
What to do now
You do not have to solve 2030 this year. Four steps that pay off immediately:
- Get your packaging records in order. Material type, weight and packaging category per product. This is the basis of your EPR report and the same data will be needed to demonstrate PPWR compliance. One job, two obligations.
- Request documentation from your suppliers. Article 16 entitles you to it. Write into your purchasing terms that data on composition and recyclability is part of the delivery.
- Look at your box sizes. The void-space rule is the most expensive change because it touches warehouse processes. Filler does not count — only real size reduction. The earlier you start, the cheaper it is.
- Check your EPR registration. If you sell on marketplaces, from 12 August 2026 the platform will verify your registration number and may suspend your account if it is missing or incorrect. As a foreign seller this cannot be solved without a Hungarian authorised representative.
Frequently asked questions
Do I need a new registration because of the PPWR?
The PPWR does not create a new Hungarian registration portal — entry in the producer register still goes through OKIR. What the PPWR adds is that from 12 August 2026 online marketplaces and fulfilment service providers must verify that registration number before providing their services. Sellers who have so far managed without registration will now be forced to have one.
Does it apply to me as a webshop if I only resell products?
Yes, on two counts. First, you are the obliged party for your own transport and e-commerce packaging — box, filler, tape. Second, if you import or buy from abroad, you are also the first to place the product's packaging on the domestic market. The product-responsibility requirements (composition, labelling) generally fall on the manufacturer — which is exactly where the manufacturer/producer distinction saves you money.
What happens if I do not comply?
The PPWR leaves sanctions to the Member States, but the practical consequence arrives sooner: under the Digital Services Act rules an online platform must suspend its service to a trader whose data is incomplete or inaccurate and who fails to correct it after being asked. In other words, lost revenue comes before the fine.
I am a foreign company selling into Hungary. What do I need?
You must be registered as a producer in Hungary, and since you have no Hungarian establishment you need to appoint a Hungarian authorised representative (Government Decree 80/2023, Section 10(2)). The representative handles registration, quarterly reporting and dealings with MOHU, while substantive responsibility remains with you. This is the service we provide to foreign clients.