At Agrométodos, we would like to highlight the forthcoming application of the new European Packaging and Packaging Waste Regulation, commonly known as the PPWR. This legislation creates a common framework across the European Union and will require many companies in the agricultural sector to review how they purchase, design, market and manage their packaging.
The change does not affect packaging manufacturers alone. Depending on their activities and on how they place products on the market, it may also apply to importers, distributors, packers, marketers and companies selling packaged products.
Although many of the measures will be introduced progressively, companies should already begin identifying the packaging they use, the documentation available and the role they perform within the supply chain.
What Is the PPWR and When Will It Apply?
Regulation (EU) 2025/40 on packaging and packaging waste establishes requirements covering the entire life cycle of packaging, from its design and manufacture to its marketing, reuse, collection and recycling.
The Regulation entered into force on 11 February 2025 and will generally apply from 12 August 2026. As an EU regulation, it will be directly applicable in the Member States, although some measures have later implementation dates or require technical standards and implementing acts.
The PPWR will progressively replace Directive 94/62/EC. Its purpose is to harmonise European packaging rules, reduce waste generation and promote packaging solutions that are more recyclable, reusable and efficient in their use of materials.
Which Companies in the Agricultural Sector May Be Affected?
The scope of the Regulation is broad, as it applies to packaging placed on the European Union market and to the waste generated from it, regardless of the packaging material or type.
Within the agricultural sector, particular attention should be paid by companies involved in:
- Plant protection products.
- Fertilisers, biostimulants and other agricultural inputs.
- Seeds and products used in agricultural activities.
- Products intended for livestock farming.
- Packaged agricultural products.
- Sales, grouped and transport packaging.
- Imports or distance sales of packaged products.
The specific obligations will depend on the role performed by each company. A packaging manufacturer will not have the same responsibilities as a company that imports products, packages goods under its own brand, distributes merchandise or makes a packaged product available for the first time in a Member State.
For this reason, one of the first steps should be to identify who acts as the manufacturer, importer, distributor or producer in each transaction.
What Changes Does the PPWR Introduce?
Sustainability and Recyclability Requirements
The Regulation establishes a framework aimed at improving packaging recyclability and reducing its environmental impact. Among other matters, it includes requirements relating to design, materials, recycling performance and, for certain plastic packaging, recycled content.
Companies will need to understand the composition of their packaging more precisely and work with suppliers that can provide reliable technical information.
Not all these requirements will become enforceable in August 2026. Some measures, particularly those relating to recyclability, recycled content and design for recycling, will apply at later dates. Companies will therefore need to check the specific timetable for each obligation before modifying any packaging.
Reduction of Packaging Weight and Volume
One of the PPWR’s objectives is to reduce unnecessary packaging and limit its weight and volume to what is strictly necessary for it to perform its function.
In the agricultural sector, this review must be carried out with particular care. Reducing material must not compromise the preservation, strength, safety or transport conditions of products that require specific protection due to their nature.
Adaptation should not simply involve producing lighter packaging. Companies must also be able to justify that the design is appropriate and does not use more material than necessary.
New Labelling Rules
The Regulation provides for a harmonised labelling system designed to make it easier to identify packaging materials and correctly separate packaging waste.
This may require companies to review symbols, disposal instructions, information on material composition and the consistency between the information shown on the label and the actual packaging material.
Part of this system still requires further technical development. Companies should therefore avoid making definitive changes until the relevant specifications and implementation dates have been confirmed.
Compliance and Technical Documentation
Economic operators will need to be able to demonstrate that their packaging complies with the requirements applicable to them.
This may require technical documentation, declarations of conformity and information on the materials used. The information published by SIGFITO specifically highlights packaging preparation, the role of packaging manufacturers, compliance and producer responsibilities.
In practice, agricultural companies should review the documentation they receive from their suppliers and determine whether it is sufficient to prove the characteristics of their packaging.
Extended Producer Responsibility
Extended producer responsibility, also known as EPR, assigns certain financial, organisational and reporting obligations to those who place packaged products on the market in relation to the management of the resulting waste.
The PPWR harmonises aspects of these systems across the European Union, including producer registration, data reporting and contributions towards waste management costs.
Spain already has a framework established by Royal Decree 1055/2022, which includes measures on prevention, reuse, recycling and extended producer responsibility for packaging. Companies will therefore need to assess how their current obligations interact with the new European Regulation.
What Should Companies Begin Reviewing?
Although each case must be assessed individually, several actions can help companies prepare:
- Prepare an inventory of all packaging used.
- Include sales, grouped and transport packaging.
- Identify materials, weights, formats and suppliers.
- Determine the role the company performs in each transaction.
- Request documentation on composition and conformity.
- Review labelling and waste disposal instructions.
- Check current extended producer responsibility obligations.
- Assess whether material can be reduced without compromising safety.
- Establish a system for updating documentation when a supplier or packaging format changes.
These actions are preparatory and form part of an internal review process. They do not mean that all packaging must be changed before 12 August 2026 or that every obligation will become enforceable from that date.
Agricultural Packaging Management and the Circular Economy
The proper management of agricultural packaging does not end when the product has been used. Correct separation, collection and treatment make it possible to recover materials, reduce improper disposal and limit the environmental impact of agricultural activities.
The PPWR reinforces this circular approach by requiring packaging to be designed with the end of its useful life in mind. For agricultural companies, adapting to the Regulation may also provide an opportunity to improve traceability, gain a better understanding of the materials they use and review their relationships with suppliers.
Compliance will remain a legal obligation, but preparing in advance can also help reduce risk, organise documentation more effectively and move towards more efficient packaging management.
Frequently Asked Questions About the PPWR
When Will the PPWR Begin to Apply?
The Regulation will generally apply from 12 August 2026. However, it includes measures with later implementation dates and others that require technical standards or implementing acts before they become fully enforceable.
Does the PPWR Only Affect Packaging Manufacturers?
No. Depending on their activities and how products are marketed, it may also affect importers, distributors, packers, marketers and companies that place packaged products on the market.
Must Agricultural Companies Change All Their Packaging Immediately?
Not necessarily. Companies should first identify which requirements apply to each type of packaging and when they become enforceable. However, it is advisable to begin reviewing materials, suppliers, labelling, technical documentation and current obligations.
How Is the PPWR Related to Extended Producer Responsibility?
The PPWR harmonises several aspects of extended producer responsibility across the European Union. Spain already has obligations under Royal Decree 1055/2022, so companies will need to assess how their existing responsibilities relate to the new European framework.
On the Agrométodos blog, we will continue sharing information on legislation, innovation and sustainability to help companies in the agricultural sector understand the changes that may affect their activities.
