A practical scenario: a Vietnamese coffee exporter to Germany. Its German importer announces: under PPWR, the current packaging fails — redesign needed (less plastic, more recycled content), and EPR fees will be deducted from purchase prices. “Packaging is regulated too?” — in the EU, packaging is a regulated object — non-compliant packaging can’t enter the market.
1. PPWR: the EU’s new packaging law
PPWR (Packaging and Packaging Waste Regulation, (EU) 2025/40) took effect 11 February 2025, with obligations phasing in from 12 August 2026. Key content: packaging-reduction targets (cutting unnecessary weight and volume); recyclability — packaging must be recyclable by design criteria, with material-specific recycling targets; EPR (Extended Producer Responsibility): producers/importers pay fees for packaging collection and recycling; bans on certain single-use plastics (on-site food-service plastics…). As a regulation, it applies directly in every EU state — no transposition needed.
2. Impact on Vietnamese exports to the EU
PPWR targets EU-based producers/importers — but Vietnamese exporters feel it indirectly through contracts: EU importers demand PPWR-compliant packaging (recyclable design, less plastic), labeling (sorting instructions, recycled content), and EPR cost-sharing (deducted from prices or charged separately). Reality: many German and French importers have sent “PPWR packaging requirement packs” to Vietnamese suppliers since 2025. Non-compliance — lost EU orders. Companies need to: audit all EU-bound packaging, redesign for recyclability, work with domestic packaging suppliers.
3. A PPWR packaging checklist for exporters
- Audit current packaging: materials, weight, recyclability — against PPWR criteria.
- Redesign: less virgin plastic, more recycled content, easier sorting — with packaging suppliers.
- Labeling: sorting instructions, recycled content — per EU models.
- EPR: agree EPR cost allocation with importers — build into price negotiations.
- Timeline: obligations phase in from 12 August 2026 — time to prepare, but don’t wait.
Packaging: PPWR-compliant before EU entry
This article is general information. Each product needs individual assessment. FLAT Law Firm helps companies meet EU-market requirements. Contact us for advice.
This article is general information only and does not replace legal advice for any specific case. Regulations may change; please check the current texts.
Frequently asked questions
1. What is PPWR?
The EU Packaging and Packaging Waste Regulation ((EU) 2025/40) — in force 11 February 2025, phasing in from 12 August 2026.
2. What is EPR?
Extended Producer Responsibility — producers/importers pay for packaging collection and recycling.
3. Are Vietnamese exporters subject to PPWR?
Indirectly — via EU importer demands (compliant packaging, labeling, EPR cost-sharing).
4. What about single-use plastics?
PPWR bans certain types (on-site food-service plastics…) — audit current packaging.
5. How does a regulation differ from a directive?
A regulation applies directly in every EU state — no per-state transposition like directives.
This article is pending review by the QA Council.
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