New EU Packaging Rules: What the PPWR Means for Dutch Business and the Agri-Food Sector

Packaging rules in the European Union are entering a new phase. The Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40 entered a force on 12 August 2026, replacing the previous Packaging and Packaging Waste Directive and introducing a common regulatory framework directly applicable across EU Member States.

For businesses operating in the Netherlands, the Regulation represents more than a change in waste policy. It introduces requirements that can affect packaging design, material choices, supply chains, retail operations, logistics, food service and producer responsibility. For the agri-food sector in particular, the implications are significant: packaging plays an essential role not only in transporting and presenting products, but also in protecting food quality, hygiene and safety.

While many of the Regulation's most substantial obligations will be phased in towards 2030, businesses should already be assessing how their packaging portfolios and operating models may need to adapt.

From packaging waste to packaging design

One of the central shifts introduced by PPWR is that packaging sustainability is increasingly addressed before packaging becomes waste. The Regulation requires packaging to be recyclable and introduces a system under which recyclability will ultimately be assessed according to performance grades. From 2030, design-for-recycling criteria will form part of that assessment, with packaging falling below the required recyclability threshold facing restrictions on being placed on the market. At the same time, manufacturers and importers will be required to reduce packaging weight and volume to the minimum necessary to maintain its functionality. From 2030, packaging characteristics intended merely to increase the perceived volume of a product, such as unnecessary layers, false bottoms and double walls, will generally no longer be permitted. Importantly, the Regulation recognises that packaging must continue to fulfil functions including hygiene, safety and product protection. For companies, this means packaging decisions are likely to become increasingly connected to regulatory compliance. Manufacturers, importers, retailers and their packaging suppliers will need to consider recyclability, material use and packaging functionality together rather than as separate issues.

Particular implications for agri-food

The agri-food sector faces some of the Regulation's most specific requirements. A major immediate change concerns PFAS in food-contact packaging. From 12 August 2026, food-contact packaging containing PFAS at or above the concentrations specified in the Regulation may no longer be placed on the market. Compliance must also be supported through technical documentation. Plastic packaging will also be subject to minimum recycled-content requirements. Under Article 7, the 2030 requirements include different thresholds for contact-sensitive PET packaging, other contact-sensitive plastic packaging, single-use plastic beverage bottles and other plastic packaging. Here the Regulation explicitly recognises the particular challenges of food packaging. It allows for derogations where suitable recycling technologies for contact-sensitive packaging, including food packaging, are not sufficiently available, and provides for exceptional adjustments where shortages or excessive prices of recycled plastics could have severe adverse effects, including on the security of food supply. This balance between circularity and food protection also appears elsewhere in the Regulation. When businesses are required to reduce empty space in sales packaging, for example, air within food or protective gases used to protect a food product are not treated as empty space.

Some familiar packaging formats will need to change

From 1 January 2030, several packaging formats listed in Annex V will be restricted. These include certain single-use plastic formats directly relevant to agri-food and hospitality. Among them is single-use plastic packaging for less than 1.5 kg of pre-packed fresh fruit and vegetables, although Member States may establish exemptions where packaging is necessary to prevent issues such as water loss, microbiological hazards, physical damage or oxidation. The restrictions also extend to certain single-use plastic packaging for food and beverages consumed on HORECA premises, as well as individual portions of products such as condiments, sauces, coffee creamer, sugar and seasoning, subject to the exceptions established by the Regulation. For food producers, retailers and hospitality operators, adapting may therefore involve more than changing packaging material. In some cases, it may require reconsidering how a product is sold, served, transported or returned.

Reuse and refill move closer to the mainstream

The PPWR also creates concrete obligations around reuse and refill. By 12 February 2027, HORECA businesses selling takeaway beverages or ready-prepared food must provide a system allowing consumers to bring their own containers, without charging them more or offering less favourable conditions than for the equivalent product in single-use packaging. By 12 February 2028, relevant HORECA businesses must also offer consumers the possibility of receiving takeaway food or beverages in reusable packaging within a reuse system, subject to an exemption for micro-enterprises. Further requirements arrive from 2030. Certain transport packaging will be subject to reuse requirements, while final distributors of alcoholic and non-alcoholic beverages will generally have to make at least 10% of those products available in reusable packaging within a reuse system. The Regulation nevertheless contains sector-specific exemptions, including for certain packaging in direct contact with food and feed and for specified beverage categories. For businesses, reuse therefore raises operational questions beyond the packaging itself: collection, return, cleaning, tracking and the organisation of reuse systems may all become part of compliance.

A transition that requires early preparation

Not every PPWR requirement takes effect in 2026. Many of the major recyclability, recycled-content, reuse and packaging-format requirements arrive between 2027 and 2030. But that should not be interpreted as a reason to postpone preparation. Packaging developed today may remain part of a company's product portfolio for years. Decisions concerning packaging suppliers, materials, production lines, logistics arrangements and reuse systems can also require considerable planning. The Regulation itself acknowledges the particular importance of the agri-food sector: when the European Commission evaluates the PPWR by 2034, the evaluation must include a dedicated assessment of its impact on the agri-food system and food waste. For Dutch businesses across manufacturing, food and beverage production, retail, hospitality, packaging and logistics, the coming years therefore offer an important opportunity to understand where regulatory obligations intersect with existing business models, and where early adaptation may be necessary.

Join the ICC webinar

To help businesses better understand these changes, the International Chamber of Commerce invites companies and stakeholders to join the webinar “Unfolding the New Packaging Rules for Agri-Food Operators Supplying the EU Markets” on September 8th. The session will provide an opportunity for businesses supplying the EU market to further explore the new packaging regulatory landscape and what it means for agri-food operators.

Learn more and register for the ICC webinar