The EU Packaging and Packaging Waste Regulation (PPWR — Regulation EU 2025/40) applies from 12 August 2026. With less than three months until the compliance deadline, fashion brands that haven't started their packaging audit are running out of time. This is the practical guide to what PPWR requires, what you need to do immediately, and how to build packaging compliance infrastructure that also supports your DPP programme.
What fashion brands must do before August 2026
Three things are non-negotiable before 12 August 2026:
- →Complete a packaging inventory — every packaging SKU by material, weight, and recyclability grade. You cannot report to EPR schemes without this data.
- →Register with EPR schemes — Extended Producer Responsibility registration is required in each EU country where you sell. Registration deadlines vary by country and some have already passed.
- →Enforce packaging minimisation — void space in your shipping boxes and mailers must not exceed 40% from August 2026. Review your packaging specifications now.
What counts as fashion packaging under PPWR
Everything that wraps, contains, or protects your product for sale or transport: polybags and poly mailers, shipping boxes and cartons, tissue paper and void fill, garment bags, shoe boxes and lids, e-commerce mailers, inner padding, gift boxes and ribbons, and retail bags at point of sale. Hangtags directly attached to garments without secondary packaging, and labels sewn into garments, are generally excluded.
The polybag question
Polybags are not banned — but most current polybag formats will need to change. Single-material LDPE or HDPE polybags can meet the recyclability test. Mixed-material laminated bags — which account for the majority of fashion polybags in use today — almost certainly cannot. If your current polybag spec includes any lamination, metallic finish, or mixed material layer, plan your transition now. Lead times for compliant alternatives run 12–18 months.
QR codes on packaging — from 2027
From 2027, every packaging unit must carry a QR code linking to a digital record containing material composition, recyclability status, recycled content percentage, and producer contact information. This is effectively a DPP for packaging. TraceID generates these records and QR codes in the same batch workflow as product DPPs — one process, two compliance requirements satisfied.
Recycled content targets — 2030
By 2030, all plastic packaging must contain a minimum of 30% post-consumer recycled content, provable through GRS certification or equivalent. For fashion brands, the most affected packaging formats are polybags, mailers, and garment bags. Start engaging with packaging suppliers on recycled content roadmaps now — certification systems take time to establish.
Your PPWR action plan — right now
- →This week: Identify every packaging format you use and its material composition. Flag any formats that are likely non-compliant (mixed material, excessive void space).
- →This month: Register with EPR schemes in your key EU markets. Start with Germany, France, Italy — the largest markets and strictest enforcers.
- →Next 3 months: Audit void space in your shipping boxes. Engage packaging suppliers on recyclability grades and recycled content roadmaps. Import packaging SKUs to TraceID.
- →By Q1 2026: Packaging digital records created in TraceID. Begin QR code rollout planning. Recycled content targets agreed with packaging suppliers.
- →August 2026: Fully compliant. EPR registered. Minimisation rules met. Non-compliant formats phased out.