Packaging and Packaging Waste Regulation (PPWR)

Review date: July 2026

1. What is the Packaging and Packaging Waste Regulation (PPWR)?

The Packaging and Packaging Waste Regulation (PPWR), formally cited as Regulation (EU) 2025/40, is a binding European Union legislative entered into force on 11 February 2025, and its core obligations apply from 12 August 2026. Additional requirements are phased in progressively through 2028, 2030, 2035, and 2040.

The PPWR replaces and repeals the Packaging and Packaging Waste Directive 94/62/EC (PPWD), which had governed EU packaging law since 1994. Crucially, as an EU Regulation  rather than a Directive  the PPWR applies directly and uniformly across all  EU Member States across EEA without requiring transposition into national law.

2. Core Objectives of the PPWR

  • Ensure all packaging placed on the EEA market is recyclable by 2030, assessed using harmonized recyclability criteria and grading (Classes A–D).
  • Introduce harmonized EU-wide labelling on all packaging to enable consistent consumer sorting and disposal from 2028.
  • Strengthen and standardize Extended Producer Responsibility (EPR) schemes with eco-modulated fees across Member States.
  • Support the EU Green Deal Circular Economy Action Plan and 2050 climate neutrality target.

3. What Constitutes Packaging Under the PPWR?

For Zebra Technologies, ‘packaging’ is defined as any material or component, regardless of its composition, that is used for the containment, protection, handling, delivery, or presentation of a Zebra product at any stage in the supply chain.

This definition extends beyond the primary shipping box and includes every item that is not an integral, functional part of the final product itself and is intended to be removed and disposed of by an economic operator or the end-user.

4. What Does Zebra do with Packaging as Required by the PPWR?

As Zebra places packaged products in EEA markets, Zebra has obligations across the entire packaging lifecycle from design and materials selection through to end-of-life waste management. The PPWR places these responsibilities directly on producers the companies that first make packaging available on a national EEA market.

5. ZEBRA’s Packaging Obligations Under the PPWR

ZEBRA treats PPWR compliance as an opportunity not merely an obligation to reduce the environmental footprint of its products. Packaging teams work continuously to design out waste, increase recycled content, and support the collection and recycling infrastructure that enables packaging materials to remain in productive use.

6. What is the Role of End Users in Making the PPWR Sustainable?

Zebra end users who receive packaged goods play an essential and irreplaceable role in the sustainable management of packaging waste.

End User Obligations and Best Practices

  • Sort packaging waste correctly at source by material category and place in the appropriate collection stream provided by the local municipality or private waste operator.
  • Use designated collection points and follow hazard warnings and disposal instructions for specific hazardous materials and packaging containing hazardous products.
  • Read and act on packaging disposal labels and pictograms. From 2028, EU-harmonized pictograms will provide consistent instructions across all Member States.
  • Avoid littering and improper disposal. Packaging discarded in the environment cannot be collected, sorted, or recycled, and causes direct harm to ecosystems and human health.
  • Minimize packaging waste by choosing products with less packaging and opting for refillable or reusable alternatives where available.

7. How Does ZEBRA Comply with the PPWR?

ZEBRA has implemented a structured PPWR compliance program covering producer registration, EPR financial contributions, packaging reporting, design compliance and labelling transitions. The program is managed by ZEBRA’s Environmental Compliance Team in coordination with packaging engineering, procurement, and legal functions.

8. Producer Registration

ZEBRA has registered or is in the process of registering with the national producer registers in each Member State where it is the obligated producer. Under the PPWR, producers must be registered in every country where they first make packaging available on the national market.

FAQ

1. Packaging Reporting

ZEBRA reports, on at least an annual basis, the quantities and types of packaging placed on the market in each Member State where it is obligated. Reports are disaggregated by material category and packaging type in accordance with the harmonized reporting formats under the PPWR and applicable national requirements.

2. Packaging Design Compliance

ZEBRA's packaging engineering and sustainability teams are actively working to ensure all packaging meets PPWR recyclability criteria ahead of the 2030 deadline. This includes assessing all packaging against D4R standards and recyclability class grading, reducing unnecessary packaging volume and layers, and eliminating restricted substances.

3. Labelling

ZEBRA will apply for required packaging disposal information labels in compliance with applicable Member State requirements. From 12 August 2028, ZEBRA will transition to the harmonized EU-wide disposal pictograms mandated by the PPWR.

4. When is ZEBRA NOT Obligated Under the PPWR?

ZEBRA's EPR and producer obligations under the PPWR are jurisdiction specific. They apply only in the EEA market where ZEBRA is the entity that first makes packaging available on the national market. Where another party in the supply chain holds this position, that party not ZEBRA bears the producer’s obligations.

The PPWR's definition of 'producer' is broad and may shift compliance responsibility across complex supply chains. Companies that previously considered themselves 'only distributors' or 'only brand owners' may now be classified as producers with full compliance obligations. If you are uncertain whether ZEBRA or your organization holds the producer’s obligation in each Member State, please contact ZEBRA’s Environmental Compliance Team for clarification.

Circumstances Where ZEBRA is Not the Obligated Producer

Circumstance

Explanation

Sales through authorized distributors/resellers

Where an authorized distributor or reseller is the first entity making packaging available on a national EEA market, that distributor or reseller is the obligated producer not ZEBRA. The distribution partner bears registration, reporting, and EPR fee obligations in that country.

Customers located outside the EEA

The PPWR applies to packaging placed on the EEA market. Sales to customers outside the European Economic Area (EEA) and non-EU third countries are outside the PPWR scope. Separate national packaging regulations may apply in those territories. However, any business from outside EEA countries exporting packaged goods into the EEA market must still fully comply to PPWR regulation.

Internal/intra-logistics packaging

Packaging used purely for internal or inter-business logistical purposes and not made available to the market (e.g. reusable transit packaging consistently returned and never sold or transferred) may fall outside EPR reporting scope, subject to verification under applicable national rules.

 

6. When is ZEBRA Obligated Under the PPWR?

ZEBRA is the obligated producer and therefore bears EPR registration, reporting, and financial contribution obligations under the PPWR in the following specific circumstances:

  • For end user customers located in the EEA who purchase packaged products directly from ZEBRA; and
  • For authorized distributors and resellers located in EEA market where ZEBRA has registered as the obligated producer and is the first entity making packaging available on that national market.

7. Acronyms, Definitions, and Further Information

The following acronyms and defined terms are used throughout this document in the context of the PPWR  packaging compliance:

Acronym

Full Term and Explanation

PPWR

Packaging and Packaging Waste Regulation - Regulation (EU) 2025/40. The primary subject of this document.

PPWD

Packaging and Packaging Waste Directive - Directive 94/62/EC.

EPR

Extended Producer Responsibility - the system under which producers bear financial and operational responsibility for end-of-life management of packaging they place on the market.

D4R

Design for Recycling - the set of harmonized criteria used to assess and classify packaging recyclability under the PPWR (graded Classes A to D). Only Class C or above permitted from 2030.

EEA

European Economic Area - comprises the 27 EU Member States plus Iceland, Liechtenstein, and Norway.

EU

European Union - the political and economic union of 27 Member States

For additional inquiries, please consult www.zebra.com/environment or reach out to our Product Environmental Compliance Team at PEC@zebra.com.