Packaging laws like the PPWR now govern markets in more than 60 countries across the world, with fees that can reach millions of euros and penalties that can restrict market access. John Blake, Senior Director Analyst at Gartner, explores the key risk areas and explains how companies can address them.
The EU’s Packaging and Packaging Waste Regulation (PPWR) generally applies from 12 August 2026, but many producers are approaching the deadline with fragmented packaging records and a lack of clear oversight for compliance. In addition, packaging extended producer responsibility (EPR) is growing globally, exposing gaps in packaging data.
Based on the rise in global packaging regulations, broad based data and governance gaps could pose serious financial and market access risks. Many companies still need to establish central oversight of their packaging obligations. That oversight begins with reliable packaging specification data and should provide functional stakeholders with enough information to prepare for rising compliance costs.
Crucially, these efforts need to coalesce around a single, authoritative owner to highlight and mitigate these risks in conjunction with senior management.
Localized compliance efforts cannot keep pace
Packaging EPR legislation transfers the cost of waste collection and management to obligated producers, including brand owners, retailers and importers. Companies must register with producer responsibility organizations and report precise information about the packaging they place on the market. Some laws also set requirements for recycled content or restrict materials.
The obligations differ by jurisdiction. The EU’s PPWR operates alongside country level packaging EPR schemes and a widening collection of state laws in the U.S. As of July 2026, seven U.S. states had passed packaging EPR legislation, with several others reviewing their own legislation. The enacted laws covered about 20% of the U.S. population, leaving producers responsible for fees on a corresponding share of domestic sales.
A global company responding to these requirements market-by-market can quickly lose track of which legal entity is responsible, or which products are covered. Reporting dates will change, and new jurisdictions will add their own rules. A series of local projects may complete individual filings, but it will not give senior leaders a consistent view of the company’s total obligations.
Packaging costs are showing up in company accounts
The financial impact is already appearing in company accounts. One major UK retailer reported a £29 million charge for a new packaging EPR levy in its 2025 interim results, recognizing the expected full-year cost during the period.
Other organizations have estimated that PPWR compliance could cost as much as one million Euros or more in each EU country where products are sold. Separate national obligations can therefore become a substantial annual expense for multinational producers.
Published fee schedules provide enough information to begin estimating the initial costs. U.K. government schedules for 2025 to 2026 set base fees at “£192 per tonne for glass and £461 per tonne for fibre-based composites.”
In the United States, the Circular Action Alliance has also published 2026 schedules for Oregon and Colorado with California’s expected later this year. Finance teams can apply these rates to current packaging volumes to reveal the effect on budgets.
Late or inaccurate reporting adds another source of expense. California can impose penalties of up to $50,000 per day for noncompliance, including failures to register or report packaging. Oregon’s penalties can reach $25,000 per day. Continuing violations could produce fines approaching $1 million in a single month. PPWR and California’s SB 54 also create the possibility that noncompliant packaging will be restricted from the market.
These figures place packaging compliance beyond the remit of a local sustainability team. Senior management needs a consolidated estimate of expected fees and a clear account of the circumstances that could place sales at risk.
Weak packaging data increases the risk
Regulators require information about material type and packaging format, with quantities reported by weight. These records are used to calculate fees and establish baselines for packaging-reduction targets. Information previously maintained for purchasing or product development must now support formal submissions with financial consequences.
Many producers do not hold complete packaging records in a verified form. Short-term reporting requirements are proving difficult because companies must collect missing information from separate sources, update outdated specifications and check the results before submission. The burden increases when the same product is sold in markets with different reporting rules.
A missing specification can prevent a producer from supporting its filing. An inaccurate material record may affect the amount charged. As future packaging restrictions take effect, the same weaknesses could make it difficult to establish whether a format remains compliant.
Companies should test their systems against the information regulator’s request. The test should determine whether complete records can be retrieved for each affected product without a manual reconstruction shortly before the deadline. Specialist compliance software may help where records are dispersed across legacy systems. Legal counsel can clarify which entities fall within each law when the obligations are unclear.
Compliance needs an owner with authority
Packaging compliance should be assigned to a named leader with the authority to involve senior management. That leader should maintain a current view of the jurisdictions in which the company is obligated and the products subject to each law.
The work will require input from several parts of the business. Legal teams can interpret the obligations while packaging specialists provide the underlying specifications. Finance must prepare for new fees, and sourcing decisions may need to reflect how different materials are charged. Regular review is essential because a regulatory issue may require a packaging change or affect the timing of a product launch.
Authority matters as much as coordination. A compliance leader who can identify a data problem but cannot obtain resources or change a packaging decision will remain dependent on last-minute responses. Senior leaders need to know who can act when a filing is at risk or a package no longer meets the requirements of a market.
Packaging laws increasingly influence whether a product can remain on sale. A company that cannot verify what its packaging contains will struggle to calculate what it owes, or to support its regulatory filings. As product restrictions take effect, that same data gap could determine whether the packaging can remain in the market.
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