The European Union’s new packaging rules are already in effect, but not every requirement applies immediately—and chemical drums, intermediate bulk containers (IBCs) and flexible bulk bags need particular attention.
Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR), began applying on August 12, 2026. It introduces requirements covering packaging materials, conformity documentation, waste prevention, recycling and reuse.
For industrial chemical buyers, the immediate challenge is understanding which requirements apply to their packaging and who must demonstrate compliance.
One especially important distinction is that packaging used to transport dangerous goods may qualify for exemptions from certain future reuse and recycled-content targets. That does not mean all chemical packaging is exempt from the regulation.
Purchasing teams should therefore review packaging classifications, supplier documentation and contractual responsibilities before treating existing drums or IBCs as compliant—or unnecessarily replacing suitable packaging.
The PPWR Covers Industrial Packaging, Not Just Consumer Products
The PPWR establishes a harmonized framework for packaging placed on the European Union market, regardless of its material or origin.
Its scope includes packaging supplied empty or filled, subject to the regulation’s definitions and specific exclusions.
The European Commission’s overview of the new EU packaging rules confirms that the regulation entered into force on February 11, 2025, and began applying on August 12, 2026.
It generally replaces the earlier Packaging and Packaging Waste Directive, although some transitional provisions remain.
For chemical supply chains, potentially affected packaging includes steel drums, plastic drums, rigid IBCs, flexible bulk containers, smaller chemical bottles, closures and associated packaging components.
However, different obligations can apply depending on the packaging’s function, materials, contents and how it enters the EU market.
A steel drum supplied for an industrial coating raw material may not face identical requirements to a plastic IBC used for a dangerous liquid.
The regulation also distinguishes several economic-operator roles, including manufacturers, importers, distributors and producers responsible for packaging waste.
These terms have specific legal definitions.
A business that purchases filled chemical drums should not automatically assume the drum manufacturer has every compliance responsibility. Equally, the buyer should not assume that importing a chemical makes it responsible for every packaging obligation.
The correct allocation depends on the supply arrangement and the relevant PPWR provisions.
What Changed on August 12, 2026?
The application date does not mean every future recycling or reuse target became mandatory that day.
Several requirements concern the packaging’s conformity with applicable material and substance rules, together with the documentation needed to establish that conformity.
Under Article 15, manufacturers of packaging must carry out or arrange the required conformity assessment, prepare technical documentation and draw up an EU declaration of conformity when the applicable requirements have been demonstrated.
Article 16 requires packaging and packaging-material suppliers to provide manufacturers with information needed to demonstrate compliance.
For chemical buyers, this creates an important purchasing-documentation question: Who holds the technical evidence for the supplied packaging, and who is responsible for the declaration?
The documentation should relate to the actual packaging design and its applicable requirements.
A generic supplier assurance that a container is environmentally friendly is not equivalent to the information required under the regulation.
Nor does a chemical manufacturer’s ISO certification, standing alone, prove that a particular packaging design complies with the PPWR.
The European Commission’s August 2026 PPWR guidance and frequently asked questions provide additional clarification for companies interpreting the new framework.
This guidance, published on August 3, 2026, is especially useful because packaging responsibilities can differ between manufacturers, importers and other operators.
Businesses should apply the relevant legislative provisions and any applicable national implementation arrangements rather than treating general guidance as an individual compliance approval.
The 2030 Reuse Target Has an Important Dangerous-Goods Exception
One of the PPWR’s major future requirements concerns reusable industrial transport packaging.
Article 29 establishes a target under which certain economic operators using specified transport packaging, or sales packaging used for transport, must ensure that at least 40% of the covered packaging is reusable within a reuse system from January 1, 2030.
The listed formats include pallets, boxes, plastic crates, IBCs, drums and canisters, including relevant flexible formats.
The same article contains additional requirements for particular movements within companies, linked enterprises and individual EU Member States.
Its provisions also include exemptions.
In particular, Article 29(4) excludes packaging used to transport dangerous goods in accordance with Directive 2008/68/EC from the specified reuse obligations.
The published text of Article 29 on reuse targets provides the relevant packaging formats and general requirements. The exemption must be read alongside the corresponding provisions of the regulation and the Commission’s implementation guidance.
This distinction matters because a hazardous chemical and a dangerous good are not necessarily the same regulatory classification.
A chemical may require hazard information under chemical safety legislation without necessarily being classified as dangerous goods for the particular transport operation.
Similarly, a package used for dangerous goods must be assessed under the applicable transport rules; it should not be considered exempt merely because the supplier describes its contents as hazardous.
For chemical purchasers, the first question is whether the specific product and transport operation fall within the relevant dangerous-goods framework.
Only then can the packaging’s eligibility for the exemption be assessed.
The exemption from particular reuse targets is not a general exemption from the PPWR.
Other packaging requirements may still apply.
Recycled Content and Reusable Packaging Are Different Requirements
Another common source of confusion is treating recycled material content and packaging reuse as equivalent.
They address different environmental objectives.
Recycled content concerns how much qualifying recycled material is incorporated into packaging.
Reuse concerns packaging designed and used for multiple trips or rotations within an appropriate reuse system.
A plastic drum manufactured with recycled polymer is not automatically reusable.
Likewise, a reusable IBC does not necessarily contain recycled plastic.
The PPWR introduces minimum recycled-content requirements for specified plastic packaging, with major targets scheduled from 2030 or later if the regulation’s implementing-act timing conditions apply.
These requirements have their own exemptions, including relevant packaging used for dangerous-goods transport.
A purchasing specification should therefore identify which requirement is being evaluated.
Asking a supplier to provide a percentage of recycled polymer is not enough to establish that a reusable packaging system meets its legal obligations.
Similarly, requesting a reusable IBC does not establish that the container is suitable for the chemical’s physical properties, compatibility requirements or transport classification.
The wider environmental benefit also depends on factors such as cleaning, inspection, return transport, replacement rates and end-of-life management.
A claimed reduction in packaging waste should be supported by evidence describing the comparison and its boundaries. It should not be presented as a verified environmental saving without suitable data.
Pallet Wrapping Rules Show Why Exemptions Must Be Read Narrowly
Chemical shipments often use several packaging components together.
A loaded pallet may include primary containers, closures, an outer wrapping film, straps and protective materials.
The PPWR does not necessarily apply identical reuse requirements to every component.
In February 2026, the European Commission adopted a measure exempting certain economic operators using pallet wrapping and straps from the 100% reuse requirements that would otherwise apply to those formats in particular transport arrangements.
The Commission published its decision concerning pallet-wrapping and strapping exemptions on February 25, 2026.
This is not a blanket exemption for all pallet packaging, nor does it remove every applicable PPWR requirement.
It demonstrates why buyers need to examine the exact packaging component and obligation before deciding that a supplier is either compliant or exempt.
For chemical shipments, an assessment of the outer drum or IBC should therefore be accompanied by a separate review of relevant secondary and transport packaging components.
Packaging Sustainability Cannot Override Chemical Compatibility
The environmental objectives of the PPWR do not eliminate existing chemical safety requirements.
A proposed packaging change still needs to protect workers, transport personnel, customers and the environment.
For example, replacing a single-use rigid IBC with a reusable alternative raises questions about chemical compatibility, cleaning, residual contamination, closure integrity and inspection.
If the material is regulated for dangerous-goods transport, the applicable transport-packaging requirements also remain relevant.
The site’s guide to Type C and Type D FIBC electrostatic safety explains why even flexible bulk containers with similar descriptions can require different electrical protection arrangements.
A packaging sustainability claim cannot replace that technical assessment.
The same issue applies to storage arrangements.
Switching from one drum or IBC design to another may affect dimensions, dispensing connections and the containment arrangement used at the receiving facility.
The existing guidance on secondary containment for chemical drums and IBCs provides related considerations for facilities reviewing storage and spill-control systems.
These safety evaluations should remain separate from claims about recyclability or packaging-waste reduction.
A package can have favorable environmental characteristics while still being unsuitable for a particular chemical.
What Chemical Buyers Should Request From Suppliers
A practical PPWR supplier review begins with an inventory of packaging designs rather than a single compliance question covering every product.
For each relevant packaging configuration, buyers should establish the packaging type, materials, intended contents and the countries where it will be placed on the market.
They should also identify the responsible manufacturer, importer and other relevant economic operators.
Where applicable, the purchasing file should contain the packaging supplier’s technical information and the necessary conformity documentation.
For dangerous-goods packaging, the review should include evidence of the relevant transport classification and packaging suitability.
This is particularly important when a supplier changes packaging construction.
A recycled-polymer substitution, different inner liner or revised closure system may affect chemical compatibility or previously established packaging performance.
The supplier should explain what changed and provide appropriate supporting evidence.
For future reuse requirements, buyers should establish whether the intended packaging falls within the regulated category, whether a specific exemption applies and how the packaging system meets the relevant conditions.
Waste-management responsibilities should also be reviewed at the applicable Member State level, including any producer-registration and extended-producer-responsibility obligations.
These matters should not be left to an unsupported statement that the packaging is PPWR-compliant.
Keep the Supporting Documents Separate
A chemical shipment may involve several documents with different purposes.
A safety data sheet (SDS) communicates information about chemical hazards and safe handling. It is not a declaration of packaging conformity.
A certificate of analysis (CoA) reports selected test results for an identified chemical lot. It does not independently establish the regulatory status of the container.
A chemical purchasing specification defines the agreed requirements for the supplied material and any relevant packaging conditions.
A packaging declaration of conformity concerns compliance with the applicable packaging legislation.
Independent laboratory testing may provide evidence about a packaging material or container design, but the result supports only the tested characteristics and conditions.
These documents should complement one another rather than be treated as interchangeable.
The Next Purchasing Decision Is About Evidence
For chemical manufacturers and importers, the PPWR creates two parallel tasks.
The first is determining whether the packaging currently placed on the EU market meets the requirements that already apply.
The second is preparing for future recycling, recycled-content, minimization and reuse obligations where those obligations apply.
The most expensive mistake may be assuming that every industrial chemical container must be replaced with a reusable alternative by 2030.
A similarly serious mistake would be assuming that all chemical packaging is exempt because some dangerous-goods transport packaging qualifies for particular exceptions.
The stronger approach is to identify the packaging configuration, verify the applicable legal classification and obtain the necessary supporting documentation.
That allows sustainability decisions to proceed without weakening chemical safety, transport compliance or purchasing quality.