August 2026 and beyond: implementation of the new EU packaging waste regulation in Ireland

The Packaging and Packaging Waste Regulation 2025/40 (the PPWR) entered into force on 11 February 2025, with the majority of provisions taking effect in Ireland and across all Member States from 12 August 2026. The PPWR replaces the Packaging and Packaging Waste Directive 94/62/EC as implemented in Ireland by the European Union (Packaging) Regulations 2014 (S.I. No. 282 of 2014). The PPWR requires businesses to redesign packaging, fund collection and recycling schemes and meet phased sustainability targets, while also creating opportunities for companies that innovate towards circular packaging solutions. 

Our previous article What the new EU packaging regulation means for businesses looked at the PPWR and the imposition of mandatory recyclability, labelling and extended producer responsibility obligations on businesses. This article will look at some recent developments, including the helpful guidance note on the PPWR issued by the European Commission earlier this year, as well as looking at the role of Repak and designated competent authorities in the implementation of the PPWR in Ireland.

Key dates

• The PPWR entered into force on 11 February 2025.
• The majority of provisions apply since 12 August 2026 including the requirements for detailed packaging documentation, declarations of conformity, PFAS ban in food packaging and heavy metal limits.
• Member States have until 12 February 2027 to establish national penalties.
• Reusable packaging labelling requirements apply from 12 September 2029.
• By 1 January 2030 packaging must be designed for material recycling whereby resulting secondary raw materials are of sufficient quality that they can be used to substitute primary raw materials.
• By 1 January 2035 packaging must be capable of separate collection and recycling at scale.
• By 1 January 2040 higher recycled content and reuse targets apply.

European Commission guidelines on the implementation of the PPWR

On 30 March 2026, the European Commission published guidelines on the implementation of the PPWR (the Guidelines). The Guidelines note that they are in response to a “significant number” of queries which the Commission received on the implementation of the PPWR from stakeholders. This helpful document runs to almost 60 pages and has the stated aims of supporting the effective and timely implementation of the PPWR, along with facilitating its uniform application across the EU.  

The Guidelines provide helpful clarity on issues such as the definition of packaging, as well as dealing with the definitions of various economic operators to which the PPWR applies. In addition to the Guidelines, a detailed FAQ document was published in March and updated in August 2026.

Role of Repak

Repak has operated as an extended producer responsibility (EPR) scheme in Ireland since 1997 under Ministerial approval.

Minister of State Alan Dillon TD, at the Department of Climate, Energy and the Environment, renewed Repak’s approval to operate as the packaging EPR scheme for a further period of ten years in early 2026. Repak has a key role to play in the implementation of the PPWR in Ireland and has published a guide to the PPWR for Irish businesses and has also introduced a useful PPWR Hub.

Designation of competent authorities

In November 2025, a number of entities were designated under S.I. No. 541 of 2025 as responsible for the implementation and enforcement of certain obligations under the PPWR in Ireland. 

(i) The Environmental Protection Agency (EPA)

The EPA is designated as the competent authority for the PPWR provisions concerning the calculation of recycling targets, databases and reporting. This includes maintaining packaging waste databases and reporting to the European Commission on Ireland’s implementation of its packaging waste obligations.

(ii) Local authorities

Each local authority is designated, within its functional area, as competent authority for Articles 32 and 33 of the PPWR. Article 32 concerns refill obligations for final distributors, requiring them to allow consumers to use their own containers for certain products. Article 33 establishes the re-use offer obligation for the take-away sector, requiring final distributors in the accommodation and food services sector to offer beverages and ready-prepared food in reusable packaging.

(iii) The Minister for Climate, Energy and the Environment (the Minister)

The Minister holds the broadest set of responsibilities under S.I. No. 541 of 2025, including the power to grant exemptions from re-use targets in certain circumstances, re-use and refill targets for economic operators, and the reduction of plastic carrier bags. The Minister is also the designated authority in relation to the EPR regime including the producer register, registration procedures and oversight of producer responsibility organisations, mandatory collection measures and making certain information available to consumers regarding the prevention and management of packaging waste.

Penalties

Article 68 of the PPWR requires each Member State to lay down rules on penalties for infringements of the Regulation by 12 February 2027. The penalties must be effective, proportionate and dissuasive. In Ireland, the detailed penalty regime under the PPWR has not yet been enacted. S.I. No. 541 of 2025 designates competent authorities but does not itself create offences or provide for penalties.

Businesses should keep the position on penalties under review, as Ireland will need to adopt further implementing measures to give full effect to the PPWR penalty framework ahead of the February 2027 deadline.

Conclusion

The PPWR marks a significant shift in how packaging obligations are regulated across the EU. With the majority of its provisions now in effect since 12 August 2026, businesses that manufacture, import, distribute or make packaging available on the Irish or European market should already be taking active steps to ensure compliance. Looking to the future, businesses should continue to monitor the evolving enforcement and implementation landscape. While the detailed penalty regime under the PPWR has not yet been enacted in Ireland, Member States are required to have penalty provisions in place by February 2027. Businesses should keep the position on penalties under review as Ireland adopts further implementing measures. Implementing and Delegated Acts at EU level will also be required to flesh out much of the detail required for full implementation of the PPWR and should be monitored closely.

While the PPWR undoubtedly presents operational challenges, particularly around supply chain logistics and increased costs under the EPR scheme, it also creates opportunities for businesses that take a proactive approach. Early compliance can support access to new markets, strengthen sustainability credentials and position businesses ahead of competitors. Engaging with the European Commission and Repak resources and staying up to date with developments along the implementation timeline of the PPWR will be important for businesses looking to stay ahead of the curve.

With thanks to Brian Temple for his assistance in the preparation of this article.

For more information in relation to this topic, please contact Alison Fanagan, Consultant] [A1] Rachel Kemp, Senior Practice Development Lawyer or another member of the Environmental & Planning Team.

Date published: 22 September 2026