PPWR/ESPR Enforcement Countdown: Priority Checklist for Korean Companies

Introduction

The EU’s circular economy policies are shifting from directives to directly applicable regulations, signaling a stricter regulatory environment. Notably, (i) the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, “PPWR”) for the packaging sector and (ii) the Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781, “ESPR”) for sustainable products have been adopted. While long-term performance targets scale up through 2030, immediate compliance for substance restrictions, destruction bans, and reporting obligations begins this year. In this newsletter, we outline the key mandates of the PPWR and the ESPR, offering a checklist for companies to assess their compliance and ensure their readiness for these regulatory changes.

2.	Key Mandates and Compliance Timelines

(1)

PPWR

The PPWR aims to build a circular economy by comprehensively managing packaging across its full life cycle – design, manufacture, distribution, consumption, and disposal. Most of its core provisions become legally enforceable on August 12, 2026, while several high-impact mandates phase in by 2030.

From August 12, 2026, the following requirements must be met:

The use of substances of concern in packaging must be minimized, and food-contact packaging where PFAS exceeds specific limits is banned from the market (Article 5).
Manufacturers must perform Conformity Assessments and prepare both the Technical Documentation (“TD”) and the Declaration of Conformity (“DoC”) before placing any packaging on the market (Article 15).
Importers need to verify that these procedures have been completed before placing any packaging on the market and retain a copy of the DoC (Article 18).
Upon requests from national authorities, manufacturers and importers must provide all the information and TD necessary to demonstrate the conformity of packaging with the respective mandates (Articles 15 and 18).

From August 12, 2028, or 24 months after the delegated acts under Article 12 take effect (whichever is later), packaging labeling requirements—containing information on packaging material composition—shall apply (Article 12).

Building on this earlier compliance framework, the following performance mandates will take effect from January 1, 2030, and companies must take preemptive action to integrate these future standards into their transition plans:

Only packaging achieving the recyclability grade A through C may be placed in the EU (Article 6). The recyclability grade will be determined based on various factors, including packaging material composition and structure, separability of the packaging waste, substances of concern, recyclability, and economic viability. Recyclability grades will determine Extended Producer Responsibility (EPR) fees via eco-modulation, rewarding more sustainable packaging with lower costs.
Plastic packaging must incorporate a minimum percentage of recycled content (Article 7). This mandate is expected to stimulate market demand for recycled content.
The manufacturers and importers must minimize packaging and ensure the maximum empty space ratio in e‑commerce shipping packaging does not exceed 50% (Articles 10 and 24).

(2)

ESPR

The ESPR aims to establish a circular economy by comprehensively managing the entire lifecycle of physical products sold on the EU market – design, manufacture, distribution, consumption, and disposal. While many upcoming ecodesign requirements that require further enactment of delegated acts, certain transparency and disposal mandates are already in effect or have deadlines in the near-term:

Under current regulations, large companies are already required to annually disclose information on destruction of unsold products (Article 24).
From July 19, 2026, large companies are prohibited from destroying unsold apparel and footwear (Article 25, Annex VII).

For the majority of product categories, the ESPR serves as a framework, and specific performance and information requirements will be established through enactment of subsequent delegated acts (Articles 1 and 4).

In particular, from 2026 to 2030, the EU will enact these acts to codify specific ecodesign requirements for the prioritized product groups (iron, steel, aluminum, textiles (apparel), furniture, tires, and mattresses), setting specific requirements for product durability, reusability, repairability, recycled content, and environmental impacts (Articles 5 and 18).
Furthermore, electronic devices (smartphones and tablets) and household appliances (washing machines, refrigerators and dishwashers) previously governed by the Ecodesign Directive will be sequentially integrated into this new framework.
Furthermore, alongside existing labeling requirements, the Digital Product Passport (“DPP”) will be implemented as a digital record providing consumers and regulators with transparent lifecycle data (Article 9).
The ESPR also adopts a verification framework (TD, DoC) similar to the PPWR, which will be implemented sequentially as delegated acts are enacted for each product group (Articles 27 and 29).

Implications

The year 2026 marks a critical turning point where the EU’s circular economy framework moves to strict enforcement. With the primary mandates of the PPWR and ESPR expected to be broadly implemented by 2030, companies should proactively develop year‑by‑year action plans to ensure full compliance. Notably, it is advised to establish a data management system to aggregate DPP data (for product) and labeling information (for packaging) from the entire supply chain. In the medium to long term, a phased product/packaging transition strategy will be necessary to meet the applicable ecodesign specifications.

Moreover, since Korea’s Act on the Promotion of Saving and Recycling of Resources and the regulations in major countries importing Korean products are increasingly aligning with EU‑level standards, it is important for companies to prepare an integrated product/packaging design strategy that meets multiple global standards simultaneously, rather than responding to individual laws on a case‑by‑case basis.

[Korean Version]

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