When developing a new clothing collection, packaging can seem like a relatively small consideration. The garment, fabric, fit, price and delivery date naturally receive most of the attention.
But if you sell clothing into the European Union, packaging is becoming something that needs to be considered much earlier in the product development and supply chain process.
The European Union’s new Packaging and Packaging Waste Regulation, commonly known as PPWR, introduces a major overhaul of the rules governing packaging sold in the EU.
Regulation (EU) 2025/40 entered into force on 11 February 2025 and generally applies from 12 August 2026. Unlike the previous Packaging and Packaging Waste Directive, a regulation is directly applicable across EU Member States, although some obligations and implementation details will continue to develop over the coming years.
For fashion brands, this matters because packaging is everywhere.
A garment may leave the factory inside a polybag, several garments may then be packed into a carton, the carton may be secured with tape or straps, and an online order may later be placed inside another mailing bag or box before reaching the consumer.
PPWR potentially touches all of these stages.
What Is the EU Packaging and Packaging Waste Regulation?
PPWR is part of the EU’s wider transition towards a circular economy. Its objective is not simply to increase recycling after packaging becomes waste. It attempts to change the way packaging is designed, manufactured, used, reused and ultimately recycled.
Importantly, PPWR applies to packaging regardless of the material used and covers packaging originating from manufacturing, retail, distribution, services and households.
The regulation introduces requirements covering areas including:
- Packaging minimisation
- Recyclability
- Recycled content in plastic packaging
- Packaging labelling
- Reuse
- Packaging waste reduction
- Extended Producer Responsibility (EPR)
- Restrictions on certain packaging formats and substances
For a fashion company selling into Europe, PPWR therefore shouldn’t be regarded simply as a problem for the packaging supplier.
It can become a sourcing, product development, logistics and compliance issue.
Why Should Fashion Brands Care?
Think about how much packaging can be associated with a single garment.
At factory level, this might include:
- Individual garment polybags
- Tissue paper
- Cardboard inserts
- Stickers and labels
- Cartons
- Adhesive tape
- Pallet wrapping
- Plastic or textile straps
Once the product enters retail or e-commerce distribution, there may also be:
- Mailing bags
- E-commerce boxes
- Protective fillers
- Branded presentation boxes
- Additional wrapping
Some of this packaging protects the garment from moisture, dirt and damage. Some makes warehouse operations more efficient. Some exists primarily for presentation and branding.
PPWR increasingly forces companies to ask a straightforward question:
Does all of this packaging actually need to be there?
Less Packaging, Not Just Different Packaging
One of the important principles behind PPWR is packaging minimisation.
The regulation requires packaging to be designed so that its weight and volume are reduced to the minimum necessary while maintaining its functionality. Importantly for consumer brands, marketing and consumer acceptance alone are not sufficient justifications for additional packaging weight or volume.
This could become particularly relevant to fashion and luxury retail.
A beautifully presented garment might currently be delivered inside a large branded box, surrounded by tissue paper and other presentation materials. Under the direction of PPWR, brands increasingly need to think about whether their packaging is proportionate to what it is actually protecting.
That does not mean attractive packaging is disappearing.
It means packaging design will increasingly need to combine branding with material efficiency.
The 50% Empty-Space Rule
E-commerce brands should pay particular attention to the rules concerning empty space.
By 1 January 2030, or three years after the relevant implementing rules enter into force if that is later, grouped, transport and e-commerce packaging will generally be subject to a maximum empty-space ratio of 50%. The European Commission is due to establish the calculation methodology by 12 February 2028.
And simply filling a large box with more packaging isn’t necessarily the solution.
For the calculation, filling materials such as bubble wrap, air cushions, paper cuttings, foam and similar materials are treated as empty space.
Imagine shipping a folded T-shirt inside a box several times larger than necessary and filling the remaining space with paper.
From a PPWR perspective, adding more filler doesn’t necessarily solve the excessive-packaging problem.
For fashion e-commerce businesses, packaging dimensions may therefore become another area requiring optimisation.
Packaging Will Increasingly Need to Be Designed for Recycling
PPWR establishes the principle that packaging placed on the EU market must be recyclable.
From 2030, packaging recyclability is intended to be assessed using performance grades A, B and C, based on EU design-for-recycling criteria. Packaging that fails to reach the required recyclability level will eventually be unable to be placed on the EU market. The requirements become stricter again from 2038.
This has an important implication for packaging design.
A package made from several individually recyclable materials is not necessarily the same thing as a package that is easy to recycle as a complete packaging system.
Designers may increasingly need to consider whether different components can be separated and sorted effectively.
That could encourage simpler packaging structures and greater attention to:
- Material combinations
- Laminations
- Coatings
- Adhesives
- Labels
- Printing
- Closures
For fashion brands, the appearance of the packaging will therefore increasingly need to be considered alongside its end-of-life recyclability.
Plastic Packaging and Recycled Content
PPWR also introduces minimum recycled-content requirements for plastic packaging.
From 2030, subject to the detailed conditions and timelines in the regulation, plastic parts of packaging will have to contain specified minimum percentages of post-consumer recycled plastic. The exact requirement depends on the packaging type and material.
This is particularly relevant to fashion because the humble transparent garment polybag remains one of the most commonly used pieces of packaging in the industry.
The polybag has a genuine purpose. It protects finished garments against dust, moisture and contamination as products travel from factory to warehouse and eventually to the retailer.
The challenge for the industry is therefore not simply to eliminate plastic regardless of consequence.
It is to determine how necessary protection can be achieved while meeting increasingly demanding requirements around material use, recycled content and recyclability.
Reusable Transport Packaging Is Also Part of the Picture
PPWR isn’t concerned only with the packaging consumers see.
Transport packaging is also affected.
From 2030, certain transport packaging used within the EU—including pallets, boxes, trays, crates, flexible formats and some pallet wrapping and strapping—is subject to reuse targets. The general target for the covered transport packaging is at least 40% reusable packaging within a reuse system, with specific rules and exceptions applying depending on the circumstances.
This is an important distinction for international fashion supply chains.
The obligations applying to packaging used to ship garments from an Asian factory into Europe are not necessarily identical to those applying to subsequent movements between warehouses, distribution centres and retailers within the EU.
Brands therefore need to look at their entire packaging flow rather than treating every carton, pallet or mailing bag as the same compliance question.
Labelling Is Going to Change Too
PPWR also creates harmonised packaging labelling requirements intended to help consumers identify packaging materials and dispose of them correctly.
The details are being implemented progressively, so brands should be careful about redesigning packaging around assumptions about final label specifications before the relevant implementing measures are settled.
This is one reason PPWR compliance should be treated as an ongoing process rather than a one-off packaging redesign.
What About Clothing Manufactured Outside Europe?
This is particularly important for brands manufacturing in China and elsewhere outside the EU.
PPWR covers packaging placed on the EU market; manufacturing the garment outside Europe does not make the packaging irrelevant to the regulation.
That creates an important supply-chain consideration.
A European fashion brand may establish its packaging specification, but much of the physical packaging may actually be sourced, printed and applied thousands of kilometres away by its garment manufacturer and packaging suppliers.
A brand might specify:
- Polybag material and thickness
- Recycled content
- Carton dimensions
- Printing
- Labels
- Tissue paper
- Packing ratios
- Folding method
- Shipping configuration
The manufacturer’s ability to source compliant packaging and maintain accurate specifications therefore becomes increasingly important.
Compliance begins much earlier than the moment a carton arrives at European customs.
PPWR Could Change the Relationship Between Brands and Garment Manufacturers
For years, packaging instructions on garment tech packs could be relatively simple: one garment per polybag, a specified carton size and a particular packing ratio.
The future is likely to require more information.
Brands may increasingly need to discuss packaging with manufacturers during product development rather than after production has already started.
Questions could include:
- Is this packaging actually necessary?
- What material is it made from?
- Does it contain recycled material?
- Can the different components be separated?
- Is it designed for recycling?
- Can packaging dimensions be reduced?
- Is the packaging specification suitable for the destination market?
- Can the supplier provide the necessary material documentation?
These questions may sound like small operational details, but across tens of thousands—or millions—of garments, small packaging decisions become significant.
Don’t Wait Until 2030
It would be easy to look at some of PPWR’s major 2030 targets and assume there is plenty of time.
That would be a mistake.
PPWR generally applies from 12 August 2026, while additional obligations phase in over subsequent years. Meanwhile, the European Commission continues to develop delegated and implementing measures that will determine some of the technical details.
Packaging development also takes time.
Brands need to identify suppliers, test alternative materials, check product protection, redesign artwork, modify packing procedures, collect documentation and potentially change logistics arrangements.
The companies that start reviewing packaging now will have considerably more flexibility than those waiting until a deadline is approaching.
From Packaging Waste to Better Packaging Design
PPWR shouldn’t only be viewed as another compliance burden.
It can also be an opportunity to reconsider packaging that may have accumulated unnecessarily over years of product development.
Does every garment need the same packaging?
Can carton dimensions be better matched to the products inside?
Can unnecessary components be removed?
Can one well-designed piece of packaging replace several different materials?
Can a packaging specification be designed around recyclability from the beginning rather than changed later?
These are questions worth asking regardless of regulation. Reducing unnecessary packaging can reduce material consumption, shipping volume and waste—and in some cases reduce cost at the same time.
For fashion brands selling into Europe, packaging is no longer something to think about only when the garment is ready to ship.
It is increasingly becoming part of product development itself.
A good garment manufacturer should understand that the job does not end when the final stitch is sewn. How garments are folded, protected, packed and prepared for their destination market is becoming an increasingly important part of the manufacturing process.
For brands preparing for PPWR, now is a good time to start discussing packaging specifications with manufacturers and suppliers—not just what the packaging should look like, but what it is made from, why it is needed and what happens to it after the garment reaches its destination.