Much of the Packaging and Packaging Waste Regulation (PPWR) applies in Northern Ireland under the Windsor Framework, including the design, substance, labelling and economic operator rules. The Commission’s notice C/2025/946 says Articles 41 to 55, which cover EPR, registers, collection, deposits and targets, should not apply there. Businesses in Great Britain selling into the EU count as third-country businesses.
Why does an EU regulation apply in Northern Ireland?
Because the Windsor Framework already covered the old packaging directive. Article 5(4) and point 25 of Annex 2 listed Directive 94/62/EC, and Article 13(3) reads such a reference as covering the act that replaces it. The Commission’s notice C/2025/946 concludes that point 25 “shall therefore now be read as referring to Regulation (EU) 2025/40”.
DAERA, Northern Ireland’s environment department, says the rules apply to packaging placed on the Northern Ireland or EU markets, not in England, Scotland or Wales.
Which PPWR rules apply in Northern Ireland?
The product rules do, while EPR and the targets do not. The Commission’s notice lists the provisions that should not apply; the rest follows by subtraction.
| PPWR area | Northern Ireland |
|---|---|
| Substances, recyclability, recycled content, compostability, minimisation, labelling, and manufacturer, importer and distributor duties (Articles 4 to 22) | Applies |
| Empty space (Article 24) and the 2030 single-use format bans (Article 25, Annex V) | Applies |
| Re-use targets and take-away refill and re-use offers (Articles 29 to 33) | Should not apply |
| Lightweight plastic carrier bag measures (Article 34) | Should not apply, unless Northern Ireland takes its own reduction measures |
| EPR, registers, collection, deposit systems and recycling targets (Articles 41 to 55) | Should not apply |
| Article 23, parts of Article 56, Articles 57 and 63 | Should not apply |
The notice is Commission guidance, hence “should not apply”. Packaging EPR in Northern Ireland runs under the UK’s own scheme instead. Dates are in the PPWR timeline and the single-use restrictions answer.
What does a business in Great Britain owe when selling into the EU?
The same as any business outside the EU. Union law stopped applying to the UK at the end of the transition period, outside the Windsor Framework. A business in Great Britain therefore cannot be the PPWR importer, which Article 3(1)(17) reserves for businesses “established within the Union”.
It becomes the producer when it sells directly to EU end users, and then registers in each Member State of sale. Each Member State may also require a producer outside the EU to appoint an authorised representative for extended producer responsibility there, under Article 45(3). When it sells to an EU importer or distributor that resells, the EU buyer is the producer. Where it makes the goods, or has them made under its own name or trademark, it carries the manufacturer duties. The same routes for sellers outside the EU apply.
Will the UK align with the PPWR?
That is undecided. DAERA says “A decision on whether to align with the PPWR across the UK has not yet been taken”, and that a formal consultation is being planned.
Sources: Commission Notice C/2025/946 on Northern Ireland, Withdrawal Agreement and Windsor Framework, DAERA, Packaging and Packaging Waste, GOV.UK, EPR for packaging, Regulation (EU) 2025/40 (PPWR)
For a seller in Great Britain, GreenSutra’s PPWR consulting first splits sales between Northern Ireland and the EU. The EU PPWR guide covers the product rules.