Packaging Compliance 2027–2028: What Businesses Need to Prepare for Now

This blog was originally posted on 15th October, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY CATHERINE BURKE, Senior Quality Assurance Lead (Regulatory Content), ADHERENT

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Table of Contents

• Introduction
• Packaging Compliance Deadlines in 2027
• Packaging Compliance Deadlines in 2028
• Frequently Asked Questions

Introduction

The packaging regulatory landscape is entering a period of significant change. Across Europe and other key markets, new requirements are being introduced to reduce packaging waste, improve recyclability, strengthen producer responsibility and provide greater transparency around packaging materials and their environmental impact.

For businesses that manufacture, import, distribute or sell packaged products, 2027 and 2028 will bring a number of important compliance deadlines. While some requirements may still seem way off, the scale of the changes means that preparation cannot be left until the last minute. Packaging specifications, supplier relationships, data collection processes, labelling and reporting systems may all need to be reviewed well in advance. In this blog, we highlight some of the key packaging compliance deadlines coming into effect in 2027 and 2028.

Packaging Compliance Deadlines in 2027

1 January 2027 – Washington Chapter 173-925 WAC, Post-consumer Recycled Content in Plastic Containers 

Producers must annually meet no less than the minimum PCRC percentage of 20% for the total weight of plastic trash bags sold, offered for sale, or distributed in or into Washington state. 

1 January 2027 – Quebec Regulation O.C. 973-2022 Respecting a System of Selective Collection of Certain Residual Materials

Producers must arrange for the collection and transportation of residual materials across all Northern villages. They are also required to cover the collection and transportation of residual materials made from rigid polystyrene plastic or flexible plastic, as well as materials associated with products used to support, protect or present goods throughout the supply chain, from the producer through to the final user or consumer.

1 January 2027 – Kyrgyz Republic Law No. 139 on Amendments to the Law of the Kyrgyz Republic “On Restricting the Circulation of Polymer Film Bags and Plastic Products within the Territory of the Kyrgyz Republic”

From this date, a ban on the production and sale of polymer film bags and plastic products and a ban on the free distribution of polymer film bags in trade and services will apply. 

1 January 2027 – France Order of 2 December 2025 relating to Product Packaging used by Households and/or Professionals and Falling under points 4° and 5° of Article R. 543-43, III of the Environmental Code

France’s Minister Delegate for Ecological Transition announced via press release that although France’s extended producer responsibility (EPR) scheme for professional packaging was due to apply from 1 July 2026, the infrastructure needed has yet to be formalised. Therefore, it has been announced that the process has begun to postpone the application date until 1 January 2027. The formal legislation enacting the extension has yet to be released.

1 January 2027 – Uzbekistan Decree No. UP-25 on Measures to Accelerate Reforms in the Field of Technical Regulation based on Advanced International Practice

Companies producing goods subject to technical regulations, including packaging and sealing materials, must adopt the “Conformity Uzbekistan” (CUz) mark.

From 1 January 2027 to 31 December 2027 – Bulgaria Decree No. 420 of 31 December 2020 amending and supplementing legal acts of the Council of Ministers

At least 67% of all packaging waste shall be recycled during this period.

12 February 2027 – EU Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40 

Packaging included in an extended producer responsibility scheme or covered by a deposit and return system may be identified by a QR code or other standardised digital marking technology. 

The EU Commission is required to adopt a Delegated Act on minimum reusability requirements by this date. This law will establish the minimum number of rotations (lifespans) for the most frequently used packaging formats. 

31 May 2027 – Nova Scotia Extended Producer Responsibility for Packaging, Paper Products and Packaging-Like Products Regulations N.S. 139/2023 

Producers of designated material supplied to consumers in Nova Scotia are required to submit an annual report to the Administrator that contains the information set out in Article 29 of the Regulations. 

1 July 2027 – Taiwan Announcement No. 1146111613, 2025 on Amendment to the “Scope of Responsible Enterprises, Symbol Dimensions, Placement, and Other Compliance Requirements for Items or Containers Subject to Mandatory Recycling Labeling” 

From this date, enterprises responsible for plastic liners and blister packaging must label them with a plastic material identification code. Labelling is required from the day after the date falling three months after registration.

30 September 2027 – Taiwan Announcement No. 1146111613, 2025 on Amendment to the “Scope of Responsible Enterprises, Symbol Dimensions, Placement, and Other Compliance Requirements for Items or Containers Subject to Mandatory Recycling Labeling” 

Plastic liner and blister packaging manufacturers and importers who have completed responsible enterprise registration between 1 July 2025 and 30 June 2027 shall, by this date at the latest, mark the relevant recycling labels (i.e. plastic material recycling identification code) on the plastic liners or blister packaging that are manufactured, sold, given away, or promoted. 

31 December 2027 – Philippines DENR Administrative Order (DAO) No. 2023-02 – Implementing Rules and Regulations of Republic Act No. 11898

A recovery target of 70% applies to plastic packaging for the preceding year. 

31 December 2027 – Montenegro Law No. 128 on Amendments to the Law on Waste Management

The Extended Producer Responsibility (EPR) scheme for packaging must be established by this date. 

Packaging Compliance Deadlines in 2028

1 January 2028 – EU Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40

The EU Commission is required to adopt Delegated Acts establishing design for recycling criteria; recyclability performance grades; a description, for each packaging category listed in Table 1 of Annex II, of the conditions for compliance with their respective recyclability performance grades; and a framework concerning the modulation of financial contributions to be paid by producers to comply with their extended producer responsibility obligations set out in Article 45(1), based on the packaging recyclability performance grades, by this date. 

The EU Commission is required to adopt Delegated Acts establishing and specifying the detailed conditions and reporting requirements to be applied to the pooling arrangements for re-use targets by this date.

1 January 2028 – California Senate Bill 54 Enacted on Plastic Pollution Producer Responsibility Act 

Producers of all plastic covered material offered for sale, distributed, or imported in or into the state shall achieve at least a 30% recycling rate by this date.

1 January 2028 – Nigeria National Environmental (Plastic Waste Control) Regulations, S.I. No. 20

Persons in the plastic value chain using single-use PET plastic articles for packaging must incorporate food-grade recycled PET at a minimum ratio of 25% from this date. 

1 January 2028 – Switzerland Packaging Ordinance (OEmb) of 24 June 2026

A disposal tax on glass packaging takes effect from this date. 

From 1 January 2028 to 31 December 2028 – Bulgaria Decree No. 420 of 31 December 2020 amending and supplementing legal acts of the Council of Ministers 

At least 68% of all packaging waste shall be recycled during this period. 

12 February 2028 – EU Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40 

The Commission shall review the state of technological development and environmental performance of biobased plastic packaging. Based on the review, the Commission shall, where appropriate, present a legislative proposal in order to lay down requirements relating to biobased feedstock in plastic packaging by this date. 

Specified tea/coffee packaging and sticky labels attached to fruit and vegetables must be compostable by this date. Packaging other than that referred to in paragraphs 1 and 2 of Article 9, including packaging made of biodegradable plastic polymers and other biodegradable materials, shall allow material recycling in accordance with Article 6 and without affecting the recyclability of other waste streams, by this date. 

The EU Commission is required to adopt implementing acts to establish the methodology for the calculation of the empty space ratio referred to in Article 24(1) by this date. 

The economic operator who fills the sales packaging shall ensure that empty space is reduced to the minimum necessary for ensuring the packaging functionality, including product protection, by this date.

From 1 July 2028 to 30 June 2030 – Taiwan Amendment to the attached table of Item 1 of the public notice regarding “Fee Rates for the Collection, Removal, and Treatment of Containers”

The second-stage fee rate (NT$14 per kilogram) applies during this timeframe. 

1 July 2028 – Maryland Regulations COMAR 26.04.14 on Packaging and Paper Products—Producer Responsibility 

From this date, or a later date identified by the Department, producers who do not intend to join a PRO must submit their Individual Producer Responsibility Plan (IPP).

1 July 2028 – Maryland Senate Bill 901 Enacted on Environment – Packaging and Paper Products – Producer Responsibility Plans 

On or before this date, and every 5 years thereafter, producers shall, individually or as part of a PRO, submit a producer responsibility plan for review and approval.

29 October 2028 – Maryland Senate Bill 901 Enacted on Environment – Packaging and Paper Products – Producer Responsibility Plans 

From this date, or a later date identified by the Department, a producer may not sell, offer for sale, distribute, or import for sale or distribution covered materials for use in Maryland unless they have an approved responsibility plan on file.

31 December 2028 – Philippines DENR Administrative Order (DAO) No. 2023-02 – Implementing Rules and Regulations of Republic Act No. 11898 

A recovery target of 70% applies to plastic packaging for the preceding year. 

31 December 2028 – South Korea Notice No. 2024-277 on Exemptions from regulations on the use of disposable products (prohibition of free provision and restrictions on use)

General retailers, bakeries, and food service businesses must stop using biodegradable plastic bags, shopping bags, and straws after this date.

FAQ

• Why should businesses start preparing now for 2027 and 2028 packaging deadlines?
  The changes are large in scale, so preparation can’t be left until the last minute. Businesses may need to review packaging specifications, supplier relationships, data collection processes, labelling and reporting systems well in advance.
• What does the EU PPWR require by 12 February 2027?
  Packaging included in an EPR scheme or covered by a deposit and return system may be identified by a QR code or other standardised digital marking technology. The EU Commission must also adopt a Delegated Act on minimum reusability requirements, which will set the minimum number of rotations for the most frequently used packaging formats.
• What has changed for France’s EPR scheme for professional packaging?
  The scheme was due to apply from 1 July 2026, but the infrastructure it needs has not yet been formalised. The process to postpone the application date to 1 January 2027 has begun, though the formal legislation enacting the extension has yet to be released.
• What recycling rate does California Senate Bill 54 require, and by when?
  Producers of all plastic covered material offered for sale, distributed, or imported in or into California must achieve a recycling rate of at least 30% by 1 January 2028.
• What are the key Maryland deadlines in 2028?
  On or before 1 July 2028, producers must submit a producer responsibility plan, either individually or as part of a PRO, and every 5 years after that. Producers who don’t intend to join a PRO must submit an Individual Producer Responsibility Plan from that date. From 29 October 2028, or a later date identified by the Department, producers can’t sell, distribute or import covered materials for use in Maryland unless they have an approved responsibility plan on file.

 

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