OCTOBER 2026  |  SEEDWORLD.COM/EUROPE  I  SEED WORLD EUROPE   I   57
Frequently Asked Questions published on 3 August 2026 are there­
fore worth monitoring as the system develops.
EPR deserves particular attention because it can create obli­
gations market by market. Seed companies should establish where 
their packaging becomes waste, who is considered the producer in 
that country and what registration, reporting and producer respon­
sibility requirements apply. For companies accustomed to interna­
tional seed trade, the challenge will sound familiar: Seed World 
Europe has previously examined how different national requirements 
can turn seemingly straightforward seed movement into a regulatory 
maze. PPWR aims for greater EU harmonisation, but companies 
should not assume that EPR compliance has already become one 
single European procedure.
BIGGER PACKAGING CHANGES ARE 
APPROACHING
Recyclability is one of the central pillars of the PPWR. Beginning 
in 2030 or later where implementation depends on the adoption of 
delegated or implementing measures — packaging will increasingly 
need to meet harmonised design for recycling criteria. The goal is to 
ensure packaging is not only recyclable in theory but also designed 
for effective recycling at scale.
Plastic packaging will also face minimum recycled content 
requirements. For the general category of plastic packaging not cov­
ered by another specific category or exemption, the PPWR estab­
lishes a target of 35 % post-consumer recycled plastic from 2030, 
subject to the regulation’s detailed timing provisions and calculation 
methodology. A conventional polypropylene seed sack may therefore 
eventually be affected, making it sensible for companies to begin 
discussions with their packaging suppliers well before the deadline.
This fits into a wider shift already taking place within seed 
company sustainability strategies. Seed World Europe has highlighted 
how companies are moving beyond breeding targets to address 
energy, water, waste and operational footprints, including efforts to 
reduce waste and environmental impacts within seed related opera­
tions. PPWR effectively adds a regulatory driver to a transition that 
many companies had already begun voluntarily.
WHAT ABOUT THE 25 KG POLYPROPYLENE 
SEED BAG?
This deserves special attention because large polypropylene sacks 
are widely used for turf, forage, cereal and other seed shipments. 
The PPWR contains reuse targets from 2030 for specified transport 
packaging and for certain sales packaging used for transporting 
products, including flexible packaging formats. For several catego­
ries, the initial reuse target is 40%.
The crucial question is whether a particular seed sack is con­
sidered merely sales packaging or sales packaging that also has an 
evident transport function. The Commission indicates that design, 
shape and size can be relevant when making that assessment. There 
is currently no specific commission ruling stating that every 25 kg 
polypropylene seed bag falls within the 40% target, so conventional 
sacks cannot yet be regarded as subject to a reuse requirement. At 
the same time, companies should not assume that these sacks auto­
matically fall outside the provision.
It would be equally risky to assume that they are automatically 
outside the requirement. A substantial sack specifically designed 
both to contain a commercial quantity of seed and to facilitate han­
dling and transport is precisely the kind of format companies should 
assess with their packaging suppliers and compliance specialists. 
This is especially relevant for international companies, which already 
face the practical consequences when regulatory requirements and 
physical seed logistics intersect, as illustrated in Seed World Europe's 
examination of post Brexit seed movement and the costs created by 
regulatory friction.
Regulatory complexity is already becoming a recurring feature 
across many parts of the seed business. In areas such as biological 
seed treatments, Seed World Europe has similarly found that evolving 
and insufficiently harmonised rules can create substantial complex­
ity for companies operating across markets. Packaging may appear 
less technically demanding than seed treatment or plant health 
regulation, but the combination of environmental requirements, 
supply chain roles and national EPR systems means it should not 
be underestimated.
For European seed companies and overseas exporters alike, the 
most useful question is therefore no longer simply whether seed can 
continue to be shipped in a particular bag. Companies increasingly 
need to know who is legally responsible for that bag, what evidence 
must accompany it, what happens to it after use and whether the 
same packaging format will still satisfy European requirements 
several years from now.
The familiar 25 kg polypropylene seed sack is not suddenly pro­
hibited because the PPWR has begun to apply. But under Europe’s 
new packaging regime, it is no longer just a bag either. 
Editors’ Note: This article provides a general overview of Regulation 
(EU) 2025/40 and does not constitute legal advice. Companies should 
verify the requirements applicable to their individual packaging formats, 
supply arrangements and EU markets.
What Should Seed Companies Do Now?
Companies do not need to panic or abandon their existing 
packaging overnight. They should, however, treat the PPWR 
as a compliance project now rather than something that 
can be left until 2030.
1. Map the packaging portfolio. Record the bags, 
packets, boxes, liners, drums, big bags, pallets and 
other formats being used, together with their material 
composition, weight, dimensions, supplier and destination 
markets.
2. Map the supply chain roles. Determine who is the 
manufacturer, importer, distributor and EPR producer for 
the relevant transactions. Do this separately where supply 
arrangements differ between countries or customers.
3. Talk to packaging suppliers. Request accurate 
information on material composition, recycled content, 
packaging weight and recyclability. Ask suppliers how 
existing products are expected to perform against future 
PPWR requirements.
4. Review conformity documentation. Establish which 
technical documentation, declarations, identification 
details and conformity procedures apply now and which 
will become applicable later.
5. Check EPR obligations country by country. Identify 
where packaging is placed on the market and where 
it will become waste. Confirm registration, reporting, 
financing and representative requirements rather than 
assuming that the importer or customer automatically 
handles them.
6. Put 2030 on the packaging agenda now. Assess 
recyclability and recycled plastic requirements and give 
particular attention to larger flexible seed sacks that 
could potentially fall within the PPWR reuse provisions.

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