# The PPWR spares the medicine’s own pack but not its carton or shipper, and pharma packaging targets cluster where the law still bites

> Regulation (EU) 2025/40 lifts the recyclability and recycled-content duties from immediate medicinal packaging and, where quality requires it, from outer packaging, but minimisation, empty-space, reuse and EPR fee rules still reach cartons, leaflets and shippers, and GSK, Pfizer, Sanofi and Haleon each report packaging goals in different units that cannot be ranked against one another.

Publisher: Strategic Packaging Insights  
Published: 2026-10-26  
Last updated: 2026-10-26  
Page: https://www.strategicpackaginginsights.com/insights/pharma-packaging-epr-ppwr-gsk-pfizer-sanofi-haleon/

**Regulation (EU) 2025/40 lifts the recyclability and recycled-content duties from immediate medicinal packaging and, where quality requires it, from outer packaging, but minimisation, empty-space, reuse and EPR fee rules still reach cartons, leaflets and shippers, and GSK, Pfizer, Sanofi and Haleon each report packaging goals in different units that cannot be ranked against one another.**

The four companies sit at different points on the same pack stack. Sanofi targets blisters around syringe vaccines and Pfizer targets shipment materials, GSK's biggest lever is an inhaler propellant that packaging law does not touch, and Haleon, which sells consumer health products into household waste streams, reports 137 thousand tonnes of packaging and an 80% recycle-ready share.

## Executive summary

The European Union's Packaging and Packaging Waste Regulation (PPWR) treats medicines and medical devices as a safety case before a waste case. Recitals 34 and 38 of Regulation (EU) 2025/40 take immediate medicinal packaging, contact-sensitive plastic packaging of medical devices and in vitro diagnostics, and outer packaging where it is needed to preserve the medicine's quality, out of the recyclability and recycled-content duties. The Commission's guidance of 10 June 2026 adds that intravenous bags and pre-filled syringes are not packaging at all.

The exemption is narrower than the industry shorthand suggests. Minimisation under Article 10, the 50% empty-space cap on grouped and transport packaging under Article 24 and the 40% reuse target for transport packaging under Article 29 carry no medicines exemption in the Commission's August 2026 FAQ, and all three start in 2030 at the earliest. National EPR schemes keep charging fees on medicine packs, and PackUK has created separate medical reporting codes rather than an exemption.

Product law pulls the other way on the carton. Delegated Regulation (EU) 2016/161 has required a unique identifier and an anti-tampering device on the outer packaging of most prescription medicines since 9 February 2019, which limits how far a carton can shrink or disappear. Non-prescription medicines are mostly outside that rule, so a consumer health carton has more room to change than a prescription one.

Company disclosures follow this map. Sanofi reports 61.5% of syringe vaccines blister-free in 2025 against 100% by 2030, and Pfizer's 2025 Impact Report puts its packaging work into tertiary shipment materials. GSK's largest footprint lever is the propellant in the Ventolin inhaler, 43% of its carbon footprint, which falls under the F-gas Regulation. Haleon, whose packs end up in household bins, reports 137 thousand tonnes of packaging and 80% recycle-ready, and says it will revisit its 2030 goal during 2026 to align with the PPWR.

For a pharma or consumer health packaging lead, the practical moves are to sort every SKU into the four layers set out in Exhibit 3, document each exemption claimed, build the carton and shipper redesigns that 2030 requires, and settle household or non-household status and medical codes in the UK before the 2027-28 fee year.

## Key findings

1. Recitals 34 and 38 of Regulation (EU) 2025/40 exclude immediate medicinal packaging, and outer packaging where needed to preserve quality, from the recyclability and minimum recycled-content duties; the Commission FAQ places the recyclability exemptions in Article 6(11) and says the Commission will review them by 1 January 2035.
2. Article 10 minimisation applies from 1 January 2030 with exemptions only for protected geographical indications, designs and trademarks, and the Commission FAQ names anti-tamper and anti-counterfeit functions among those a pack shape may need (FAQ, August 2026).
3. Delegated Regulation (EU) 2016/161 puts the safety features on the outer packaging, or on the immediate packaging where there is no outer pack; its Annex II lists only omeprazole 20 mg and 40 mg gastro-resistant capsules among non-prescription medicines that must carry them.
4. In the UK, packaging of medicines dispensed for use at home is household packaging, while products that can only be administered in a professional setting can be classed as non-household (GOV.UK, updated 5 August 2025); PackUK reports red-rated medical packaging that is red because of a regulatory requirement as amber-medical.
5. Cyclamed collected 8,289 tonnes of unused medicines in French pharmacies in 2025, and the collection rate reached 83% against 77% in 2024 (Cyclamed, 26 June 2026).
6. Haleon used 137 thousand tonnes of packaging in the year to 30 June 2025, down from 143 thousand, with plastic down from 62 to 56 thousand tonnes (Haleon 2025 ESG Databook).
7. **SPI calculation:**  on a 100-tonne UK household mix shaped like Haleon's materials, disposal fees run from GBP 28,307.50 all green to GBP 34,862.50 with plastic red at Year 2 illustrative rates, and to GBP 42,438.70 if red plastic is priced at the 2027-28 factor of 1.6.

## What the PPWR exempts, and what it does not

The PPWR has applied since 12 August 2026 and covers packaging across its life cycle, from substances to recyclability, recycled content, minimisation, labelling, reuse and EPR ([PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)). Medicines are not carved out of its scope. They are carved out of specific duties, and Exhibit 2 sets out which, paragraph by paragraph, from official texts consulted on 22 October 2026.

SPI has not yet confirmed every article reference against the operative text in the Official Journal, so the article references below rest on three official sources: the recitals of Regulation (EU) 2025/40, the Commission's Guidance Notice C/2026/3084 of 10 June 2026, and the Commission's PPWR FAQ, August 2026 edition (catalogue KH-01-26-068-EN-N). The EUR-Lex summary, last updated on 26 September 2025, confirms that the recycled-content rule has exceptions for pharmaceutical packaging and medical devices.

**Recyclability.**  Recital 34 says recyclability requirements should not be mandatory for immediate packaging under Directive 2001/83/EC and Regulation (EU) 2019/6, and extends this to outer packaging where it is needed to preserve the quality of the medicinal product, and to contact-sensitive plastic packaging of devices under Regulations (EU) 2017/745 and 2017/746. The FAQ (section IV, Q2) says the exemptions are listed in Article 6(11) and that the Commission cannot grant further ones. Its answer on the review date (section IV, Q9) gives 1 January 2035 and names the lightweight-material exemptions; SPI has not yet confirmed from the operative text whether the medicines exemption is reviewed on the same date or carries its own deadline.

**Recycled content.**  Recital 38 grounds the Article 7 exclusion in human and animal health and the safety and supply of medicines and devices, and applies it to outer packaging where that packaging must meet specific requirements to preserve the quality of the medicinal product. The FAQ (section V, Q9) says immediate packaging will generally qualify as contact-sensitive packaging, and that the two terms should be read the same way when Article 7 is applied. The sister piece on [PPWR recycled-content targets](https://www.strategicpackaginginsights.com/insights/ppwr-recycled-content-targets-2030-2040/) covers the floors themselves.

**Definition.**  The Commission Notice says intravenous bags and syringes are outside the packaging definition, including when pre-filled, because they form an integral part of the medicinal or medical product. A blister tray holding pre-filled syringes in a vaccine pack is packaging, which is why Sanofi's blister-free goal matters for its EU compliance file.

SPI analysis

The word "where" in the outer-packaging exemption carries the weight. A carton that holds a light-sensitive product, a desiccant or a temperature indicator may qualify; a carton that exists to carry a brand panel does not. Each claim needs a reason a regulator can read in the technical documentation, and Exhibit 3 below sorts packs by the reason that applies to them.

## The pack stack: a four-layer ladder of exposure

SPI groups pharma and consumer health packaging into four layers, set by what a pack does for the medicine and which law governs it (Exhibit 3). The layers are an SPI device for sorting SKUs, built from the PPWR texts above and the company disclosures below; they are not legal categories.

Layer A is where a pharma packaging team has the least freedom, because any change to the immediate pack is a variation to the marketing authorisation, and it is where the PPWR asks the least. Layer C is where the team has the most freedom and the PPWR asks the most. Layer B sits between them, and Layer D is where the carbon is, at least for an inhaler maker.

The ladder also explains a split that SPI's [Buyers Database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/) shows across its 42 company profiles. Prescription medicine makers set targets on formats and process, such as blister removal and eco-design plans, while consumer health groups set portfolio-wide percentages in the same terms as personal care brands. The [food and FMCG pledges piece](https://www.strategicpackaginginsights.com/insights/fmcg-packaging-pledges-compared/) covers how those portfolio targets work; this piece covers the layers that make medicines different.

SPI analysis

Reading a company's packaging goals by layer is more useful than reading them by percentage. A target in Layer C will be tested against Article 24 and Article 29 from 2030, while a target in Layer A is a voluntary goal that no PPWR article requires.

## Safety features and the limits of minimisation

The Falsified Medicines Directive, Directive 2011/62/EU, amended Directive 2001/83/EC to require safety features on medicine packs, and Commission Delegated Regulation (EU) 2016/161 sets out how. It has applied since 9 February 2019 (Article 50). The safety features are a unique identifier, encoded in a two-dimensional barcode, and an anti-tampering device, defined in Article 3(2)(b) as the feature that allows a check of whether the packaging of a medicinal product has been tampered with.

The PPWR does not mention the safety features in the recitals SPI read, but the Commission's FAQ answers the question indirectly. In explaining Article 10, it lists child resistance, anti-tamper, anti-theft and anti-counterfeit features, hazard warnings and specific product characteristics among the functions a pack shape may need, and says the updated minimisation standard will take shape into account (FAQ, section VII, Q6). Until the end of 2029 the older essential requirements and EN 13428:2004 still apply, and the Commission is to request an updated standard by 12 February 2027 (FAQ, section VII, Q1 and Q3).

Recital 60 sets the test the safety features must pass: packaging should keep its weight and volume to the minimum needed to perform its functions, and marketing or consumer acceptance alone does not justify extra weight or volume. A tamper seal and a readable barcode are functions. A carton sized for shelf impact is not.

SPI analysis

For prescription medicines, the minimisation question is less whether to keep the carton than how small it can be while carrying the barcode, the tamper seal and the statutory labelling, and the answer belongs in the technical file before 2030. For non-prescription products outside Annex II, the safety features rarely apply, so a consumer health carton can be cut back or removed on its own merits, subject to labelling law. Sanofi's eSaSL digital security label, which replaces a physical label to fight falsification and illicit trafficking (Sanofi Eco-design factsheet, July 2026), shows one route to keep anti-counterfeit protection while taking material out.

## National EPR: the same pack, three national answers

EPR fees are national, and none of the official sources cited here exempts medicine packaging from them. What changes from country to country is which stream a pack belongs to, how it is rated and who collects the medicine left inside it (Exhibit 5).

### United Kingdom: household or non-household

The UK's packaging EPR regulations ([PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/)) charge disposal fees on household packaging only, so the classification is the opening cost question for a medicines producer. GOV.UK's guidance, published on 11 March 2024 and updated on 5 August 2025, treats primary and shipment packaging as household unless specific conditions are met, and says secondary and tertiary packaging must be classed as non-household. Its Example 9, a healthcare manufacturer selling through a wholesaler, shows how the line runs through a pharmacy (Exhibit 6).

The guidance asks for evidence such as binding agreements on onward supply, customer sales records, signed declarations or product specifications showing specialist use, kept for at least seven years. A vaccine maker supplying clinics can therefore move much of its primary packaging out of household fees, while an OTC brand selling through pharmacies and supermarkets cannot.

Fee modulation adds a second UK question. PackUK's modulation statement creates three medical reporting codes, green-medical, amber-medical and red-medical, and says medical packaging is not exempt from modulation because some of it is recyclable. Packaging that is red by virtue of a regulatory requirement is reported as amber-medical and pays the amber fee, while other red medical packaging pays the red factor of 1.2 in 2026-27, 1.6 in 2027-28 and 2.0 in 2028-29 ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)). Evidence supporting the recyclability assessment must be supplied for amber-medical and red-medical returns.

The Plastic Packaging Tax runs alongside. HMRC's guidance says plastic packaging for the immediate packaging of licensed human medicinal products is not subject to the tax, but must be counted when working out the 10-tonne registration threshold; the rate is GBP 228.82 per tonne ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)). The guidance does not distinguish prescription from non-prescription medicines, so the test is the MHRA licence, not the sales channel. It does not extend the relief to outer or transport packaging.

### France: Cyclamed and the household bin

France splits the medicine pack at the pharmacy counter. Cyclamed, the eco-organisation for unused human medicines, has operated since 1993 and is approved by the public authorities; it brings together community pharmacists, wholesaler-distributors and pharmaceutical companies (cyclamed.org). Its sorting guidance sends expired or unused medicines back to the pharmacy, with tablets and capsules left in their blisters, and sends the empty cardboard carton and paper leaflet to the household recycling bin. Used syringes and needles held by households are a separate healthcare waste stream.

Cyclamed reported on 26 June 2026 that 8,289 tonnes of unused medicines were collected in pharmacies in 2025 and that 7 in 10 French people now separate cardboard cartons and paper leaflets correctly before bringing the rest back (Exhibit 7). **SPI analysis:**  in France the carton and leaflet behave like any household paper packaging, while the blister travels with the medicine into a pharmacy take-back stream; a design that makes the carton easy to separate from the blister supports both streams.

### Spain and Germany

Spain's tax on non-reusable plastic packaging, EUR 0.45 per kg of non-recycled plastic, exempts packaging for medicines, medical devices, special medical foods, hospital infant formula and hazardous healthcare waste, provided the buyer gives a prior declaration of exempt use ([PR-ES-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-001/)). Using goods bought under the exemption for another purpose carries a penalty of 150% of the unpaid tax, with a minimum of EUR 1,000. Royal Decree 1055/2022 separately brings commercial and industrial packaging into EPR ([PR-ES-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-002/)), which reaches Layer C. In Germany, the VerpackDG has replaced the old packaging act since 12 August 2026 and requires registration and system participation for sales packaging, which covers medicine cartons ([PR-DE-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-001/)).

## Blister packs and inhalers

Blisters and inhalers are the two formats where pharma packaging departs furthest from consumer goods. A thermoformed blister combines a plastic film, often PVC, with an aluminium lid, and the PPWR's recyclability exemption for immediate packaging means no EU deadline forces it to change. Two of the four companies are changing it anyway.

Sanofi's PVC-free initiative, started in 2022, aims to reduce or where possible remove PVC from secondary and tertiary packaging, and its blister replacement work is at feasibility and pilot stage (Sanofi Eco-design factsheet, July 2026). Its Pre-Filled Safety Syringe is moving to a mono-material approach using PET/PETG with 50% chemically recycled content. Haleon works with the Circularity in Primary Pharmaceutical Packaging Accelerator (CiPPPA) on blister recycling, and says there is currently no commercially viable recycle-ready solution for its Theraflu sachets (Haleon Health Inclusivity and Sustainability Report 2025).

The inhaler question is a propellant question. Regulation (EU) 2024/573 on fluorinated greenhouse gases brings the metered dose inhaler sector into the HFC quota system. Recital 20 says the mechanism will guarantee full quota for the sector, matching its most recent market share, for 2025 to 2026, and that the sector reaches the full reduction rate of the other sectors only in 2030. Article 12(1)(f) adds labelling for aerosol dispensers containing fluorinated gases, including metered dose inhalers.

GSK's statement of 4 September 2026 says the Ventolin metered dose inhaler accounts for approximately 43% of the company's total carbon footprint, and that the HFA-152a version could cut greenhouse gas emissions by approximately 92% per inhaler. GSK's earlier phase III release of 22 October 2025 gave 45% of the footprint, as recorded in SPI's profile; the 2025 report and the September statement both give 43%. **SPI analysis:**  for an inhaler maker, the propellant switch is likely to move carbon totals more than any change to the canister, actuator or carton, and it is governed by F-gas and medicines law rather than by the PPWR.

## What the four companies report

Each company measures packaging in its own unit and boundary, so Exhibit 9 sets them side by side without adding, averaging or ranking them. All figures are as published by each company on the date shown.

In practice: GSK.

GSK has no plastic packaging target. Its Responsible Business 2025 report sets a 25% environmental impact reduction for products and packaging by 2030, and says 42% of the products in scope, which include its anti-infectives and respiratory portfolios, have reduction plans, with plans for all in-scope products due by the end of 2026. It established a 2022 baseline of 3.8 million tonnes of upstream waste and reports a 3% reduction, mainly through work with its aluminium packaging supply chain. Paper packaging is one of 12 naturally derived materials in its sourcing goal. SPI's profile, citing GSK's materials and waste page, adds recycled card, e-leaflets for vaccines and device take-back schemes in Denmark, Singapore and Switzerland.

In practice: Pfizer.

Pfizer's packaging page sets four aims with no numbers or dates, including eliminating and reducing packaging on existing products as regulations and technology allow (see Industry reaction). Its 2025 Impact Report, published on 2 June 2026, describes the 3R Circular Program for high-volume tertiary shipment materials and pilots reusing cold chain thermal blankets and lighter wooden pallets. The report's climate figures are 40.9% lower Scope 1 and 2 emissions than in 2019, against 46% by 2030, and 72% of suppliers by spend with science-based targets, against a 64% goal. The supplier figure counts suppliers of every kind and is not a packaging measure.

In practice: Sanofi.

Sanofi's July 2026 eco-design factsheet reports 61.5% of syringe vaccines blister-free in 2025, against 100% by 2030, and 60% of its 20 top-selling products following an eco-design approach. It expects about a 5% cut in packaging material and logistics consumption from size optimisation, and says almost half of leaflets in scope are covered by its eco-leaflet programme. In 2024, 98% of its 1.4 million shippers were described as biodegradable, with 78% in an EverGreen polystyrene grade that the company says degrades in landfill, which is not a recyclability measure. A pallet loop saved 2,078 pallets at Ambarès in 2023 and 2,780 at Tours in January to June 2024 against the same months of 2023. Its 2025 Sustainability Statement reports Scope 3 emissions 14% below 2019, against a 30% cut by 2030.

In practice: Haleon.

Haleon's 2025 ESG Databook, issued in March 2026, gives the only packaging tonnage of the four: 137 thousand tonnes in the year to 30 June 2025 including third-party manufacturing, of which 74 thousand tonnes paper and board and 56 thousand tonnes plastic (Exhibit 10). Its sustainability report says 80% of packaging was recycle-ready, against a restated 79% in 2024, and that WRAP has designated its mono-material HDPE toothpaste tubes recyclable since the end of 2023, with over 70 English local authorities accepting tubes at kerbside. Its 2030 goal is to make all packaging recyclable or reusable where safety, quality and regulations permit.

**SPI calculation:**  Haleon's plastic tonnage fell 9.7% year on year (62 to 56 thousand tonnes) while total packaging fell 4.2% (143 to 137 thousand tonnes), so plastic's share of its packaging fell from 43.4% to 40.9%. The virgin plastic figure of -9% against 2022 is a different measure and should not be read from these tonnes.

Exhibit 11 maps each company's disclosed actions onto the pack stack.

SPI analysis

The three prescription companies report most of their work in Layers B, C and D, where change does not touch the licensed immediate pack, with Sanofi's blister removal as the main Layer A exception. Haleon works in Layer A because its products, many of them toothpastes and vitamins rather than licensed medicines, sit in household streams where recyclability is tested by fees today.

## Industry reaction

> "Single-use packaging that is necessary for food safety, public health, or medical purposes can still be used."

***European Commission (DG ENV)** , [Facts about the new EU rules on packaging and packaging waste](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/facts-about-new-eu-rules-packaging-and-packaging-waste_en), consulted 22 October 2026*

The same page says the aim is not to ban single-use packaging outright but to offer greener alternatives, which is why medical uses are named alongside food safety rather than given a separate regime.

> "The development of plastic regulations could also significantly increase Sanofi's operating costs."

***Sanofi** , pharmaceutical company, [2025 Sustainability Statement](https://www.sanofi.com/assets/dotcom/content-app/publications/esg-reports/sanofi-sustainability-statement-2025.pdf), February 2026*

Sanofi lists the risk under raw material scarcity. Its exposure, on SPI's reading, is concentrated in Layers B and C, because the immediate pack is largely exempt.

> "Eliminate and reduce packaging materials as regulations allow and technology enables for existing products."

***Pfizer** , pharmaceutical company, [Green Journey: packaging](https://www.pfizer.com/purpose/workplace-responsibility/green-journey/packaging), consulted 22 October 2026*

The words as regulations allow point at medicines licensing, under which any change to an existing product's pack needs regulatory approval.

> "During 2026, we will revisit our 2030 goal to make all packaging recyclable or reusable"

***Haleon** , consumer health company, [Annual Report and Form 20-F 2025](https://www.haleon.com/content/dam/haleon/corporate/documents/investors/oar-2025/Annual-Report-and-Form-20-F-2025.pdf.downloadasset.pdf), March 2026*

The annual report ties the review to the latest industry developments, including the PPWR, and the sustainability report says the goal will be revisited in 2026 to align with the latest guidance.

## Scenarios: what UK classification and ratings do to a consumer health bill

The UK is where the household question and the medical codes turn into money soonest. SPI priced a 100-tonne UK household packaging mix shaped like Haleon's reported materials (54.7 tonnes paper and board, 41.4 tonnes plastic, 3.7 tonnes glass and 0.2 tonnes aluminium, scaled from the 2025 ESG Databook) at PackUK's Year 2 illustrative fees (Exhibit 12). The mix is an SPI assumption, not Haleon's UK tonnage, and every figure is in sterling.

The working is short. At amber, 54.7 x 210 + 41.4 x 455 + 3.7 x 205 + 0.2 x 270 = GBP 31,136.50, of which plastic is GBP 18,837, or 60.5%. Rating all plastic red at Year 2 rates adds 41.4 x 90 = GBP 3,726. At the 2027-28 factor applied to the amber rate, red plastic would cost GBP 728 per tonne, and the plastic line alone would be GBP 30,139.20.

SPI analysis

Two features of the UK system decide which row a medicines producer is in. The household test turns on the supply route, so a clinic-administered vaccine and a pharmacy-sold analgesic in identical packs land in different rows. The amber-medical code then caps the cost of a pack that is red only because regulation requires it, which rewards a producer that can document the regulatory requirement for each red component, such as a blister film. The gap between the base and stress rows, GBP 11,302.20 on 100 tonnes, is the value of that evidence by 2027-28 for packs that would otherwise be red.

Exhibit 13 sets out the pace each company needs on its own metric. Each row is in its own unit and is not compared with any other.

**SPI calculation:**  GSK's 3% reduction from 2022 to 2025 is about 1.0 point a year, against 1.4 points a year needed to 2030. Sanofi's 60% of its top 20 products is read by SPI as 12 products, which matches the 12 products the factsheet names. Haleon reports passing -10% by the end of 2025 on results to 30 September 2025, so its row starts from the -9% reported for the year to 30 June 2025.

## What leaders should do now

1. **Packaging and regulatory affairs leads, by 31 March 2027:**  sort every SKU into the four layers of Exhibit 3 and record, for each pack that relies on the medicinal exemption, whether it is immediate packaging or outer packaging needed for quality, with the quality reason written down.
2. **Packaging development teams, before 2027 artwork and line changes are frozen:**  model the minimisation case for each prescription carton against the barcode, tamper seal and labelling requirements, so the 2030 technical file shows why the remaining volume is needed.
3. **Logistics and cold chain leads, by 30 June 2027:**  inventory shippers, thermal blankets, pallets and shrink film against Article 24 (50% empty space) and Article 29 (40% reusable transport packaging), and confirm in writing which Article 29(4) exemptions, if any, each flow can rely on.
4. **UK compliance teams, before the 2027-28 data submissions:**  map each product's supply route against the household test, collect seven years of evidence for any non-household claim, and document every red medical component that qualifies for amber-medical reporting.
5. **Consumer health brand owners, by the end of 2026:**  treat OTC packs as household packaging in the UK and EU, check whether each product is a licensed medicine for the UK Plastic Packaging Tax relief, and plan recyclability work as if the medicinal exemptions do not apply to non-medicine lines such as toothpaste.
6. **Inhaler and device portfolio owners, through 2027:**  track the F-gas quota path to 2030 for propellants and keep propellant transitions in the same plan as canister, actuator and carton changes, since approvals and launches move together.
7. **Sustainability reporting teams, at the next annual report:**  report packaging targets by layer and in tonnes where possible, and state which exemption each excluded pack relies on, so readers do not compare unlike metrics.

## Questions for your board

- Which of our packs rely on the PPWR medicinal exemption, and can we show for each outer carton that it is needed to preserve quality?
- How much of our transport and cold chain packaging will meet the 50% empty-space cap and the 40% reuse target in 2030?
- In the UK, what share of our packaging is household, and how much red medical packaging could we report as amber-medical with evidence?
- Do our packaging targets cover the layers where the law bites, or only the layers we find easy to change?
- How do propellant or device changes rank against packaging changes in our carbon plan, and who owns both?
- Which of our consumer health products are licensed medicines, and which are cosmetics or food supplements under different rules?

## What to watch

- **31 Dec 2026:**  GSK's target date for environmental impact reduction plans covering all in-scope products (GSK Responsible Business 2025), and the end of the year in which Haleon has said it will revisit its 2030 packaging goal.
- **12 Feb 2027:**  the Commission's request for updated minimisation standards under Article 10(3) and its Annex V guidelines under Article 25(6) are due ([PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/), [PR-EU-008](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-008/)).
- **1 Apr 2027:**  PackUK's red modulation factor rises to 1.6 for 2027-28 ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)).
- **30 Jun 2027:**  the Commission's calculation rules for reuse targets under Article 30 are due ([PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/)).
- **2027:**  GSK expects launches of the lower-carbon Ventolin, if approved (GSK, 4 September 2026).
- **1 Jan 2028:**  Commission assessment of possible derogations under Article 7(12) ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/)).
- **1 Jan 2030:**  minimisation, empty-space and reuse duties start at the earliest; Sanofi's blister-free and top 20 targets and Haleon's 2030 goals fall due; the inhaler sector reaches the full HFC reduction rate.
- **1 Jan 2035:**  the Commission's review of the Article 6(11) recyclability exemptions is due (Commission FAQ, August 2026).

## Methodology

- **Data used:**  SPI Packaging Buyers Database profiles for GSK, Pfizer, Sanofi and Haleon (written 14 October 2026); SPI Regulation Tracker rules [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/), [PR-EU-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-003/), [PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/), [PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/), [PR-EU-008](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-008/), [PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/), [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/), [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/), [PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/), [PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/), [PR-DE-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-001/), [PR-ES-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-001/) and [PR-ES-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-002/); official EU, UK and French sources and company reports consulted on 22 October 2026.
- **Regulation text:**  article references rest on the recitals of Regulation (EU) 2025/40, Commission Notice C/2026/3084 and the Commission PPWR FAQ (August 2026), because SPI has not yet confirmed them against the operative article text in the Official Journal; the EUR-Lex summary is used for the recycled-content exceptions.
- **Counting rules:**  company figures are used as published, with their dates and boundaries; no figure is summed, averaged or ranked across companies; percentages are percentage points where stated.
- **Scenarios:**  the UK mix is an SPI assumption scaled from Haleon's 2025 material shares; fees are PackUK Year 2 illustrative rates in GBP; the stress case applies the 2027-28 factor to Year 2 amber rates, which is an assumption.
- **Framework:**  the four-layer pack stack is an SPI device for sorting SKUs, not a legal category.
- **Cut-off:**  22 October 2026.
- **Limitations:**  SPI has not yet confirmed packaging tonnage for GSK, Pfizer or Sanofi, the review date that applies to the medicinal recyclability exemption, how French sorting signage applies to medicine cartons, or how state EPR laws in the US treat drug packaging. This is analysis, not legal advice; check with counsel.

## Sources

1. EUR-Lex, Regulation (EU) 2025/40 on packaging and packaging waste, OJ L 22.1.2025, recitals 34, 38, 60, 84 and 95, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), consulted 2026-10-22.
2. EUR-Lex, Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (OJ C, 10.6.2026), sections 1 and 13, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202603084](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202603084), consulted 2026-10-22.
3. European Commission (DG ENV), Packaging and Packaging Waste Regulation (PPWR) Frequently Asked Questions, August 2026, KH-01-26-068-EN-N, [https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1](https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1), consulted 2026-10-22.
4. EUR-Lex, Summaries of EU legislation, Packaging and packaging waste (from 2026), last updated 26.9.2025, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=LEGISSUM:4806724](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=LEGISSUM:4806724), consulted 2026-10-22.
5. European Commission (DG ENV), Facts about the new EU rules on packaging and packaging waste, [https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/facts-about-new-eu-rules-packaging-and-packaging-waste_en](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/facts-about-new-eu-rules-packaging-and-packaging-waste_en), consulted 2026-10-22.
6. EUR-Lex, Commission Delegated Regulation (EU) 2016/161 on the safety features appearing on the packaging of medicinal products for human use, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0161](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0161), consulted 2026-10-22.
7. EUR-Lex, Regulation (EU) 2024/573 on fluorinated greenhouse gases, recital 20 and Article 12, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024R0573](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024R0573), consulted 2026-10-22.
8. GOV.UK, Extended producer responsibility for packaging: how to assess household and non-household packaging (published 11 March 2024, updated 5 August 2025), [https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-how-to-assess-household-and-non-household-packaging](https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-how-to-assess-household-and-non-household-packaging), consulted 2026-10-22.
9. GOV.UK (PackUK), Producer disposal fees modulation statement, [https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement](https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement), consulted 2026-10-22.
10. GOV.UK (PackUK), Year 2 illustrative waste disposal fees, EPR for packaging (published 16 December 2025, updated 19 December 2025), [https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging](https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging), consulted 2026-10-22.
11. GOV.UK (HMRC), Check which packaging is not subject to Plastic Packaging Tax, [https://www.gov.uk/guidance/check-which-plastic-packaging-is-exempt-from-plastic-packaging-tax](https://www.gov.uk/guidance/check-which-plastic-packaging-is-exempt-from-plastic-packaging-tax), consulted 2026-10-22.
12. Cyclamed, Les Français n'ont jamais aussi bien trié leurs médicaments non utilisés (26 June 2026), [https://www.cyclamed.org/cyclamed-les-francais-nont-jamais-aussi-bien-trie-leurs-medicaments-non-utilises/](https://www.cyclamed.org/cyclamed-les-francais-nont-jamais-aussi-bien-trie-leurs-medicaments-non-utilises/), consulted 2026-10-22.
13. Cyclamed, Comment trier ?, [https://www.cyclamed.org/comment-trier/](https://www.cyclamed.org/comment-trier/), consulted 2026-10-22.
14. GSK, Responsible Business 2025, [https://www.gsk.com/media/okghs41i/responsible-business-2025.pdf](https://www.gsk.com/media/okghs41i/responsible-business-2025.pdf), consulted 2026-10-22.
15. GSK, GSK files regulatory submission in the EU for a next-generation, lower-carbon version of Ventolin (salbutamol) metered dose inhaler (4 September 2026), [https://www.gsk.com/en-gb/media/media-statements/gsk-files-regulatory-submission-in-the-eu-for-a-next-generation-lower-carbon-version-of-ventolin-metered-dose-inhaler/](https://www.gsk.com/en-gb/media/media-statements/gsk-files-regulatory-submission-in-the-eu-for-a-next-generation-lower-carbon-version-of-ventolin-metered-dose-inhaler/), consulted 2026-10-22.
16. Pfizer, 2025 Impact Report (2 June 2026), [https://cdn.pfizer.com/pfizercom/Pfizer_2025_Impact_Report_02JUN2026.pdf](https://cdn.pfizer.com/pfizercom/Pfizer_2025_Impact_Report_02JUN2026.pdf), consulted 2026-10-22.
17. Pfizer, Green Journey: packaging, [https://www.pfizer.com/purpose/workplace-responsibility/green-journey/packaging](https://www.pfizer.com/purpose/workplace-responsibility/green-journey/packaging), consulted 2026-10-22.
18. Sanofi, Eco-design factsheet (July 2026), [https://www.sanofi.com/assets/dotcom/pages/docs/our-company/social-impact/responsible-business-values/esg-index/environment/factsheeteco-design2026-version-finale.pdf](https://www.sanofi.com/assets/dotcom/pages/docs/our-company/social-impact/responsible-business-values/esg-index/environment/factsheeteco-design2026-version-finale.pdf), consulted 2026-10-22.
19. Sanofi, 2025 Sustainability Statement, [https://www.sanofi.com/assets/dotcom/content-app/publications/esg-reports/sanofi-sustainability-statement-2025.pdf](https://www.sanofi.com/assets/dotcom/content-app/publications/esg-reports/sanofi-sustainability-statement-2025.pdf), consulted 2026-10-22.
20. Haleon, Health Inclusivity and Sustainability Report 2025, [https://www.haleon.com/content/dam/haleon/corporate/documents/investors/oar-2025/health-inclusivity-and-sustainability-report-2025-accessible.pdf](https://www.haleon.com/content/dam/haleon/corporate/documents/investors/oar-2025/health-inclusivity-and-sustainability-report-2025-accessible.pdf), consulted 2026-10-22.
21. Haleon, 2025 ESG Databook (issued March 2026), [https://www.haleon.com/content/dam/haleon/corporate/documents/our-impact/2025/2025-ESG-Databook.pdf](https://www.haleon.com/content/dam/haleon/corporate/documents/our-impact/2025/2025-ESG-Databook.pdf), consulted 2026-10-22.
22. Haleon, Annual Report and Form 20-F 2025, [https://www.haleon.com/content/dam/haleon/corporate/documents/investors/oar-2025/Annual-Report-and-Form-20-F-2025.pdf.downloadasset.pdf](https://www.haleon.com/content/dam/haleon/corporate/documents/investors/oar-2025/Annual-Report-and-Form-20-F-2025.pdf.downloadasset.pdf), consulted 2026-10-22.
23. SPI Regulation Tracker, rules PR-EU-001, PR-EU-003, PR-EU-004, PR-EU-006, PR-EU-008, PR-EU-009, PR-EU-010, PR-GB-001, PR-GB-002, PR-GB-003, PR-DE-001, PR-ES-001, PR-ES-002 and PR-FR-003, /data/packaging-regulation-tracker/european-union/, consulted 2026-10-22.
24. SPI Packaging Buyers Database, GSK, Pfizer, Sanofi and Haleon profiles (written 14 October 2026), /data/packaging-buyers-database/, consulted 2026-10-22.