The European Union's Packaging and Packaging Waste Regulation (PPWR), officially known as Regulation (EU) 2025/40, represents a significant legislative shift aimed at addressing the escalating environmental impact of packaging waste across member states. This comprehensive regulation replaces the previous EU Packaging Directive 94/62/EC, transitioning from a directive to a regulation to ensure uniform application across the EU.
1. Objectives
The rules aim to minimize the quantities of packaging and waste generated while lowering the use of primary raw materials and fostering the transition to a circular, sustainable and competitive economy.
The core objectives of the PPWR are to:
Reduce packaging waste, promote the use of recyclable and reusable materials and drive the application of sustainable materials.
Achieve specific waste reduction targets: a 5% reduction by 2030, 10% by 2035, and 15% by 2040.
Restrict single-use packaging and promote reusable alternatives.
The regulation entered into force on February 11, 2025, and will be fully implemented starting August 12, 2026, unless specified otherwise.
2. Scope and Definitions
The PPWR applies to all packaging and packaging waste placed on the EU market, regardless of the material used or its origin (e.g., industrial, retail, distribution, office, services, or households).
The regulation defines packaging based on its function. That is, the packaging is intended to be used for the containment, protection, handling, delivery or presentation of products, provided it is not an integral part of the product itself.
Examples of what is NOT packaging:
IV bags and syringes (integral parts of medical devices).
Empty beverage cups sold directly to consumers for personal use.
Garbage bags and dog waste bags.
Examples of what IS packaging:
Beverage cups filled at the point of sale (service packaging).
Dust bags for shoes or clothing (if used for transport and display).
Plant pots used only for sale and transport (but not those used during the nursery production process).
3. Key Stakeholders and Responsibilities
The PPWR clearly defines the roles and responsibilities of key economic operators in the supply chain.
Stakeholder | Core Definition | Main Responsibilities and Characteristics | Special Notes |
Manufacturer | Natural or legal person who designs or manufactures packaging/packaged products under their own name or trademark | Core Responsibility: Carry out conformity assessment, draw out the technical documentation and an EU Declaration of Conformity. Uniqueness: Each packaging corresponds to only one manufacturer in the EU supply chain. | Trademark Principle: If packaging bears a specific trademark, the trademark owner is generally considered the manufacturer. Exception: If the brand owner is a micro-enterprise in the same Member State as the supplier, the supplier may be deemed the manufacturer. |
Producer | The operator who first makes the packaging available within the territory of a Member State where the packaging is expected to become waste. | Waste Management: Primarily fulfills Extended Producer Responsibility (EPR) and bears waste management costs. Territoriality: Responsibilities are specific to a particular Member State. | Multiplicity: The same packaging may correspond to multiple producers across different Member States. |
Importer | An EU-registered legal entity that places non-EU packaging on the EU market. | Compliance Gatekeeper: Ensures products comply with EU regulations. Responsible Entity: Bears accountable compliance responsibility within the EU. | Legal Status: Branches without independent legal status cannot act as importers. Non-EU Enterprises: Must establish a subsidiary or appoint an authorized representative. |
4. Packaging Requirements
The PPWR introduces stringent requirements across various aspects of packaging design, material composition, and end-of-life management.
4.1 Substance Restrictions (Article 5)
Starting August 12, 2026, packaging that does not meet substance requirements cannot be placed on the EU market.
Substances of Concern: The concentration of substances of concern in packaging or its components must be minimized. A detailed list of these substances is expected by December 31, 2026.
Heavy Metals Limit: The sum of concentration levels of lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr(VI)) in packaging or its components must not exceed 100 mg/kg. This is in addition to restrictions under REACH Annex XVII and, where applicable, Food Contact Materials Regulation (EC) No 1935/2004.
PFAS Restrictions: The use of Per- and Polyfluoroalkyl Substances (PFAS) in food contact packaging is strictly prohibited, with specific limits:
◦ Each individual PFAS < 25 ppb.
◦ Sum of PFAS (excluding polymeric PFAS) < 250 ppb.
◦ Sum of PFAS (including polymeric PFAS) < 50 ppm. If total fluorine > 50 ppm, technical documentation proving the PFAS or non-PFAS content is required.
4.2 Recyclability (Article 6)
From August 12, 2026, all packaging placed on the EU market must be recyclable. The regulation emphasizes the principle of "Design for Recycling" (DfR), which is measured as the assessment of recyclability per unit, in terms of weighting. Packaging recyclability shall be expressed in the performance grades A, B or C as follows:
Grade A: Recyclability ≥ 95%.
Grade B: Recyclability 80-94%.
Grade C: Recyclability 70-79%.
Technically Non-recyclable: ≤ 70%
By January 1, 2030, only packaging graded C or above will be permitted. By January 1, 2038, this requirement will be elevated to only allow Grade A and B packaging.
Furthermore, EPR fees will be eco-modulated based on these DfR grades, meaning optimized packaging structures can lower export costs.
4.3 Recycled Content in Plastic Packaging (Article 7)
Starting January 1, 2030, any plastic part of packaging placed on the market must contain a minimum percentage of Post-Consumer Recycled (PCR) plastic waste.
2030 Targets:
Contact-sensitive packaging made from polyethylene terephthalate (PET) as the major component: ≥ 30% (excluding single-use plastic beverage bottles).
Contact-sensitive packaging made from non-PET plastic materials: ≥ 10% (excluding single-use plastic beverage bottles).
Single-use plastic beverage bottles: ≥ 30%.
Other packaging: ≥ 35%.
2040 Targets:
Contact-sensitive packaging with PET as the major component: ≥ 50%.
Contact-sensitive packaging made from non-PET plastic materials: ≥ 25%.
Single-use plastic beverage bottles: ≥ 65%.
Other packaging: ≥ 65%.
By 31 December 2026, the Commission shall adopt implementing acts establishing the methodology for the calculation and verification of the PCR percentage.
4.4 Biobased Feedstock in Plastic Packaging (Article 8)
By February 12, 2028, the Commission will review the technological development and environmental performance of bio-based plastic packaging.
Based on the review, The Commission shall prposal a legislation to establish sustainability requirements for bio-based materials and set quantitative targets to gradually increase their substitution share in various plastic packaging.
For food contact packaging, if the safety assessment of recycled plastics cannot be met, bio-based raw materials may be permitted to replace part of the recycled material quota.
4.5 Compostable Packaging (Article 9)
From February 12, 2028, specific packaging items (Article 3(1), point(1)(f) ), such as permeable tea, coffee bag and sticky labels attached to fruits and vegetables, must meet industrial composting standards. Member States may also require additional compliance with home composting standards.
Additionally, Member States with well-developed bio-waste collection schemes and waste treatment infrastructure may mandate that specific packaging, such as lightweight plastic carrier bags like non-permeable coffee/tea single-serve unit, be compostable when first placed on their market.
4.6 Packaging Minimization (Article 10 & 24)
From January 1, 2030, packaging must be designed to reduce its weight and volume to the minimum necessary to ensure functionality, considering shape and material. Over-packaging intended solely to increase perceived volume (e.g., double walls, false bottoms) is prohibited.
From January 1, 2030, grouped packaging, transport packaging, or e-commerce packaging must ensure that the maximum empty space ratio, expressed as a percentage, is 50 %.
4.7 Reusable Packaging (Article 11 & 29)
From August 12, 2026, manufacturers must prove that packaging claimed or designed to be reusable meets specific requirements.
Design and Circulation (Article 11): Packaging must be designed for multiple reuses under normal conditions, supporting emptying, loading, refilling, cleaning, repair, and refurbishment without damage. At the end of its life, it must meet recyclability requirements.
Transport and E-commerce Targets (Article 29): By January 1, 2030, at least 40% of transport and e-commerce packaging must be reusable. This target increases to at least 70% by 2040.
4.8 Labeling Requirements (Article 12)
4.8.1 Harmonized Labeling
From August 12, 2028 (or 24 months after the implementing act), packaging must bear a harmonized label indicating its material composition basd on pictograms. Compostable packaging must be labeled as such.
Digital labeling is required for packaging containing substances of concern.
In addition to the harmonised label, economic operators may place a QR code or other type of digital data carrier on the packaging that contains packaging component information to facilitate consumer sorting.
This obligation does not apply to e-commerce packaging which is subject to a deposit and return system.
4.8.2 Deposit Return Systems (DRS)
From August 12, 2028, packaging subject to DRS must bear national labels and harmonized color DRS labels as required by Member States.
4.8.3 Reusable Packaging Labeling
From February 12, 2029 (or 30 months after the implementing act), reusable packaging must be labeled to inform users of its reusability, potentially supplemented by QR codes providing information on reuse systems and collection points.
5. Conformity Assessment
From August 12, 2026, manufacturers must carry out conformity assessment of packaging as regards the requirements set out in Part 4 (Article 5-12).
The manufacturer shall draw up a written declaration of conformity (format provided in Annex VIII) for each packaging type and keep record for 5 years after single-use packaging has been placed on the market, and 10 years after reusable packaging has been placed on the market.
They should also draw up the technical documentation that includes:
Packaging description and its intended use;
Conceptual design, manufacturing drawings and materials of compounds;
Descriptions and explanations for such drawings;
List of applicable standards, technical specifications;
Qualitative descriptions of how the assessments provided for in Articles 6, 10 and 11 have been carried out;
Test reports.
6. Extended Producer Responsibility (EPR)
The EPR system is a cornerstone of the PPWR, holding producers accountable for the entire lifecycle of their packaging.
6.1 Definition
EPR is an environmental management system where the "Producer" (the operator first providing the packaging in a Member State) is responsible for the collection, recycling, and disposal of packaging waste.
6.2 Core Obligations for Producers
Producers must fulfill three primary duties in each Member State where they operate:
Registration: Register with the competent authority in the target Member State and obtain a unique registration number.
Reporting: Regularly (quarterly or annually) declare the material types and weights of packaging placed on that specific market.
Payment: Pay waste management fees. In the future, these fees will be eco-modulated, meaning they will be adjusted based on the packaging's recyclability (DfR) grade—higher recyclability leads to lower fees.
Note: Since the EU EPR framework is implemented individually by each member state, requirements for producer identification, registration, data reporting, and fee payments can vary significantly. Therefore, companies should tailor their EPR registration to the specific regulations of their target export markets.
