What is the PPWR?

What does PPWR stand for?

PPWR stands for the Packaging and Packaging Waste Regulation. Its full title is Regulation (EU) 2025/40 on packaging and packaging waste.

The PPWR replaces Directive 94/62/EC, commonly known as the Packaging and Packaging Waste Directive or PPWD. Unlike a directive, an EU regulation is directly applicable in all Member States without first having to be transposed into national law.

This creates a more harmonised framework for packaging across the EU single market. National authorities, enforcement systems and Extended Producer Responsibility schemes nevertheless continue to play an important role. Some practical requirements and penalties may therefore still differ between Member States.

The PPWR addresses the entire packaging lifecycle. It covers how packaging is designed, which materials and substances it contains, how much packaging is used, what information must be provided, and whether packaging can be reused or recycled.

Why was the PPWR introduced?

Packaging protects products, supports safe transport and provides information to consumers. At the same time, packaging consumes substantial quantities of raw materials and generates a significant amount of waste.

The PPWR aims to prevent packaging waste at source and support the European Union’s transition towards a circular economy. Rather than focusing only on waste management, the regulation introduces requirements that affect packaging decisions from the earliest design stage.

Its main objectives are to:

• Prevent unnecessary and excessive packaging

• Reduce the amount of packaging waste generated

• Make packaging recyclable

• Increase the use of post-consumer recycled material in plastic packaging

• Promote reusable packaging, reuse systems and refill solutions

• Restrict certain substances of concern in packaging

• Improve consumer information through harmonised labelling

• Strengthen Extended Producer Responsibility

• Create more consistent packaging rules across the EU market

Member States must reduce the amount of packaging waste generated per person by at least 5% by 2030, 10% by 2035 and 15% by 2040 compared with 2018 levels.

Which packaging is covered?

The PPWR applies to all packaging placed on the EU market, regardless of the material used or the sector in which the packaging is used.

This includes:

• Sales packaging supplied with an individual product

• Grouped packaging used to combine several sales units

• Transport packaging used for handling, storage and delivery

• E-commerce packaging sent directly to customers

• Food and beverage packaging

• Industrial and business-to-business packaging

• Plastic, paper, cardboard, glass, metal and wooden packaging

• Composite and multi-material packaging

• Reusable packaging and refill containers

• Empty packaging supplied to another organisation for filling

Specific provisions also apply to certain formats, including compostable packaging, tea and coffee system single-serve units, single-use plastic packaging and food contact packaging.

Whether a particular requirement applies can depend on the packaging material, format, intended use and position in the supply chain. Organisations should therefore assess packaging at the level of each packaging type rather than assuming that one conclusion applies to their entire portfolio.

Who does PPWR apply to?

PPWR obligations may apply to manufacturers, suppliers, importers, distributors, fulfilment service providers, final distributors and other economic operators.

Brand owners, retailers and organisations selling packaged goods online may also have obligations, depending on their activities and route to market.

The regulation follows the packaging and the transaction. It does not apply only according to where the parent company or brand owner is established. A business based outside the EU must address PPWR requirements when its packaging or packaged products are placed on the EU market.

An organisation may have different roles in different situations. For example, the same business could act as a manufacturer for its own-brand products, an importer when bringing packaged goods into the EU and a distributor when reselling products acquired from another EU business.

The applicable role should therefore be assessed for every:

• Legal entity

• EU Member State

• Product or packaging type

• Supplier relationship

• Sales channel

• Route to market

Correct role mapping is one of the first steps towards reliable PPWR compliance.

The main PPWR requirements

PPWR changes more than packaging design. It connects packaging materials and formats with technical documentation, supplier evidence, data management, reporting and internal governance.

The applicable obligations do not all begin on the same date. Some requirements apply from 12 August 2026, while many design and performance obligations are introduced from 2030, 2035 or later.

Recyclable packaging

From 2030, packaging placed on the EU market must comply with design-for-recycling requirements.

Packaging will be assessed against recyclability performance grades. Packaging that does not meet the applicable performance threshold may no longer be placed on the EU market.

The detailed design-for-recycling criteria and assessment methods will be further developed through delegated and implementing acts. These measures will take account of factors such as:

• Material composition

• Coatings and barriers

• Labels, sleeves and adhesives

• Closures and other components

• Inks and printing

• Ease of separation

• Compatibility with collection, sorting and recycling processes

From 2035, recyclability will also depend on whether packaging is recycled at scale. This connects theoretical packaging design with the performance and availability of actual collection, sorting and recycling infrastructure.

Recycled content in plastic packaging

From 2030, certain plastic packaging must contain minimum percentages of post-consumer recycled content.

There is no single recycled-content percentage that applies to every type of plastic packaging. The applicable threshold depends on the packaging category and intended use.

Different requirements apply to categories including:

• Contact-sensitive packaging with PET as its major component

• Other contact-sensitive plastic packaging

• Single-use plastic beverage bottles

• Other plastic packaging

Higher targets generally apply from 2040. The regulation also contains exclusions and specific conditions for certain packaging and applications.

Organisations must classify their plastic packaging correctly before determining which recycled-content requirement applies. Reliable information about material composition, recycled material and supplier evidence will be essential.

Packaging minimisation

From 2030, packaging must be designed so that its weight and volume are reduced to the minimum necessary while maintaining its functionality.

The assessment can consider functions such as:

• Product protection

• Manufacturing and filling processes

• Logistics and transport

• Hygiene and safety

• Legal information requirements

• Product presentation and marketing

• Recyclability and recycled content

• Reuse and refill

Packaging features intended only to increase the perceived volume of a product, such as unnecessary double walls, false bottoms or excessive layers, may conflict with these requirements.

The PPWR also limits excessive empty space in grouped, transport and e-commerce packaging. Businesses will need to assess both the packaging structure and the way products are packed for transport or delivery.

Reuse and refill

The PPWR introduces reuse and refill requirements for selected packaging formats and sectors.

These requirements can affect areas such as:

• Transport packaging

• Grouped packaging

• Beverage packaging

• Takeaway food and drinks

• Distribution between business sites

• Certain e-commerce and logistics activities

The applicable target is not identical for every packaging type. Requirements can also depend on the format, distribution model, business size and availability of an exemption.

Reusable packaging requires more than a design that can technically be used several times. A functioning reuse system may need processes for:

• Collection and return

• Transport and reverse logistics

• Inspection

• Cleaning

• Repair

• Repeated circulation

• Record keeping

Businesses should assess whether their current operating model can support these activities in practice.

Labelling and consumer information

PPWR introduces harmonised labelling requirements to help consumers identify packaging materials and dispose of packaging correctly.

Certain reusable packaging will also need to provide information about its reusability and the relevant reuse system. Digital data carriers may be used for some information.

These requirements are introduced according to specific timelines and depend partly on future implementing measures. Organisations should avoid assuming that every new label becomes mandatory on the PPWR’s general application date.

Packaging artwork and labelling processes should nevertheless be included in the organisation’s implementation roadmap.

Compostable and bio-based packaging

The regulation contains specific requirements for certain packaging formats that must be compostable under defined conditions.

Compostability does not automatically make packaging compliant, recyclable or exempt from other PPWR requirements. Claims about compostability must be supported and must not mislead consumers.

Bio-based and recycled materials must also be treated as separate concepts. Bio-based plastic does not necessarily contain recycled material and is not automatically recyclable or compostable.

Each material claim and compliance requirement should therefore be assessed separately.

PFAS restrictions in food contact packaging

From 12 August 2026, food contact packaging may not be placed on the EU market when it contains per- and polyfluorinated alkyl substances, known as PFAS, at or above the following limits:

• 25 ppb for any individual PFAS measured through targeted analysis

• 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis

• 50 ppm for PFAS, including polymeric PFAS

If total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user must be able to provide evidence of the amount of fluorine measured as either PFAS or non-PFAS upon request.

The restrictions apply to food contact packaging and are subject to the measurement and technical conditions set out in Article 5 of the PPWR.

Businesses should confirm whether affected packaging has been assessed using appropriate supplier documentation, declarations, analytical methods or test results.

How is PPWR compliance demonstrated?

Manufacturers must demonstrate that packaging complies with the applicable PPWR requirements before placing it on the EU market.

This process generally includes:

1. Identifying the applicable requirements
   Determine which PPWR obligations apply to the packaging type, material, use and market role.

2. Completing the conformity assessment
   Follow the applicable conformity-assessment procedure set out in the regulation.

3. Preparing technical documentation
   Compile the information needed to demonstrate compliance in line with Annex VII.

4. Drawing up the EU declaration of conformity
   Prepare the declaration according to Article 39 and the model structure in Annex VIII.

5. Maintaining compliance
   Keep the documentation current and reassess compliance when packaging, materials, suppliers or production processes change.

The technical documentation may need to contain information about the packaging design, manufacturing process, materials, test results, assessments and applicable requirements.

The EU declaration of conformity confirms that compliance has been demonstrated. The manufacturer is responsible for drawing up and maintaining this declaration. It must be available in the language or languages required by the Member State in which the packaging is placed on the market.

The technical documentation and declaration must be retained for the period specified by the PPWR. The applicable period differs for single-use and reusable packaging.

Penalties and enforcement

Member States must establish effective, proportionate and dissuasive penalties for infringements of the PPWR.

Because enforcement and penalty frameworks are implemented nationally, the precise consequences may differ between Member States. Consequences may include administrative sanctions as well as measures affecting whether packaging can continue to be placed on the market.

National market-surveillance authorities can request compliance evidence and take action where packaging does not meet the applicable requirements.

Businesses operating in multiple EU countries should therefore monitor both the PPWR itself and relevant national enforcement arrangements.