The EU Packaging and Packaging Waste Regulation—Regulation (EU) 2025/40, commonly called the PPWR—establishes harmonized requirements for packaging and packaging waste throughout the European Union.
The PPWR applies to all packaging placed on the EU market, regardless of the packaging material or the sector in which it is used. It introduces requirements covering substances in packaging, recyclability, recycled plastic content, packaging minimization, labeling, reuse, extended producer responsibility, technical documentation and conformity assessment.
The Regulation entered into force on February 11, 2025, and has generally applied since August 12, 2026, although many operational requirements are being introduced progressively through 2028, 2029, 2030, 2038 and 2040.
Companies placing packaged products on the EU market should now treat PPWR as an active compliance obligation.
The PPWR replaces the former Packaging and Packaging Waste Directive 94/62/EC. Because it is a regulation rather than a directive, it applies directly across EU Member States and is intended to harmonize packaging requirements throughout the EU.
Its objectives include:
The PPWR does not completely eliminate national packaging obligations. Companies may still have country-specific registration, reporting, labeling, deposit-return and extended producer responsibility requirements.
The PPWR covers packaging of all materials and packaging waste from all sources. This includes packaging used in industrial, commercial, office, retail, service, household and other activities.
Packaging may include:
Packaging used with imported products can also be subject to the PPWR when the packaged product is placed on the EU market.
Obligations depend on the company’s role and activities. Relevant economic operators may include:
A company may be a manufacturer for conformity purposes and a producer for extended producer responsibility purposes. These roles must therefore be evaluated separately.
Non-EU companies selling packaged products into the EU should determine:
The combined concentration of the following substances generally must not exceed 100 mg/kg by weight in packaging or packaging components:
Applicable exemptions and derogations must be assessed before concluding compliance.
Since August 12, 2026, food-contact packaging must not be placed on the EU market when it contains per- and polyfluoroalkyl substances—PFAS—at or above the following limits:
Where total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user may need to provide evidence showing the fluorine content attributable to PFAS and to non-PFAS substances.
The detailed scope, measurement rules and exclusions in Article 5 of the PPWR must be considered when evaluating compliance.
Packaging must be designed for material recycling. Beginning in 2030, packaging must satisfy defined design-for-recycling criteria and meet at least the applicable recyclability performance grade.
The PPWR progressively strengthens these requirements:
Compliance will depend on delegated and implementing acts establishing design-for-recycling criteria, recycling-performance grades and assessment methodologies for different packaging categories.
Companies should already examine:
Beginning in 2030, certain plastic packaging must contain minimum percentages of post-consumer recycled plastic. Subject to applicable exclusions and transitional provisions, the targets include:
Plastic packaging category | 2030 target | 2040 target |
|---|---|---|
Contact-sensitive PET packaging | 30% | 50% |
Contact-sensitive plastic packaging other than PET | 10% | 25% |
Single-use plastic beverage bottles | 30% | 65% |
Other plastic packaging | 35% | 65% |
The applicable calculation and verification methods, packaging category and availability of implementing measures must be confirmed before applying these percentages to a specific packaging type.
By 2030, packaging must be designed so that its weight and volume are reduced to the minimum necessary to ensure functionality.
Acceptable performance considerations may include:
Packaging designed primarily to increase the product’s perceived volume—including unnecessary double walls, false bottoms or superfluous layers—may not satisfy the minimization requirements.
From 2030, grouped, transport and e-commerce packaging will generally also be subject to a maximum empty-space ratio of 50%, subject to the PPWR’s detailed rules.
The PPWR introduces harmonized packaging labels intended to facilitate consumer sorting and waste management.
These labeling requirements include:
Many harmonized labeling requirements are expected to apply from August 12, 2028, or later depending on the adoption and entry into force of the relevant implementing acts.
National requirements, such as France’s Triman logo and sorting information, may continue to require separate assessment.
The PPWR establishes reuse and refill requirements for certain packaging categories and sectors. Depending on the packaging and business model, obligations may apply to:
Targets, exemptions and calculation rules differ by packaging category. Companies should not apply a general reuse percentage without first determining the relevant PPWR provision.
Beginning in 2030, the PPWR restricts several single-use packaging formats, subject to specific conditions and exemptions.
Potentially affected formats include certain:
Each restriction must be assessed against the definitions, conditions and exemptions in Annex V of the PPWR.
Nearly all Enviropass PPWR projects initially lacked sufficient packaging information to complete the assessment.
The most common gaps involved missing packaging component weights, unidentified polymer or resin types, incomplete supplier composition data, or packaging components that had not been included in the product BOM.
This reinforces an important practical lesson: packaging data should be managed as part of product compliance data—not collected only when a PPWR or EPR deadline approaches.
See the full 2026 Product Environmental Compliance analysis.
Source: Enviropass Expertise Inc., 2026 Product Compliance Project Portfolio, January–August 2026.
Manufacturers must demonstrate that their packaging conforms to applicable PPWR sustainability and labeling requirements.
The conformity process may require:
Technical documentation should contain enough information to assess the packaging’s conformity. Depending on the applicable requirements, it may include:
Documentation must generally be retained for:
The EU Declaration of Conformity should be prepared for each packaging type and made available to market-surveillance authorities upon request.
A producer may need to register in each Member State where it first makes packaging or packaged products available.
Depending on the Member State and sales model, obligations may include:
A producer that is not established in a Member State where it makes packaging or packaged products available may need to appoint an authorized representative in that Member State. One representative may therefore not be sufficient for all EU countries.
EPR obligations should be assessed separately for every Member State where products are sold.
Date | Main milestone |
|---|---|
February 11, 2025 | PPWR entered into force |
August 12, 2026 | PPWR generally became applicable; food-contact packaging PFAS limits began applying |
August 12, 2028 or later | Harmonized material-composition and sorting labels, depending on implementing acts |
February 12, 2029 or later | Reusable-packaging labeling requirements |
January 1, 2029 | Deposit-return systems required for certain beverage containers, subject to exemptions |
January 1, 2030 | Major recyclability, recycled-content, minimization, empty-space, reuse and packaging-format requirements |
January 1, 2038 | Stricter recyclability-performance grade |
January 1, 2040 | Increased recycled-content and certain reuse targets |
The exact application date of a requirement may depend on delegated or implementing acts. Companies should monitor these measures rather than relying exclusively on the headline dates.
A practical PPWR compliance program should include:
Companies should distinguish between packaging conformity documentation and EPR records. Both may be required, but they demonstrate compliance with different obligations.
Enviropass can support manufacturers, importers and producers with:
Our assessments can cover individual packaging components or complete packaging systems used for products placed on the EU market.
Contact Enviropass to discuss your PPWR compliance requirements.
For requirements outside the European Union, consult our broader packaging compliance guide.
Yes. Regulation (EU) 2025/40 has generally applied since August 12, 2026. However, several major requirements—including harmonized labeling, recyclability grades, recycled-content targets, minimization and reuse targets—are being introduced progressively.
Yes. The PPWR applies to packaging placed on the EU market, including packaging associated with imported products.
Yes. PPWR is not limited to consumer or household packaging. Industrial, commercial, grouped, transport and e-commerce packaging may also be within its scope.
Manufacturers must draw up an EU Declaration of Conformity for packaging subject to the PPWR conformity requirements. The declaration must be supported by technical documentation demonstrating compliance.
No. Packaging conformity and EPR are related but separate obligations. A packaging type may require conformity documentation, while the producer may separately need to register, report packaging quantities and pay EPR fees in individual Member States.
Not automatically. The need for testing should be determined using a risk-based assessment considering the packaging materials, coatings, barriers, inks, manufacturing processes and available supplier documentation. Testing may be appropriate where documentary evidence is insufficient.
PPWR harmonizes many packaging requirements, but it does not eliminate every national obligation. Member States continue to administer EPR systems and may maintain certain national requirements where permitted.
No. The PPWR requires conformity assessment, technical documentation and an EU Declaration of Conformity, but it does not generally require packaging to bear the CE marking.
Written and technically reviewed by: Aurélien “Aury” Hathout, M.Env., VEA®, CEA
Last technical review: September 2026
This page was reviewed for technical accuracy using primary and authoritative European regulatory sources.
This page is based primarily on official European Union regulatory sources, including: