Packaging and Packaging Waste Regulation (PPWR)
With the introduction of EU regulation 2025/40, better known as the Packaging and Packaging Waste Regulation (PPWR), the regulations concerning packaging and packaging waste within the European Union are changing significantly. Since February 11, 2025, the regulation has been in force. With this, the European Union is taking the next step towards a circular and climate-neutral economy. For organizations, this means that packaging must now meet stricter requirements throughout the entire life cycle.
The PPWR applies to manufacturers of packaging, producers who place products on the market in packaging, importers, distributors, and service providers. All these parties must timely demonstrate whether their packaging meets the European requirements and where adjustments are needed.
Step-by-step implementation
Although the regulation already applies, most obligations are not yet directly applicable. The first requirements will take effect from 12 August 2026, unless specific provisions have other effective dates. Many parts of the PPWR will be further elaborated through implementing acts by the European Commission. These are expected to be published between 2025 and 2030. This gives organizations time to prepare, but also requires timely action.
Main substantive obligations
The PPWR sets clear requirements for the composition, design, recyclability, and reusability of packaging. Harmful substances must be limited as much as possible. For packaging that comes into contact with food, PFAS are actively being phased out.
In addition, every packaging must be recyclable in the future. From 2030 onwards, packaging must be designed in such a way that recycling is actually possible.
From 2035 onwards, packaging must also be able to be collected as a separate waste stream, without this affecting the quality of other waste streams.
For plastic packaging, additional obligations apply regarding the minimum content of recycled material. This affects, among other things, beverage bottles and food packaging.
At the same time, the European Commission is investigating how bio-based plastics and compostable packaging can be used responsibly. By 2028 at the latest, it will be assessed whether additional regulations are needed for this.
Unnecessary packaging is also being actively countered. From 2030 onwards, the weight and volume of packaging must be reduced to what is functionally necessary. Reusability is playing an increasingly important role in this. Packaging must be suitable for reuse without loss of product quality and must have clear labeling and QR codes with information about material use and waste separation.
Responsibilities of manufacturers, importers and producers
Manufacturers of products that are placed on the market packaged must be able to demonstrate that their packaging complies with the PPWR. They do this with a declaration of conformity and technical documentation, which is usually provided by the packaging supplier. It is important to request and assess this information in a timely manner.
Importers have a supervisory role. They may only place packaging on the market for which the correct documentation is available and must check whether labeling and packaging information are correct.
Service providers, such as logistics parties, must ensure that the conformity of packaging is maintained during storage, handling, and shipping.
Producers are parties who place packaging on the European market for the first time. This may involve producing packaging for third parties, placing packaged end products on the market, or importing packaging from outside the European Union.
These producers are subject to the strictest obligations of the PPWR. They must comply with sustainability requirements for design, material use, and labeling, and must register in the producer register of every EU Member State in which they are active. This enables supervision and enforcement.
An important part of this is the extended producer responsibility. Producers are responsible for the entire life cycle of the packaging, including the waste phase. This means that they contribute to the costs for collection, sorting, and recycling, and provide insight into how they responsibly handle packaging after use.
Packaging and e-commerce
The e-commerce sector must also take measures. For shipping packaging, empty space must be minimized as much as possible. Within a foreseeable period, this empty space may amount to a maximum of 50 percent of the packaging. This requires a revision of packaging concepts within online logistics.
Time for action
Although the first obligations will only take effect in 2026, it is wise to start taking steps now. Map out which packaging streams are relevant within your organization, assess existing packaging, and enter into discussions with suppliers about documentation and design choices. Actively follow the implementing acts of the European Commission and ensure that registration in the producer register is arranged on time.
This way you avoid surprises and are prepared for the upcoming obligations.
Requirement | Description | Year |
Substances in packaging | Requirements for the maximum amount of PFAS in food packaging. | 2026 |
Producer register | Register becomes available. | 2026 |
Biobased packaging | These packages can be separated without deteriorating the quality of other streams. | 2028 |
Labeling and QR codes | Packaging provided with informative labels and QR codes. | Labels 2028 QR codes 2029 |
Recyclable packaging & separability without loss of quality | All packaging must be recyclable, designed and separable without reducing the quality of other streams. | Recyclable 2030 Separable without loss of quality 2035 |
Recycled plastic content | Minimum percentage of recycled plastic in relevant packaging | 2030 (later increase in % follows in 2040) |
Minimization of packaging | Volume and weight of packaging must be limited to the minimum without losing its function. | 2030 |
Limiting empty space | Maximum 50% empty space in packaging for e-commerce. | 2030 |
Reuse in e-commerce | 40% of e-commerce packaging must be reusable. | 2030 |
