What is PPWR and Why It Matters
The EU Packaging and Packaging Waste Regulation (PPWR) – Regulation (EU) 2025/40 – replaces Directive 94/62/EC and becomes enforceable on August 12, 2026. If you manufacture, import, or distribute packaging in the EU market, non-compliance means potential fines, market bans, and reputational damage.
Unlike the old directive, PPWR is a regulation – it applies directly without national transposition. You cannot place packaging on the EU market after August 12, 2026 without meeting its requirements.
Who Must Comply
All economic operators placing packaging on the EU market:
- Manufacturers & converters – Must perform conformity assessments and issue declarations
- Importers – Must verify declarations exist before importing
- Distributors – Must ensure packaging carries required documentation and labels
- Brand owners & fillers – Share Extended Producer Responsibility obligations
If you rebrand or modify packaging, you assume manufacturer obligations.
Core Requirements by Category
1. Minimization & Design (Articles 5-7)
Effective August 12, 2026:
- Minimize materials and dimensions while maintaining functionality
- Eliminate unnecessary layers, double walls, and false bottoms
- Limit empty space to ≤50% for e-commerce, transport, and grouped packaging (2030 deadline)
- Design for easy component separation during recycling
Action required: Review all packaging designs against minimization criteria. Document why current dimensions and materials are necessary.
2. Recyclability Requirements (Article 8)
By 2030, your packaging must achieve minimum recyclability thresholds:
| Grade | Recyclability | Requirement |
|---|---|---|
| Grade A | ≥95% recyclable | Best EPR fee rates |
| Grade B | ≥80% recyclable | Mandatory by 2038 |
| Grade C | ≥70% recyclable | Minimum to sell in EU (2030) |
Recyclability is calculated by weight – the percentage of your packaging that can be recycled using available collection and recycling systems.
Action required: Calculate current recyclability rates for each packaging type. Grades below C require immediate redesign. The European Commission will publish detailed assessment methodologies by January 1, 2028.
3. Recycled Content Mandates (Article 9)
Plastic packaging must contain post-consumer recycled (PCR) content:
2030 Targets:
- 30% PCR for contact-sensitive PET (except beverage bottles)
- 10% PCR for other contact-sensitive plastic packaging
- 30% PCR for single-use plastic beverage bottles
- 35% PCR for all other plastic packaging
2040 Targets:
- 50% PCR for contact-sensitive PET
- 25% PCR for other contact-sensitive plastic packaging
- 65% PCR for single-use plastic beverage bottles
- 65% PCR for all other plastic packaging
Calculation method: Assess each plastic component comprising >5% of total packaging weight separately. Composite packaging requires component-by-component assessment.
Action required: Audit current PCR content. Secure supplier declarations and chain-of-custody certificates. For 2030 compliance, source compliant materials by 2029 at the latest.
4. Material Restrictions (Article 10)
Banned from August 12, 2026:
- Packaging containing >100 ppm PFAS (per- and polyfluoroalkyl substances)
- Single-use plastic condiment sachets
- Single-use plastic packaging for fresh produce <1.5 kg
- Specific single-use formats in hospitality (exceptions for sealed pre-packaged items)
Action required: Test packaging for PFAS content if unsure. Eliminate banned formats immediately.
5. Reuse & Refill Systems (Articles 24-26)
By 2030, mandatory reuse quotas apply to:
- Transport packaging (pallets, crates, containers)
- Certain B2B grouped packaging
- Specific beverage packaging formats
Member States may set additional reuse targets for other categories.
Action required: If selling in high-reuse categories, establish take-back systems or join collective reuse schemes by 2029.
Conformity Assessment & Documentation
Declaration of Conformity (Mandatory August 12, 2026)
For every packaging type, you must prepare an EU Declaration of Conformity stating compliance with Articles 5-12, 24, and 26.
Required contents:
- Unique identification number
- Manufacturer/importer name and address
- Packaging description and identification
- Reference to harmonized standards or implementing acts used
- Statement of conformity
- Date and authorized signatory
The European Commission will publish standardized declaration formats via implementing acts.
Technical Documentation (Keep 5-10 Years)
Supporting documentation must include:
- Design specifications (materials, weights, dimensions, drawings)
- Recyclability calculations and test reports
- PCR content evidence (supplier declarations, certificates, third-party verification)
- Design-for-recycling justification
- Minimization assessment
Retention periods:
- 5 years for single-use packaging (after placing on market)
- 10 years for reusable packaging
Market surveillance authorities can request documentation anytime during retention periods. Failure to provide complete records = penalties or market withdrawal.
Action required: Establish centralized, version-controlled documentation system with audit trails. Assign clear ownership for creating, updating, and archiving declarations.
Labelling Requirements
Phase 1: Digital Identifiers (2027)
Certain packaging must carry QR codes or similar digital identifiers linking to environmental information.
Phase 2: Harmonized EU Labels (Mandatory August 12, 2028)
All packaging must display:
- Material composition (standardized symbols and text)
- Collection instructions (where to dispose/return)
- Recyclability or reusability status (performance grade once methodology published)
Labels must use Commission-approved formats and symbols (expected late 2026).
Action required: Implement unique packaging ID system linking physical items to digital documentation. Prepare for label redesign in 2027-2028.
Implementation Timeline
| Date | Requirement |
|---|---|
| February 11, 2025 | PPWR entered into force |
| August 12, 2026 | Most provisions become mandatory:<br>- Declarations of conformity required<br>- Essential design requirements<br>- PFAS ban<br>- Single-use format bans |
| 2027 | Digital identifiers for certain packaging |
| January 1, 2028 | Design-for-recycling criteria published |
| August 12, 2028 | Harmonized EU labelling mandatory |
| 2030 | – Minimum 70% recyclability (Grade C)<br>- First PCR content targets<br>- 50% empty space limit<br>- Reuse quotas begin<br>- 5% waste reduction vs 2018 |
| 2035 | 10% waste reduction vs 2018 |
| 2038 | Minimum 80% recyclability (Grade B) |
| 2040 | – Increased PCR targets<br>- 15% waste reduction vs 2018 |
Compliance Roadmap: What to Do Now
Immediate (Q1-Q2 2026)
- Inventory all packaging – Create complete portfolio database with materials, weights, dimensions, suppliers
- Conduct gap analysis – Compare current packaging against August 2026 requirements (minimization, PFAS, banned formats)
- Eliminate non-compliant items – Remove PFAS-containing packaging and banned single-use formats
- Assign responsibilities – Designate who performs conformity assessments, creates declarations, maintains documentation
Short-term (Q3 2026-Q4 2027)
- Perform conformity assessments – Assess each packaging type against Articles 5-12
- Create declarations of conformity – Prepare declarations for all packaging (use Commission templates when published)
- Establish documentation system – Implement centralized storage with version control and 5-10 year retention
- Calculate recyclability – Assess current performance grades; redesign Grade D/E packaging
- Verify PCR content – Obtain supplier declarations for plastic packaging; identify gaps for 2030 targets
- Implement digital IDs – Add QR codes or tracking codes linking to compliance documentation (2027)
Medium-term (2028-2029)
- Redesign labels – Update all packaging with harmonized EU labels by August 12, 2028
- Source compliant materials – Secure suppliers meeting 2030 PCR targets; finalize contracts
- Optimize recyclability – Redesign packaging to reach Grade B (80%+) ahead of 2038 requirement
- Establish reuse systems – If applicable, join collective schemes or create take-back programs
Long-term (2030+)
- Meet 2030 targets – Achieve 70% recyclability, PCR content targets, 50% empty space limits
- Monitor 2038/2040 requirements – Plan gradual improvements toward Grade B recyclability and increased PCR
- Annual audits – Conduct internal compliance reviews; update documentation as designs change
Extended Producer Responsibility (EPR)
PPWR builds on existing national EPR schemes. You must:
- Register in every EU member state where you place packaging on the market
- Report annually on packaging volumes, materials, and weights
- Pay fees based on packaging placed on market – fees vary by material and recyclability grade
Higher performance grades (A/B) reduce EPR fees; lower grades face penalties.
Action required: Register with national EPR authorities before placing packaging in each country. Update registrations when entering new markets.
Enforcement & Penalties
Member states enforce PPWR through national laws. Potential consequences:
- Fines – Thousands to millions of euros depending on violation severity
- Market bans – Authorities can prohibit sale of non-compliant packaging
- Product recalls – Costs of recall, replacement, and disposal
- Criminal charges – Possible for serious/intentional violations or false declarations
- Reputational damage – Loss of customers and retail partnerships
Penalties escalate for repeat violations or knowing non-compliance.
Frequently Asked Questions
How do I prove PCR content?
Acceptable evidence includes:
- Supplier declarations with chain-of-custody certification
- Third-party verification reports
- Mass balance or credit-based accounting systems (if permitted by implementing acts)
Documentation must trace PCR content from waste source through recycling to your packaging.
What if my supplier changes?
You must obtain new declarations and technical documentation from the new supplier. Update your records immediately and verify the new packaging meets PPWR requirements before placing it on the market.
Can I use transition packaging after August 12, 2026?
No grace period exists for placing non-compliant packaging on the market after August 12, 2026. However, you may sell through existing stock that entered the market before the deadline (check national sell-through rules).
What about medical device packaging?
Medical device packaging can request partial exemptions from design-for-recycling requirements if recyclability compromises sterility or safety. Other PPWR requirements still apply.