PPWR: An overview of the new EU Packaging and Packaging Waste Regulation

The PPWR establishes a new regulatory framework for packaging in the European Union. Its objectives are to significantly reduce packaging waste, improve recyclability, and strengthen the circular economy. The Regulation applies to all packaging, regardless of the material used, and, for the first time, covers the entire packaging life cycle, from design and manufacture to distribution and end-of-life management. The key requirements and their practical implications for businesses are outlined below.

1. Businesses In Scope

The PPWR covers all relevant economic operators along the packaging supply chain – from manufacturing through to delivery to the end consumer. Two roles are of particular importance for businesses. The manufacturer (Article 3(1), point (13), of Regulation (EU) 2025/40) is responsible for conformity assessment, technical documentation and packaging labelling – typically the company that has packaging or a packaged product designed or produced under its own name or trademark. The role of manufacturer must be distinguished from that of the producer (Article 3(1), point (15), of Regulation (EU) 2025/40), which refers to the manufacturer, importer or distributor that makes packaging available for the first time in an EU Member State and is subject to the Extended Producer Responsibility ("EPR") obligations in that Member State, including a requirement to register.

Clarifying a company's role under the PPWR at an early stage is essential, as it determines which specific obligations apply.

2. Requirements already in force

Not all requirements under the PPWR apply immediately. Many of the more complex obligations, including those relating to recyclability, minimum recycled content and packaging minimisation, will for example become applicable from 2030 onwards (see section 3 below). As of 12 August 2026, however, in particular the following obligations apply:

• Requirements for substances in packaging (Article 5 of Regulation (EU) 2025/40): All packaging must comply with concentration limits for heavy metals. The combined concentration of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg. These limits already applied under the previous legal framework (Art. 11(1) of Directive 94/62/EC) and have been carried over unchanged. New, however, are restrictions on per- and polyfluoroalkyl substances ("PFAS") in food-contact packaging: individual PFAS may not exceed 25 ppb, and the total concentration of all PFAS may not exceed 250 ppb. A further threshold of 50 ppm applies to PFAS, including polymeric PFAS. Where total fluorine exceeds 50 mg/kg, proof of the measured fluorine content must be provided upon request.
• Conformity Assessment (Articles 38 and 39 in conjunction with Annex VII of Regulation (EU) 2025/40): For the first time, the PPWR introduces a conformity assessment procedure for packaging – a concept previously known primarily from product safety legislation. Before placing packaging on the market, the manufacturer must carry out an internal production control, taking all necessary measures to ensure the packaging's conformity and prepare technical documentation that sets out the relevant requirements and enables assessments of the packaging’s conformity with applicable requirements. On this basis, an EU declaration of conformity must be drawn up. The manufacturer must retain the technical documentation and the declaration of conformity for five years from the date the packaging is placed on the market in the case of single-use packaging, and for ten years in the case of reusable packaging.
• Labelling (Article 15(5) and (6) of Regulation (EU) 2025/40): As of 12 August 2026, packaging must bear a type, batch or serial number for identification purposes. The manufacturer must also indicate on the packaging its name, registered trade name or trade mark, postal address and, where available, electronic contact details. Further labelling requirements – in particular relating to material composition – will not apply before 12 August 2028.
  

3. Outlook on Upcoming Changes

The more complex and impactful obligations will enter into force gradually. From 2027, the rules on Extended Producer Responsibility ("EPR") will apply. Under these rules, producers must register with a national producer register in each EU Member State where they first make packaging or packaged products available on the market or first unpack them, providing key information such as their name, brand name, address and commercial register number. Producers without an establishment in the relevant Member State must appoint an authorised representative for EPR purposes in that Member State (Article 45(3) of Regulation (EU) 2025/40). The authorised representative assumes certain of the producer's obligations under the PPWR.

From 12 February 2028, compostable packaging must meet the standard for industrial composting and, where required by the Member States, the home-composting standard. In addition, from 12 February 2028 at the earliest, such packaging must bear a clearly legible label indicating its material composition to help consumers sort correctly.

From 2030, packaging must be at least 70 % recyclable. Packaging that does not meet this threshold may continue to be placed on the market for a transitional period of up to five years. Also from 2030, mandatory minimum targets for recycled content from post-consumer plastic waste will apply, with further increases from 2040. In addition, packaging weight and volume must be reduced to the minimum necessary to ensure functionality. Packaging designed solely to increase perceived product volume – for example through false bottoms – will generally no longer be permitted.

Further requirements – including rules on the suitability of packaging for large-scale recycling and higher minimum recycled-content targets for plastic packaging – will follow by 2040.

4. Conclusion

As the PPWR is already in force and a number of obligations apply immediately, businesses need to take immediate action. As a first step, they should clarify their role under the Regulation – since this determines which requirements apply to them in practice.

Manufacturers, in particular, should verify compliance with the applicable substance restrictions and put in place the processes needed for conformity assessment – notably internal production control, technical documentation and the EU declaration of conformity. At the same time, the labelling requirements already in force must be observed. Producers should begin preparing for Extended Producer Responsibility (EPR) and the obligations it entails. All businesses that place packaging on the market should gain a clear picture of the materials they use and their composition, and engage with their suppliers accordingly.

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC