On 11 February 2025, the EU Packaging and Packaging Waste Regulation (PPWR, (EU) 2025/40) officially entered into force. It fully replaces the Packaging and Packaging Waste Directive (94/62/EC) that had been in place for nearly 30 years, marking a fundamental shift from a “directive” to a “regulation” framework.
Unlike a directive, a regulation applies directly across all EU member states without the need for national transposition. The fragmented approach of dealing with each country's EPR system separately is now being replaced by a unified EU-level regulatory framework. Most substantive obligations will take effect from 12 August 2026.
PPWR Key Requirements at a Glance
I. Substance Restrictions: Heavy Metals + PFAS
Total concentration of lead, cadmium, mercury, and hexavalent chromium shall not exceed 100 mg/kg (effective 12 August 2026)
PFAS in food-contact packaging restricted from 12 August 2026
II. Recyclability Requirements
From 1 January 2030, all packaging must meet minimum recyclability performance grades A, B or C (below 70% recyclability = “technically non-recyclable” and prohibited from market)
From 1 January 2038, only grade A or B recyclable packaging will be permitted
III. Mandatory Recycled Content (PCR) Targets for Plastic Packaging
Packaging Type | 2030 Target | 2040 Target |
Single-use plastic beverage bottles | ≥30% | ≥65% |
PET contact-sensitive packaging | ≥30% | ≥50% |
Other plastic packaging | ≥35% | ≥65% |
IV. Packaging Minimisation
From 2030, packaging weight and volume must be reduced to the minimum necessary for functionality
Empty space ratio for transport packaging shall not exceed 50%
“False bottoms” and redundant layers prohibited
V. Labelling and Information
From 12 August 2028, packaging must bear harmonised pictogram labels indicating recyclability and sorting instructions
VI. Single-Use Plastic Bans
From 1 January 2030, certain single-use plastic packaging formats are prohibited, including packaging for fresh fruit and vegetables, food and beverage packaging for on-premises consumption, single-serving condiments, toiletry miniature packaging, and ultra-light plastic carrier bags with wall thickness below 15 microns
VII. Scope of Application
PPWR covers all packaging and packaging waste placed on the EU market, regardless of material (plastic, paper, glass, metal, wood, etc.) or origin. It applies to every economic operator that places packaging or packaged products on the EU market, regardless of whether they are established within the EU.
Implications for Manufacturers
For exporters, the most profound change is the shift from a “directive” to a “regulation”. Instead of navigating different national rules, businesses now face a single, unified EU-level framework.
Manufacturers are required to carry out conformity assessments, issue an EU Declaration of Conformity, and prepare technical documentation. All packaging placed on the EU market must be recyclable or reusable by 2030.
Key Deadlines: 12 August 2026 — core obligations apply; 1 January 2030 — recyclability grading and recycled content targets full effect.
Recommended actions:
Conduct a packaging compliance audit — assess current packaging against PPWR requirements
Optimise packaging design — ensure recyclability and minimise excess packaging
Establish supply chain traceability — to meet recycled content and substance restriction requirements
Prepare conformity documentation — technical files and EU Declaration of Conformity
Penalties under PPWR are significantly more severe than under the old directive — non-compliant businesses may face product bans, mandatory recalls, and even restrictions on commercial activities within the EU. Compliance is not optional — it is essential for market access.
