PPWR in plain terms
The Packaging and Packaging Waste Regulation (PPWR), formally Regulation (EU) 2025/40 on packaging and packaging waste, is the EU’s single rulebook for the whole life-cycle of packaging. It sets environmental sustainability and labelling requirements that packaging must meet to be placed on the market, and it lays down extended producer responsibility, packaging waste prevention, re-use and refill, and the collection and recycling of packaging waste (Art. 1(1)). Because it is a regulation, it applies directly in every Member State from 12 August 2026 without national transposition, and it replaces the Packaging and Packaging Waste Directive 94/62/EC from that date (Art. 70 and Art. 71).
The regulation’s core rule is simple: packaging may only be placed on the market if it complies (Art. 4(1)). What “complies” means is built up in stages. Substance limits and the general obligations of economic operators apply from 12 August 2026; harmonised labelling follows from 12 August 2028; and the design requirements on recyclability, recycled content, minimisation, format restrictions and re-use targets apply from 1 January 2030, in several cases only 24 or 36 months after the Commission has adopted the supporting delegated and implementing acts if that is later.
Official text Read the regulation on EUR-Lex: Regulation (EU) 2025/40 (CELEX 32025R0040). The Commission’s guidance document C/2026/3084 interprets selected provisions; Delegated Decision (EU) 2026/429 exempts pallet wrappings and straps from the 100 % re-use requirements.
Scope
The regulation applies to all packaging, regardless of the material used, and to all packaging waste, whether it is used in or comes from industry, other manufacturing, retail or distribution, offices, services or households (Art. 2(1)). Packaging is any item an economic operator uses to contain, protect, handle, deliver or present products to another operator or an end user. The definition expressly includes items that are necessary to contain, support or preserve a product without being an integral part of it, their components and ancillary elements, service packaging designed to be filled at the point of sale, disposable items sold and filled at the point of sale, permeable tea and coffee bags, and single-serve beverage units used in a machine (Art. 3(1), point (1)); Annex I gives an indicative list of what is and is not packaging. The regulation distinguishes sales, grouped, transport and e-commerce packaging, and single-use from reusable packaging (Art. 3(1), points (5) to (8) and (27) to (28)).
The regulation sits alongside, not above, the rules on the packed product: it applies without prejudice to Union requirements on safety, quality, health protection and hygiene of packed products and to transport requirements, and where it conflicts with Directive 2008/68/EC on the inland transport of dangerous goods, that directive prevails (Art. 2(2)). Immediate and outer packaging of medicinal products, contact-sensitive packaging of medical devices and in vitro diagnostics, infant-food packaging and dangerous-goods packaging are carved out of the recyclability and recycled-content requirements (Art. 6(11) and Art. 7(4)).
Duties fall on economic operators: the manufacturer, supplier, importer, distributor, authorised representative, final distributor and fulfilment service provider (Art. 3(1), point (12)). The manufacturer is whoever manufactures packaging or a packaged product, or has either made under its own name or trademark; a micro-enterprise brand owner whose packaging supplier is in the same Member State is not the manufacturer, the supplier is (Art. 3(1), point (13)). Importers and distributors that sell under their own brand or modify packaging in a way that could affect compliance take on the manufacturer’s obligations (Art. 21). A separate role, the producer, carries extended producer responsibility: it is the manufacturer, importer or distributor that first makes packaging or packaged products available in a Member State, sells them directly to end users in another Member State, or unpacks packaged products without being an end user (Art. 3(1), point (15)). Online platforms and fulfilment service providers must check that the producers they serve are registered (Art. 45(4) to (8)).
What you must do
Substances in packaging
Packaging must be manufactured so that the presence and concentration of substances of concern are minimised (Art. 5(1)). The sum of lead, cadmium, mercury and hexavalent chromium in packaging or its components may not exceed 100 mg/kg (Art. 5(4)). From 12 August 2026, food-contact packaging may not be placed on the market with PFAS at or above 25 ppb for any PFAS, 250 ppb for the sum of PFAS or 50 ppm including polymeric PFAS (Art. 5(5)). Compliance is shown in the Annex VII technical documentation (Art. 5(6)). By 31 December 2026 the Commission, assisted by ECHA, must report on substances of concern in packaging (Art. 5(2)).
Recyclability, recycled content and compostability
All packaging must be recyclable: designed for material recycling and, when it becomes waste, collected separately, sorted and recycled at scale (Art. 6(1) and (2)). The manufacturer assesses recyclability against design-for-recycling criteria that the Commission must adopt by 1 January 2028 and grades it A, B or C (Art. 6(3) and (4)). From 1 January 2030, or 24 months after those delegated acts if later, packaging outside grades A to C may not be placed on the market; from 1 January 2038 only grades A and B remain (Art. 6(3)). The recycled-at-scale condition applies from 1 January 2035 or five years after the Commission’s methodology (Art. 6(2) and (5)). Innovative packaging may be marketed for up to five years without meeting the criteria, after notification to the competent authority (Art. 6(10)). Producers’ extended producer responsibility fees are modulated by recyclability grade 18 months after the criteria and methodology are in force (Art. 6(8)).
From 1 January 2030, or three years after the Commission’s calculation methodology if later, every plastic part of packaging must contain minimum recycled content from post-consumer plastic waste, calculated per manufacturing plant and year: 30 % for contact-sensitive PET, 10 % for other contact-sensitive plastics, 30 % for single-use plastic beverage bottles and 35 % for other plastic packaging, rising to 50 %, 25 %, 65 % and 65 % from 1 January 2040 (Art. 7(1) and (2)). Recycled content must come from waste collected and recycled in the Union or under equivalent standards (Art. 7(3)); medicinal, medical, compostable, dangerous-goods and infant-food packaging and plastic parts under 5 % of the packaging weight are exempt (Art. 7(4) and (5)). By 12 February 2028, tea, coffee and beverage bags and sticky fruit labels must be compostable, and other biodegradable packaging must be designed for material recycling (Art. 9(1) and (3)).
Minimisation and reusable packaging
By 1 January 2030 the manufacturer or importer must ensure that packaging weight and volume are reduced to the minimum necessary for functionality, assessed against the Annex IV performance criteria, and packaging whose only purpose is to increase perceived volume (double walls, false bottoms, unnecessary layers) may not be placed on the market unless a protected design, trademark or geographical indication justifies it (Art. 10(1) and (2)). Packaging placed on the market from 11 February 2025 is reusable only if it meets all nine criteria of Article 11(1), including being designed for as many rotations as possible, being reconditionable per Annex VI and being recyclable at end of life; the Commission sets minimum rotation numbers by 12 February 2027 (Art. 11).
Labelling and claims
From 12 August 2028, or 24 months after the Commission’s implementing acts if later, packaging must carry a harmonised pictogram label on its material composition to help consumers sort it; transport packaging other than e-commerce packaging and deposit-return packaging are excluded, and compostable packaging must be marked as not home-compostable and not to be discarded in nature (Art. 12(1)). Reusable packaging placed on the market from 12 February 2029 must be labelled as reusable with a QR code or other data carrier giving re-use system and collection information (Art. 12(2)). Recycled-content and biobased-content labels must follow the harmonised specification (Art. 12(4)). Labels must be visible, legible and firm, in a language the Member State determines, and the information must also be available before online purchase (Art. 12(5)). No label, mark, symbol or inscription may mislead consumers about sustainability, other packaging characteristics or waste management options (Art. 12(8)), and environmental claims about regulated packaging properties are allowed only where the packaging exceeds the minimum requirements (Art. 14).
The general obligations of economic operators
Manufacturers place on the market only conforming packaging, run the Annex VII internal production control, draw up the technical documentation and the EU declaration of conformity per packaging type, keep both for 5 years for single-use and 10 years for reusable packaging, keep series production in conformity, mark the packaging with an identifier and their name and contact details, take corrective action and inform the authority when packaging does not conform, and hand over documentation within 10 days of a reasoned request (Art. 15). Suppliers give manufacturers the documentation they need (Art. 16). Authorised representatives act under a mandate that must at least cover keeping documents and cooperating with authorities (Art. 17). Importers verify the manufacturer’s work before placing packaging on the market, add their own identification, guard conformity in storage and transport, take corrective action and keep the declaration of conformity available for 5 or 10 years (Art. 18). Distributors verify producer registration, labelling and identification, hold back non-conforming packaging and see that corrective action is taken (Art. 19). Fulfilment service providers keep warehousing, handling and dispatching from jeopardising compliance (Art. 20). Every operator must be able to name its suppliers and customers for 5 or 10 years (Art. 22).
Reducing packaging: empty space, format bans, re-use and refill
Operators that fill grouped, transport or e-commerce packaging must keep the empty-space ratio at or below 50 % from 1 January 2030, or three years after the Commission’s methodology if later, and filling materials such as air cushions and chips count as empty space; operators that fill sales packaging must reduce empty space to the minimum by 12 February 2028 (Art. 24). From 1 January 2030 the formats in Annex V may not be placed on the market: single-use plastic grouped packaging, single-use plastic packaging for less than 1,5 kg of fresh fruit and vegetables, single-use plastic packaging for food and drink consumed on HORECA premises, single-use plastic portion packs in HORECA, single-use hotel toiletries and very lightweight plastic carrier bags, each with the exceptions written into the Annex (Art. 25).
From 1 January 2030, operators using transport packaging or sales packaging used for transport must ensure at least 40 % is reusable within a re-use system, 100 % for movements between their own or linked sites and for deliveries to another operator in the same Member State, and 10 % for non-cardboard grouped boxes; final distributors of beverages must sell at least 10 % in reusable packaging and take it back free of charge, with exemptions for small shops, islands, sparsely populated municipalities, micro-enterprises under 1 000 kg a year and Member States that outperform their recycling and prevention targets (Art. 29). Delegated Decision (EU) 2026/429 exempts pallet wrappings and straps from the 100 % requirements. Anyone using reusable packaging must participate in a compliant re-use system and recondition the packaging (Art. 26 and Art. 27); refill stations must follow the Annex VI rules and display the rules for refill (Art. 28). In the HORECA sector, final distributors must let consumers bring their own container for take-away drinks and food by 12 February 2027 and offer reusable take-away packaging by 12 February 2028, micro-enterprises excepted (Art. 32 and Art. 33).
Extended producer responsibility and registers
Producers must register in the national register of every Member State where they first make packaging or packaged products available, or unpack them without being an end user, before doing so, and report the quantities of the preceding calendar year by 1 June; below 10 tonnes a year a simplified report applies (Art. 44). They carry extended producer responsibility under the Waste Framework Directive for that packaging, with the costs of labelling waste receptacles and compositional surveys added (Art. 45(1) and (2)). Producers selling directly to end users in another Member State must appoint an authorised representative for extended producer responsibility there (Art. 45(3)). Online platforms must collect the producer’s register number and self-certification before allowing sales, and fulfilment service providers must verify the same information and suspend producers that do not correct it (Art. 45(4) to (9)). Member States must reach 90 % separate collection of single-use plastic bottles and metal beverage containers up to three litres through deposit and return systems by 1 January 2029 (Art. 50), cut packaging waste per capita by 5 %, 10 % and 15 % in 2030, 2035 and 2040 against 2018 (Art. 43), and keep lightweight plastic carrier bag consumption at or below 40 per person a year (Art. 34).
Enforcement and penalties
The regulation adds itself to Annex I of Regulation (EU) 2019/1020, so the market surveillance framework applies to packaging (Art. 66). Where a market surveillance authority has sufficient reason to believe packaging presents a risk to the environment or human health, it evaluates it, requires proportionate corrective measures within a set period and, if the operator does not comply, prohibits the making available of the packaging, withdraws or recalls it, and informs the Commission and the other Member States (Art. 58). Compliant packaging that still presents a risk can be subject to the same measures (Art. 60), and customs authorities receive the information for import controls (Art. 61). Formal non-compliance, such as a missing or incorrect EU declaration of conformity, incomplete technical documentation, missing identification or a QR code without the required information, must be ended and, if it persists, leads to prohibition, recall or withdrawal; persistent non-compliance with the recyclability, recycled-content, empty-space, format, re-use, refill and take-away rules triggers the national penalties (Art. 62).
Penalties are set at national level. Member States must lay down effective, proportionate and dissuasive penalties by 12 February 2027 and notify them to the Commission, and for the waste-reduction duties of Articles 24 to 29 the penalties must include administrative fines or an equivalent court-imposed fine (Art. 68). In Denmark, Miljøstyrelsen (the Danish Environmental Protection Agency) is the competent authority designated to the Commission for the regulation, and producers register with Dansk Producentansvar.
How Conphora helps
Conphora monitors PPWR and maps your packaging against its requirements, flagging gaps in substance limits, recyclability grades, recycled content, labelling, the EU declaration of conformity and producer registration before they become enforcement problems. The platform helps you build and keep the technical documentation, tracks the 2026, 2028 and 2030 deadlines per packaging type, and alerts you when the Commission adopts the delegated and implementing acts that start the clocks.
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Sources
- Regulation (EU) 2025/40 on packaging and packaging waste, OJ L 2025/40 of 22 January 2025 (EUR-Lex)
- Document information, dates, corrigenda and relationships for CELEX 32025R0040 (EUR-Lex)
- Commission Delegated Decision (EU) 2026/429 exempting pallet wrappings and straps from the 100 % re-use requirements (EUR-Lex)
- Commission Notice C/2026/3084, guidance document for Regulation (EU) 2025/40 (EUR-Lex)
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)
- Packaging waste (European Commission, DG Environment)
- Packaging and Packaging Waste Regulation, implementation and national competent authorities (European Commission, Green Forum)
- Packaging and Packaging Waste Regulation, frequently asked questions of 3 August 2026 (European Commission)
- Producentansvar for emballage, typiske spørgsmål og svar (Miljøstyrelsen)
This guide is for general information and is not legal advice.