PPWR
What is PPWR?
PPWR (Regulation (EU) 2025/40 on packaging and packaging waste) is the EU regulation that sets harmonised, binding requirements for the design, composition, labelling, and end-of-life management of packaging placed on the EU market. It replaces the earlier Packaging and Packaging Waste Directive (94/62/EC) and applies directly across all EU member states without the need for national transposition, covering almost all packaging types and materials, including packaging used for products imported from outside the EU. It entered into force on 11 February 2025 and applies from 12 August 2026.
Why It Matters
PPWR affects any business that places packaged goods on the EU market, not only packaging manufacturers. Producers, importers, and distributors are all expected to ensure that the packaging associated with their products meets recyclability, minimisation, and labelling requirements before it reaches EU consumers.
Businesses that source packaged products from outside the EU cannot assume their suppliers have already addressed PPWR obligations. Packaging design, material choices, and labelling decisions made earlier in the supply chain can create compliance gaps that fall back on the importer or distributor placing the product on the market.
Non-compliant packaging can result in enforcement action, required redesign of packaging lines, and restricted market access. Given that most substantive PPWR obligations begin applying from 12 August 2026 — the date the Regulation itself specifies — businesses that sell into the EU are expected to be reviewing their packaging now rather than waiting for that date to arrive.
Key Requirements
Who Is Required to Comply with PPWR?
PPWR obligations apply to any economic operator involved in placing packaging or packaged products on the EU market, including:
- Producers and manufacturers of packaging
- Importers bringing packaged goods into the EU from third countries
- Distributors and online marketplaces making packaged products available to EU consumers
- Fulfilment service providers handling packaged goods on behalf of non-EU sellers
The PPWR applies across virtually all packaging categories, including primary, secondary, and tertiary (transport) packaging, e-commerce and shipping packaging, food contact and food-adjacent packaging, as well as both reusable and single-use packaging formats.
Responsibilities Relating to PPWR
Depending on their role in the supply chain, businesses are generally expected to:
- Ensure packaging is designed to be recyclable in line with EU design-for-recycling criteria
- Meet minimum recycled content thresholds for plastic packaging — 30% for PET contact-sensitive packaging, 10% for other contact-sensitive plastic packaging, 30% for single-use plastic beverage bottles, and 35% for other plastic packaging by 1 January 2030, rising to 50%, 25%, 65%, and 65% respectively by 2040 (with exemptions for pharmaceutical, infant/young-children’s food, medical device, hazardous-goods transport, and compostable plastic packaging)
- Ensure packaging meets applicable recyclability performance grades, which apply from 2030, with a requirement to be recyclable “at scale” from 2035 and stricter recyclability obligations from 2038
- Avoid restricted substances in packaging, including a combined 100 mg/kg limit on lead, cadmium, mercury, and hexavalent chromium, and limits on intentionally added PFAS in food contact packaging from 12 August 2026
- Limit empty space in grouped, transport, and e-commerce packaging to no more than 50% by 2030
- Apply harmonised labelling to indicate material composition and recyclability
- Register with the relevant extended producer responsibility scheme where required
- Retain documentation demonstrating how packaging meets applicable essential requirements
PPWR and Technical Documentation
Producers placing packaging on the EU market are generally required to draw up technical documentation showing how the packaging meets PPWR’s essential requirements, along with an EU declaration of conformity for the packaging. Technical documentation must generally be retained for five years, or ten years in the case of reusable packaging. Importers and distributors should request access to this documentation from their suppliers, since it forms the evidence base for demonstrating that packaging entering the EU market is compliant
Packaging Compliance Under PPWR
Selling packaged products in the EU? Every unit now falls under the Packaging and Packaging Waste Regulation (EU) 2025/40. Euverify handles your Declaration of Conformity, technical file, and compliance documentation as part of your plan, no expertise required on your end.
Related Terms
Further Reading
