EU Packaging and Packaging Waste Regulation (PPWR)

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Last updated: 28.11.202   EU Packaging and Packaging Waste Regulation (PPWR)

EU Packaging and Packaging Waste Regulation (PPWR)

On 22 January 2025, the European Union published Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), replacing Directive 94/62/EC. The regulation entered into force on 11 February 2025 and will apply from 12 August 2026, with certain provisions taking effect at later dates.

The PPWR establishes harmonized rules across the EU to

  • reduce packaging waste,
  • enhance recyclability,
  • and promote a circular economy.

It applies to all packaging and packaging waste placed on the EU market, regardless of material or sector.

The PPWR applies to all packaging and packaging waste placed on the EU market, regardless of material or sector.

Key Obligations for Businesses

  • how: By 1 January 2030, all packaging must be designed for recyclability, meeting criteria set by the European Commission in delegated acts.
  • Packaging Minimization: From 1 January 2030, packaging must be reduced to the minimum necessary volume and weight, with a maximum empty space ratio of 50% for transport packaging.
  • Recycled Content Targets: Mandatory minimum recycled content for plastic packaging will be phased in starting 1 January 2030, with targets varying by packaging type.
  • Labeling and Consumer Information: From 12 August 2028, packaging must bear harmonized labels indicating material composition and disposal instructions to facilitate recycling.
  • Extended Producer Responsibility (EPR): Producers must register in each Member State where they place packaging on the market, provide data on packaging materials, and contribute financially to waste management based on the recyclability and environmental impact of their packaging.

How to stay compliant with PPWR?

Companies operating within the EU should begin preparing now for the upcoming Packaging and Packaging Waste Regulation (PPWR) by taking the following steps:

  • Review your current packaging portfolio – Assess whether your packaging meets the new requirements for recyclability, use of recycled content, and material reduction.
  • Develop a compliance strategy – Plan for necessary packaging redesigns, label updates, and steps to meet recycled content targets.
  • Engage with Extended Producer Responsibility (EPR) schemes – Register with the relevant national authorities and prepare for financial contributions based on the environmental performance of your packaging.
  • Stay updated on regulatory developments – Monitor delegated and implementing acts, which will provide further details on compliance expectations and timelines.

FAQ: EU Packaging and Packaging Waste Regulation (PPWR)

What is the Packaging and Packaging Waste Regulation (PPWR) and how does it differ from the previous Packaging Directive?

The Packaging and Packaging Waste Regulation (PPWR) replaces the previous Packaging Directive (94/62/EC), creating harmonised packaging requirements across EU Member States. It aims to ensure that all packaging, including service packaging, sales packaging, grouped packaging, and composite packaging, is placed on the EU market recyclable by 2030.

What are the obligations regarding packaging recyclability and reusable packaging?

All packaging categories must meet strict recycling criteria. From 2030, all packaging on the EU market must be recyclable, with certain minimum reusability requirements applied to reusable packaging. Reusable packaging must be compatible with approved reuse systems, and economic operators must provide relevant technical documentation.

Reusable and recyclable packaging compliant with EU PPWR 2030 requirements, including reuse system compatibility and documentation standards.

Are there mandatory recycled content obligations under the PPWR?

Yes. There are minimum recycled content thresholds for plastic packaging, including:

  • 30% for contact sensitive packaging made from PET and beverage bottles
  • 10% for contact sensitive plastic packaging using other plastics
  • 35% for other plastic packaging types

These thresholds apply to post-consumer plastic waste and promote the use of recycled plastics and recycled material across packaged products.

How does the PPWR address packaging minimisation and design?

Packaging design must ensure that packaging units are not excessive. The regulation mandates packaging minimisation, with restrictions such as a 50% maximum empty space ratio for e-commerce packaging, grouped packaging, and transport packaging. Lightweight plastic carrier bags and certain packaging formats like miniature cosmetics will be restricted.

What about packaging for food and beverages?

Food contact packaging, food packaging, and beverage packaging must comply with mandatory recycled content rules, and bans will apply to certain single use packaging and single use plastic packaging.

Compostable packaging may only be used where appropriate collection infrastructure exists, and compostable plastic packaging must not interfere with material recycling or contaminate other waste streams.

Compostable packaging with proper collection infrastructure, avoiding contamination of recycling and waste streams under EU PPWR rules.

What are the labelling requirements under the PPWR?’

There are strict labelling requirements to facilitate consumer sorting.

All packaging must display harmonised labels showing recycled materials used, consumer sorting instructions, and, where applicable, reuse guidelines. This supports transparency and ensures that sustainable packaging solutions are effectively integrated.

How does the PPWR relate to sustainability and emissions?

The PPWR supports the shift to sustainable packaging by reducing the use of primary raw materials, decreasing greenhouse gas emissions, and supporting packaging waste management practices that align with circular economy goals.

The regulation mandates clear roles for manufacturing plants in ensuring compliance.

Expert team leader D&P Legal Michał Puk
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Expert team leader D&P Legal Ignacy Heckert
Contact our expert
Write an inquiry: [email protected]
check full info of team member: Michał Puk