European Packaging and Packaging Waste Regulation (PPWR)
This article is provided by BRC Associate Member, UL Solutions.
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On Jan. 22, 2025, “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” was published in the Official Journal of the European Union.
This regulation is also known by the initialism PPWR.
The PPWR aims to harmonize packaging management in the European Union’s (EU) common market, prevent and minimize packaging waste, reduce the use of primary raw (virgin) material, and promote packaging sustainability and safety for human health, thus contributing to the transition to a circular economy and climate neutrality.
Among the specific innovations this regulation introduces, we highlight the minimization of the weight and volume of some packaging and the restrictions on the use of specific packaging formats. Other changes include the future definition of “recyclability” applicable to all packaging, requirements for the reuse and refilling of specific packaging, and rules on the collection and treatment of packaging waste.
We also highlight the requirements related to the verification of packaging conformity, the issuance of technical documentation, the EU Declaration of Conformity (DoC) of the packaging and the new labeling requirements.
In addition, innovations have been introduced regarding Extended Producer Responsibility (EPR).
The regulation also restricts the content of certain per- and polyfluoroalkyl substances (PFAS) in food-contact packaging.
Finally, we expect the future identification of a list of specific substances of concern (SoCs), including obligations to minimize and communicate their presence in packaging above certain limits through standardized and open digital marking technologies.
The PPWR came into force on Feb. 11, 2025, and its general application date is Aug. 12, 2026, though different specific requirements apply on different dates.
Also expected is the publication of implementing acts, standards or related guidelines for various requirements. This is necessary to clarify the requirements or, in some cases, to make them legally applicable.
In addition, the PPWR repeals the current European Packaging and Packaging Waste Directive 94/62/EC (PPWD) as of Aug. 12, 2026, except for specific requirements for which the repeal dates will be later.
Notably, a Commission Notice was published in 2025 regarding the partial application of the PPWR to Northern Ireland in respect to the United Kingdom.
Main provisions of the PPWR
An overview of the main provisions of the PPWR is provided below.
- Requirements for the recyclability of packaging, to be further defined by specific implementing acts
- Requirements for minimum recycled content in plastic packaging (subject to implementing acts to define their criteria)
- Restrictions on the use of certain packaging formats
- Compostability requirements for specific packaging formats
- Definition of “reusable packaging” (subject to integration by a delegated act)
- Introduction of reuse obligations for the takeaway sector for hot or cold beverages and food ready and intended for immediate consumption
- Provisions concerning the reduction of lightweight plastic carrier bags
- Requirements for minimizing the weight and volume of packaging – Except for grouped packaging, transport packaging or e-commerce packaging, the maximum empty space ratio, expressed as a percentage, shall be 50%.
- Requirements for the management of packaging and packaging waste (registration of producers, EPR requirements) and for deposit and return systems
- Restrictions on the content of certain PFAS in food-contact packaging (this requirement is not present in the PPWD)
- Restrictions on the content of certain heavy metals (lead, cadmium, mercury, chromium (VI)), applicable to all packaging; though the PPWR limit is currently the same as the PPWD, this limit may be lowered
- New labeling of packaging harmonized at the EU level – This includes the identification of the manufacturer and, if any, the importer of the packaging as well as “a type, batch or serial number or other element allowing its identification.” In addition, based on specific implementing acts, other environmental information shall be provided, partly physically affixed to the packaging and partly conveyed via a QR code (or similar methods). Specific implementing acts will be published to apply some of these requirements.
- The first list of SoCs has yet to be defined.
- Provisions on the labeling of waste receptacles for the collection of packaging waste
- Specific provisions on certain environmental claims relating to packaging
- Definitions and obligations of economic operators regarding packaging
- Requirements for the specific conformity assessment procedure of packaging, the issuance of technical documentation and of an EU DoC for the packaging
Application dates:
Due to the regulation’s complexity and phased implementation, the overview below highlights certain PPWR application dates.
This is a general summary only. Each economic operator must assess its specific obligations, deadlines and requirements.
Dates and requirements may change, including possible amendments to the regulation, delays or the publication of specific exemptions or additional provisions.
From 2025:
| Requirement | Date of application | Notes |
| Definition of reusable packaging | Feb. 11, 2025 | The definition in Art. 11(1) is already in force, but this definition will be supplemented in 2027. |
| Recycling targets and promotion of recycling | Dec. 31, 2025 | Same limits as the PPWD for 2025; stricter targets from Dec. 31, 2030 |
From 2026:
|
Requirement |
Date of application |
Notes |
|
Restrictions on the content of certain heavy metals |
Aug. 12, 2026 |
Same requirements as PPWD |
|
Restrictions on the content of certain PFAS in food-contact packaging |
Aug. 12, 2026 |
|
|
Type, batch or serial number, or other element allowing the identification of the packaging |
Aug. 12, 2026 |
On the packaging |
|
Identification of the manufacturer/importer |
Aug. 12, 2026 |
On the packaging or with a QR code |
|
Provisions relating to environmental claims |
Aug. 12, 2026 |
|
|
Procedures for verification of compliance |
Aug. 12, 2026 |
|
|
Technical documentation |
Aug. 12, 2026 |
|
|
EU DoC |
Aug. 12, 2026 |
|
|
Definitions of the various economic operators and their respective obligations |
Aug. 12, 2026 |
|
|
EPR and related obligations |
Effective Aug. 12, 2026 |
Various dates |
|
Report on SoCs in packaging |
Expected by Dec. 31, 2026 |
A report on such substances is to be published by the European Commission (EC) and European Chemicals Agency (ECHA). |
From 2027:
|
Requirement |
Date of application |
Notes |
|
Integration of the definition of reusable packaging regarding the minimum number of rotations |
Feb. 12, 2027 |
A minimum number of rotations for the reusable packaging formats most frequently reused will be established. |
|
Guidelines on restrictions on the use of specific packaging formats |
Feb. 12, 2027 |
Restrictions applicable from Jan. 1, 2030 |
|
Mandatory refill requirements for the takeaway food and beverage sector |
Feb. 12, 2027 |
|
|
Deadline for the definition of specific sanctions by member states |
Feb. 12, 2027 |
|
From 2028
|
Requirement |
Date of application |
Notes |
|
Publication of the first criteria for the recyclability of packaging |
Jan. 1, 2028 |
Further publications to be made by Jan. 1, 2030 |
|
Minimization of empty space in sales packaging |
Feb. 12, 2028 |
|
|
Review of the state of technological development and environmental performance of bio-based plastic packaging |
Feb. 12, 2028 |
The EC may present a proposal for regulation after the review. |
|
Requirements on the compostability of some packaging |
Feb. 12, 2028 |
|
|
Possibility of obtaining hot or cold beverages or ready-to-eat food intended for takeaway consumption in reusable packaging |
Feb. 12, 2028 |
Applicable to the accommodation and food service activities sector — hotel, restaurant and café/catering (HORECA) |
|
A label is physically affixed to the composition materials to facilitate consumer packaging sorting. |
Aug. 12, 2028 |
Or 24 months after the date of entry into force of the implementing acts, whichever is later; other labeling requirements may apply on other dates |
|
Label containing information identifying the percentage of recycled content |
From 2029
|
Requirement |
Date of application |
Notes |
|
Deposit and return systems for single-use plastic beverage bottles and single-use metal beverage containers with a capacity of up to three liters |
Jan. 1 2029 |
|
|
Setting of collection objectives |
Jan. 1 2029 |
To be defined by the member states |
|
Labeling of packaging as reusable |
Feb. 12, 2029 |
Or 30 months after the date of entry into force of the implementing act, whichever is later |
From 2030
|
Requirement |
Date of application |
Notes |
|
Application of the first criteria on the recyclability of packaging |
Jan. 1, 2030 |
Or 24 months after the date of entry into force of the delegated acts, whichever is later; further criteria apply starting from Jan. 1, 2035 |
|
Reduction of maximum empty space ratio (50% or less) in grouped packaging, transport packaging or e-commerce packaging |
Jan. 1, 2030 |
Or three years from the entry into force of the implementing acts, whichever is later |
|
Minimum recycled content in plastic packaging |
Jan. 1, 2030 |
Or three years after the date of entry into force of an implementing act, whichever is later; different percentages apply based on the type of plastic packaging; additional requirements from Jan. 1, 2040 |
|
Restrictions on the use of specific packaging formats |
Jan. 1, 2030 |
By Feb. 12, 2027, the European Commission shall publish guidelines. |
|
Publication of methodology for using digital marking to identify SoCs in packaging |
Jan. 1, 2030 |
|
|
Ten percent of takeaway food and beverage products distributed in a reusable format |
Jan. 1, 2030 |
Applicable to the accommodation and food service activities sector — hotel, restaurant and café/catering (HORECA) |
|
Ten percent of the sales area dedicated to refilling stations for both food and nonfood products |
Jan. 1, 2030 |
Applicable to final distributors with a sales area of more than 400 m2 |
|
Reuse targets for packaging |
Starting from Jan. 1, 2030 |
Various targets and dispositions; exemptions have been or might be published in the future |
From 2031:
| Requirement | Date of application | Note |
| Green public procurement — mandatory minimum requirements to be set | One year after the adoption of an EC act | Acts to be adopted by Feb. 12, 2030 |
Official sources:
https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025XC00946
