PPWR Explained: What the EU's New Packaging Regulation Means for Product Companies

The Packaging and Packaging Waste Regulation (EU) 2025/40 (known as PPWR) is the EU's new packaging law. It entered into force on 11 February 2025 and applies from 12 August 2026, replacing the 1994 Packaging and Packaging Waste Directive (94/62/EC). PPWR sets binding rules on packaging design, recyclability, recycled content, reuse, restricted substances, labelling, and Extended Producer Responsibility, and it applies to every economic operator that places packaging or packaged products on the EU market, regardless of where the company is established.

For most product companies, the practical implication is the same: every SKU now carries packaging-level obligations that need to be tracked, documented, and updated as the regulation phases in through 2030 and beyond. This article walks through what PPWR is, who has to comply, the core requirements in plain language, the key dates, and what to start doing now.

The Packaging and Packaging Waste Regulation (EU) 2025/40 is an EU-wide regulation governing all packaging placed on the EU market. It was published in the Official Journal of the European Union on 22 January 2025 and entered into force 20 days later, on 11 February 2025. Most of its provisions become applicable from 12 August 2026, after an 18-month transition period.

PPWR replaces the Packaging and Packaging Waste Directive 94/62/EC, which had governed EU packaging rules since 1994. Two structural changes matter:

• It is a regulation, not a directive. That means PPWR applies directly in every Member State without being transposed into national law. The same rules (same articles, same definitions, same thresholds) apply from Lisbon to Helsinki. PPWR is built around the principle of free movement of compliant packaging across the single market, harmonising rules at EU level so that compliant packaging cannot be blocked by additional national requirements that conflict with the regulation.
• It introduces measurable, market-wide targets. Where the old directive set goals at Member State level, PPWR sets binding requirements at the product level: recyclability grades, recycled content percentages, reuse rates, empty-space caps, and substance limits.

PPWR sits inside the broader EU Green Deal and the EU's Circular Economy Action Plan. It is closely connected to other ongoing regulatory work, including the Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport, and is one of the central instruments through which the EU intends to reduce packaging waste and increase circularity.

PPWR applies to every economic operator that places packaging (or a packaged product) on the EU market. According to the European Commission, this includes manufacturers, importers, distributors, fulfilment service providers, and online marketplaces facilitating sales into the EU. There is no general size-based exemption from PPWR's product requirements. The regulation does provide lighter administrative rules for micro-enterprises (broadly, those placing less than 10 tonnes of packaging on the EU market per year), but the core packaging design, substance, and labelling rules apply regardless of company size.

Does PPWR apply to non-EU companies?

Yes. If your company manufactures outside the EU but places packaged products on the EU market (directly or through a distance seller, fulfilment provider, or marketplace), PPWR obligations apply to you. Non-EU producers selling into a Member State via distance contracts may be required by that Member State to appoint an authorised representative for Extended Producer Responsibility (EPR) purposes; the practical detail is set in national law within the harmonised PPWR framework.

The regulation also explicitly captures online sales. Online marketplaces are required, under Article 45 of PPWR, to verify that traders selling packaging or packaged products into a given Member State are registered with that Member State's producer register. Fulfilment service providers carry duties relating to handling, warehousing, and packing of packaged products in line with PPWR's product requirements.

PPWR's requirements span six areas: substances, recyclability, recycled content, reuse, restricted formats and empty space, labelling, and EPR. The summary below uses the regulation as published; specific dates and thresholds are detailed further down.

Restricted substances in packaging

Article 5 of PPWR sets restrictions on substances of concern in packaging. The sum of the concentrations of lead, cadmium, mercury, and hexavalent chromium resulting from substances present in packaging or packaging components must not exceed 100 mg/kg. The cap applies from 12 August 2026.

Article 5 also restricts per- and polyfluoroalkyl substances (PFAS) in food-contact packaging. The limits are 25 parts per billion (ppb) for any individual non-polymeric PFAS measured by targeted analysis, 250 ppb for the sum of non-polymeric PFAS, and 50 parts per million (ppm) for total organic fluorine; the latter captures polymeric PFAS. The PFAS restrictions apply from 12 August 2026 to any food-contact packaging placed on the EU market after that date, even if the packaging itself was manufactured earlier.

Recyclability

Article 6 of PPWR requires that, by 1 January 2030, all packaging placed on the EU market must be designed for recycling and meet a recyclability performance grade (A, B, or C) set out in the regulation, with detailed assessment criteria in delegated acts. Packaging that does not meet at least the lowest qualifying grade will not be allowed on the EU market from 2030 onward. From 1 January 2038, packaging classified as grade C is phased out, leaving only grades A and B on the market. The exact percentage thresholds for each grade are set out in PPWR's annexes and the supporting delegated acts; product companies should track the delegated acts as they are adopted.

Recycled content in plastic packaging

Under Article 7 of PPWR, from 1 January 2030 plastic packaging placed on the EU market must contain a minimum share of post-consumer recycled plastic. The headline 2030 targets are:

• 30% recycled content in single-use plastic beverage bottles
• 30% in contact-sensitive plastic packaging made primarily of PET
• 10% in contact-sensitive plastic packaging made of plastics other than PET
• 35% in other plastic packaging not covered above

Higher targets apply from 1 January 2040. For example, single-use plastic beverage bottles rise to 65% recycled content. The European Commission must report on implementation by 12 February 2032 and may revise the 2040 targets in light of recyclate availability and market conditions. Recycled content is calculated as an average per manufacturing plant and per year, using the methodology set out in PPWR's delegated acts.

Reuse targets

Article 29 of PPWR introduces binding reuse targets for specific packaging types. From 1 January 2030, final distributors of beverages (covering both alcoholic and non-alcoholic categories) must make at least 10% of the beverages they sell available in reusable packaging within a reuse system, rising to 40% by 1 January 2040. Milk and other beverages requiring aseptic technology due to microbiological sensitivity are exempt from these targets, and several categories (including wine, aromatised wine products, spirit drinks, and milk products) are exempt from mandatory deposit-and-return obligations.

For transport, industrial, and e-commerce packaging, Article 29 sets a reuse rate of at least 40% by 1 January 2030, rising to 70% by 1 January 2040. In addition, from 1 January 2030 transport packaging used between business sites within the EU must in principle be reusable.

A reuse system means a defined organisational, technical, and financial arrangement that ensures the packaging is reused multiple times, including reverse logistics, cleaning, and inspection.

Empty space and restricted formats

To reduce over-packaging, Article 8 of PPWR limits the empty space ratio of grouped, transport, and e-commerce packaging to a maximum of 50%. The cap takes effect from 1 January 2030, in line with the calculation methodology to be set in a Commission implementing act (which the Commission must adopt by 12 February 2028). The 50% empty space cap does not apply to reusable packaging.

Article 25 of PPWR, together with Annex V, prohibits certain single-use plastic packaging formats from 1 January 2030. The banned formats include single-use plastic packaging for unprocessed fresh fruit and vegetables under defined weight thresholds, single-serve plastic packaging for condiments, sauces, sugar, coffee creamer and similar in the HoReCa sector, single-use plastic miniature toiletries provided in the hotel and accommodation sector, and very lightweight plastic carrier bags. For points 1 to 4 of Annex V, composite packaging with a plastic content of 5% or less by weight is exempt from these specific bans.

Labelling

Article 12 of PPWR introduces harmonised packaging labels showing material composition, with pictograms designed to help consumers sort waste correctly. Reusable packaging must carry a specific reuse label, and packaging containing recycled content must indicate the recycled share where claimed. The harmonised labelling rules apply from 12 August 2028, or 24 months after the entry into force of the Commission implementing act establishing the harmonised label specifications, whichever is later. The Commission must adopt those implementing acts by 12 February 2027.

Extended Producer Responsibility

PPWR harmonises core elements of Extended Producer Responsibility (EPR) for packaging across all Member States. Producers (defined broadly to include manufacturers, brand owners, importers, and distance sellers) must register with the national producer register in every Member State where they place packaging on the market, and contribute financially to the collection, sorting, and treatment of packaging waste. PPWR introduces mandatory eco-modulation of producer fees based on packaging recyclability performance.

What PPWR does not fully harmonise is the operational layer: fee amounts, registration mechanics, collection schemes, and additional national modulation criteria continue to run through each Member State's national EPR system. Member States may also require non-EU producers selling into their territory under distance contracts to appoint an authorised representative for EPR purposes. There is no exemption from EPR registration for micro-enterprises, although they may benefit from lighter administrative obligations under PPWR.

The August 2026 application date is a milestone, not the finish line. The hardest deadlines for most product companies (recyclability grades, recycled content, reuse, format bans) sit on 1 January 2030, with further tightening through 2038 and 2040.

The August 2026 application date is the floor, not the ceiling, of PPWR work. Substance restrictions and the EPR framework apply from day one. Recyclability grades, recycled content, reuse, and format bans land in 2030, but the data, design, and supplier work behind those rules takes years.

What is the difference between PPWR and the old Packaging and Packaging Waste Directive?

PPWR is a regulation, while the previous PPWD was a directive. The directive set goals that each Member State implemented through its own national law, leading to fragmentation; PPWR applies the same binding rules directly in every Member State. PPWR also goes further substantively: it sets product-level targets for recyclability, recycled content, reuse, and restricted formats that did not exist under the directive.

Does PPWR apply to non-EU companies?

Yes. PPWR applies to any economic operator that places packaging or a packaged product on the EU market, regardless of where the company is established. Member States may require non-EU producers selling into their territory under distance contracts to appoint an authorised representative, particularly to handle EPR registration and compliance, with the practical detail set in national law within the harmonised PPWR framework.

When does PPWR start applying?

PPWR entered into force on 11 February 2025. Most provisions apply from 12 August 2026, after an 18-month transition period. Specific obligations (most notably the recyclability grade, recycled content, reuse targets, empty space cap, and Annex V single-use plastic bans) apply from 1 January 2030. Higher recycled content targets and the phase-out of recyclability grade C extend into 2038 and 2040.

What happens if my packaging is not compliant with PPWR?

Under PPWR, non-compliant packaging may not be placed on the EU market. Article 47 requires Member States to lay down rules on penalties for infringements, which must be effective, proportionate, and dissuasive. In practice, non-compliance can result in market surveillance actions, sales bans, removal of products from marketplaces, and administrative fines applied at Member State level.

Does PPWR replace national EPR rules for packaging?

PPWR harmonises core EPR obligations (including the producer definition, mandatory registration, financial responsibility, and eco-modulation of fees based on recyclability), but the operational details continue to run through each Member State's national EPR scheme. Producers still need to register with each national scheme in which they place packaging on the market. PPWR sets the baseline rules; national authorities run the systems.

PPWR is not a single deadline; it is a multi-year programme that turns packaging from a procurement decision into a regulated, data-intensive part of every product. Four implications stand out for product companies:

• Packaging is now a SKU-level data problem. Material composition, recyclability grade, recycled content share, reuse-system status, and substance compliance all need to be known and documented per packaging unit, not estimated at portfolio level.
• The 2030 milestones drive 2026–2027 decisions. Recyclability grades, recycled content targets, reuse infrastructure, and Annex V format bans all need lead time; supplier qualification, redesign, and reverse-logistics setup do not happen overnight.
• EPR exposure expands. Every EU Member State you sell into is a registration to manage, and non-EU producers face authorised-representative obligations on top of that.
• Cross-functional ownership is unavoidable. Packaging, quality, regulatory, sourcing, and operations teams all touch PPWR, and they need a shared, structured view of packaging compliance across markets.

For companies managing thousands of SKUs across multiple EU markets, like Flying Tiger Copenhagen, the underlying challenge is the same one PPWR makes urgent: structured, market-by-market packaging data that updates as regulations and products change. That is precisely the problem Complir was built to solve, by automating the mapping between packaging data, regulatory requirements, and per-market documentation, so PPWR readiness becomes a workflow rather than a fire drill.

See how Complir maps every product to every applicable regulation across your EU markets.

Sources & References

• Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste: EUR-Lex
• Packaging and Packaging Waste Regulation overview: European Commission, DG Environment
• Packaging waste, policy area page: European Commission, DG Environment
• PPWR Guidance Document: European Commission, DG Environment
• PPWR Frequently Asked Questions: European Commission, DG Environment

This article is for informational purposes only and does not constitute legal advice. Regulatory requirements may vary by product category, market, and specific circumstances. Consult with a qualified legal professional for compliance guidance specific to your situation.