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EU Packaging and Packaging Waste Regulation (PPWR)

ENFORCEMENT TIMELINE

Full application begins August 12, 2026 (including restrictions on PFAS and other hazardous substances)

Enforcement: Full application begins August 12, 2026 (including restrictions on PFAS and other hazardous substances)

Overview

The EU Packaging and Packaging Waste Regulation (PPWR) is a new, comprehensive regulation covering all packaging placed on the EU market, designed to advance the circular economy. It formally entered into force on February 11, 2025, with full, phased application beginning August 12, 2026.

Unlike a directive, the PPWR does not require transposition into each member state's national law — as a regulation, it applies directly and uniformly across the entire EU with binding legal force. As a result, any company shipping products to the EU market — not only packaging material manufacturers, but also manufacturers, importers, and online sellers of packaged goods across sectors such as automotive, electronics, and consumer products — is subject to strict requirements covering packaging waste reduction, minimization of packaging (banning excessive packaging), mandatory reuse and recyclability, and packaging conformity assessment together with a Declaration of Conformity.

The PPWR represents a complete overhaul of the earlier Packaging and Packaging Waste Directive (PPWD, Directive 94/62/EC), replacing it with a regulation that applies directly across the EU. The PPWD, adopted in 1994, was a landmark environmental directive that systematically advanced the reduction, reuse, and recycling of packaging waste across EU member states and became the foundation for packaging extended producer responsibility (EPR) systems worldwide. Following phased amendments under the 2015 and 2018 Circular Economy Packages, the EU has now moved to a single, uniform set of rules across all member states to eliminate inconsistencies in national implementation, further strengthening requirements for packaging reduction, reuse, recyclable design, and mandatory use of recycled content.

Enforcement Timeline

December 1994: The original Packaging and Packaging Waste Directive (94/62/EC) is formally adopted, establishing the foundation for EU-wide packaging waste management.

2004: An amending directive enters into force, substantially raising material-specific recycling targets.

2015: The Circular Economy Package is proposed, adding requirements to reduce single-use plastic bags.

May 2018: The amending directive (EU) 2018/852 is adopted, setting packaging recycling rate targets for 2025 and 2030.

February 11, 2025: The PPWR officially enters into force.

August 12, 2026: The PPWR applies. This includes concentration limits for PFAS (per- and polyfluoroalkyl substances) in food-contact packaging (25 ppb for any targeted PFAS, 250 ppb for the sum of targeted PFAS and 50 ppm for total PFAS including polymeric PFAS; Article 5(5)), as well as the conformity assessment procedure (Article 38) and the EU declaration of conformity (Article 39).

January 2030: The obligation to cut packaging waste generation by 5% compared with 2018 takes effect, along with mandatory minimum recyclability standards (Grade A–C compliance) for all packaging materials and the start of minimum recycled-content (post-consumer recycled material) targets for plastic packaging.

January 2040: The long-term target of a 15% reduction in packaging waste generation compared with 2018 is to be fully achieved.

Related Regulations / Topics

EU Packaging and Packaging Waste Regulation (PPWR) Packaging Minimisation Standards, Empty Space Ratio Limits, and Prohibition of Excessive Packaging

This card focuses on the specific operational practice for the "packaging weight and volume minimisation obligation," the "empty space (void) ratio limit," and the "prohibition of excessive packaging" under Article 10 (packaging minimisation) and Article 24 (obligation related to excessive packaging) of the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, PPWR). By January 1, 2030, manufacturers and importers must ensure that packaging placed on the EU market is designed so that its weight and volume are reduced to the minimum necessary to ensure its functionality (Article 10(1)). Design techniques that artificially inflate volume — such as double walls, false bottoms, and unnecessary additional layers — are in principle prohibited. Economic operators who fill grouped, transport or e-commerce packaging must ensure a maximum empty space ratio of 50%, from January 1, 2030 or three years after the implementing acts setting the calculation method enter into force, whichever is later (Article 24(1); those acts are due by February 12, 2028). European standardisation bodies will subsequently establish specific numerical thresholds for weight, volume, and material thickness by packaging format and material category.

EU Packaging and Packaging Waste Regulation (PPWR) Waste Reduction Targets, Banned Single-Use Packaging Formats, and Deposit Return Systems

This card focuses on the specific operational practice for the "per capita packaging waste reduction targets at Member State level," the "ban on single-use plastic packaging for specific uses," and the "deposit return system (DRS) for single-use beverage containers" under Article 43 and Annex V, among other provisions, of the PPWR. Each Member State is legally required to reduce per capita packaging waste generation, compared with 2018 levels, by 5% by 2030, 10% by 2035, and 15% by 2040. In addition, the packaging listed in Annex V — including single-use plastic portion packaging for condiments, sugar, and creamer in the HORECA (hotel, restaurant, café) sector, single-use plastic packaging for unprocessed fresh fruit and vegetables under 1.5 kg, single-use plastic grouped packaging such as shrink wrap that bundles multiple products, and single-use packaging (of any material) for cosmetics, hygiene and toiletry products for individual bookings in the accommodation sector — may not be placed on the EU market from January 1, 2030 (Article 25(1)). Member States must further ensure the separate collection of at least 90% of single-use plastic and metal beverage containers of 3 litres or less by January 1, 2029, and set up deposit return systems to that end (Article 50(1) and (2)). Member States with a separate collection rate of 80% or more in 2026 that apply for exemption and submit an implementation plan by January 1, 2028 may be exempted from that obligation (Article 50(5)).

EU Packaging and Packaging Waste Regulation (PPWR) Recyclability Performance Grading System, Recycled Content Requirements, and Reuse Targets

This card focuses on the specific operational practice for the "recyclability performance grading system (Grades A–C)," the "recycled content obligation for plastic packaging," and the "reuse targets for the beverage, transport, and HORECA sectors" under Articles 6, 7, and 29 of the PPWR. From January 1, 2030 (or 24 months after the delegated acts setting the recyclability criteria enter into force, whichever is later), all packaging placed on the EU market will be required to meet "Design for Recycling" criteria and fall within recyclability performance grades A, B or C established by the European Commission (Article 6(3); from 2038, only grades A or B). From January 1, 2035 (or five years after the implementing acts on the recycled-at-scale assessment enter into force, whichever is later), an additional "recycled at scale" criterion applies, under which packaging must not only be theoretically recyclable but must actually be processed in significant quantities through the EU's separate collection, sorting, and recycling infrastructure. For plastic packaging, a post-consumer recycled content obligation applies from January 1, 2030 (or three years after the implementing act on the calculation method enters into force, whichever is later): 30% for contact-sensitive PET packaging other than single-use plastic beverage bottles, 10% for contact-sensitive packaging made from other plastics, 30% for single-use plastic beverage bottles and 35% for other plastic packaging, rising in 2040 to 50%, 25%, 65% and 65% respectively (Article 7). On reuse, from January 1, 2030, final distributors selling beverages to consumers must make at least 10% of those products available in reusable packaging within a re-use system, and economic operators using transport packaging must ensure that at least 40% of it is reusable packaging within a re-use system; for 2040, the regulation sets endeavour targets of 40% and 70% respectively (Article 29).

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Business Impact

The regulation applies broadly to manufacturers exporting to the EU — not just packaging material producers, but any company shipping packaged goods — as well as food, beverage, and cosmetics manufacturers, logistics and supply chain management functions, and e-commerce and online retail operators. From 12 August 2026, manufacturers must carry out the conformity assessment and draw up an EU declaration of conformity before placing packaging on the market (Articles 15 and 39). Where the declaration has not been drawn up and the non-compliance persists, Member States must prohibit the packaging from being made available on the market or ensure that it is recalled or withdrawn (Article 62).

Because PFAS concentration limits for food-contact packaging apply from 12 August 2026, test results and technical documentation showing that PFAS in water- and oil-resistant coatings stay below the limits become essential. The existing requirement inherited from the PPWD, limiting the combined concentration of the four major heavy metals (lead, cadmium, mercury, and hexavalent chromium) in packaging materials such as inks, cardboard, and plastic bags to 100 ppm or less, also remains in force.

Companies will need to design reuse and take-back systems for shipping pallets, containers, and cushioning materials, and to build new joint collection arrangements with logistics partners. Practical obligations include collecting and retaining heavy-metal compliance certificates (100 ppm or below) for export cardboard, pallets, and printing inks across the supply chain, registering for EPR with national recycling collection organizations across Europe (such as LUCID in Germany and Citeo in France), and reporting and paying contributions based on the shipped weight of packaging materials.

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Official Sources & Reference Links