DPP for Packaging Under PPWR
How the Packaging and Packaging Waste Regulation (EU) 2025/40 integrates with the EU DPP framework — the 'one DPP' rule, recyclability grading, mandatory recycled content, and the August 2026 application date.
The New Packaging Framework
Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation (PPWR) — was adopted on 19 December 2024, published in the Official Journal on 22 January 2025, and entered into force on 11 February 2025. It applies generally from 12 August 2026, replacing the 1994 Packaging Directive (94/62/EC) in full.
PPWR is a direct regulation — it applies uniformly across all EU member states without national transposition. For businesses placing packaged goods on the EU market, the August 2026 date is a hard deadline for labelling, recyclability, and DPP-related requirements.
The "One DPP" Integration Rule
The most architecturally significant provision in PPWR for companies already subject to other EU product regulations is what the regulation establishes as the "one DPP" integration rule.
Under PPWR, if a product already carries a Digital Product Passport under ESPR (Regulation (EU) 2024/1781) or any other EU law, the same DPP must also carry the PPWR packaging information. There is no requirement — and no permission — to create a separate, packaging-specific DPP. The existing DPP is extended to include the packaging data fields.
This is a direct reinforcement of the EU's "one DPP per product" principle, which the Commission has signalled as the governing philosophy across all product legislation. The practical implication: companies that are already building DPP infrastructure for ESPR compliance do not need a parallel packaging data system. They need their existing DPP to be capable of accommodating the PPWR-required fields.
What Packaging Data Must the DPP Contain?
The PPWR establishes specific data fields that must be included in the DPP (or on a label, pending implementing acts):
- Material composition of each packaging component — by weight and material type (plastic, glass, paper, metal, composite)
- Recyclability grade — A, B, C, or D, as determined by the EU recyclability assessment methodology
- Percentage recycled content — for each packaging component by material
- Whether packaging is reusable — and if so, the reuse system it is designed for
- Labelling information — material identification marks and sorting instructions for consumers
These fields must be in the DPP before the product is placed on the EU market. They must be accessible to consumers via the data carrier (QR code or equivalent), to sorting facilities and recyclers, and to market surveillance authorities.
Recyclability Grading: A Four-Point Scale
PPWR introduces a mandatory recyclability grading system for all packaging. The grades and their market access implications are:
| Grade | Definition | Market Access | |-------|-----------|---------------| | A | Recyclable at scale, high-quality output | Permitted | | B | Recyclable at scale, lower-quality output | Permitted | | C | Recyclable, but not yet at scale | Permitted until Jan 2038 | | D | Not recyclable | Prohibited from Jan 2030 |
From January 2030: Only packaging with grades A, B, or C may be placed on the EU market. Grade D packaging is prohibited. This deadline is irrespective of recycled content — packaging may meet recycled content requirements and still be prohibited if it is not recyclable.
From January 2035: Recyclability must be demonstrated at scale (not just technically possible). Grades B and C will need to meet higher substantiation thresholds.
From January 2038: Only grades A and B permitted.
The recyclability grade must be assessed using the methodology established by the Commission in implementing acts. Companies cannot self-declare grades — assessment must follow the standardised methodology.
Mandatory Recycled Content for Plastic Packaging
PPWR establishes mandatory minimum recycled content requirements specifically for plastic packaging. These thresholds phase in from 2030:
From January 2030, minimum recycled content requirements apply to plastic packaging by contact type (food contact vs non-food contact) and packaging format. The exact percentages are established in Annex II of the regulation and differ by application, with non-food contact plastic packaging facing higher initial thresholds than food contact formats.
The regulation also sets higher thresholds for specific formats — notably PET beverage bottles, which face early and more demanding recycled content targets as part of the EU's broader single-use plastics strategy.
Labelling Requirements from August 2026
From the general application date of 12 August 2026, all packaging placed on the EU market must carry:
- Material composition labels indicating the material type of each packaging component
- Consumer sorting instructions — which waste stream to use in the member state of sale
- Recyclability indicators consistent with the EU's harmonised labelling format
The Commission will adopt implementing acts establishing the exact label formats, icons, and data carrier requirements. Until those implementing acts are published, companies should follow existing national labelling rules where they apply, but plan for the harmonised EU format to supersede them from 2026.
The Broader PPWR Package
Packaging DPP requirements sit alongside a set of wider PPWR obligations that companies must also track:
- Reuse and refill targets: PPWR sets targets for reusable packaging in specific applications (takeaway food and beverages, e-commerce transport packaging). Targets phase in from 2030
- Packaging minimisation requirements: Packaging volume and weight must be minimised — empty space limits and specific thickness limits will be established by implementing acts
- Extended Producer Responsibility: PPWR builds on existing national EPR schemes, requiring harmonisation of fee structures and eco-modulation (fees adjusted by recyclability grade and recycled content) across member states
Practical Implications for Supply Chain Managers
For companies placing packaged products on the EU market from August 2026:
- Review whether your packaging has been assessed against the PPWR recyclability grading methodology. If not, engage a recognised testing or certification body now — assessment timelines are not instantaneous
- Confirm your DPP architecture can accommodate the PPWR packaging data fields if your products are also subject to ESPR or another DPP-triggering regulation
- Audit plastic packaging components for recycled content percentages — these must be documented by weight for each component before the 2030 minimum thresholds become binding
For companies with products not yet subject to ESPR DPP requirements: PPWR's packaging DPP provisions still apply. The regulation does not limit DPP packaging obligations to ESPR-in-scope products. Any product carrying packaging that meets the PPWR DPP trigger must have the relevant data available, whether through an ESPR DPP or through the packaging label format as prescribed by implementing acts.
Sources
- Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation), including DPP integration rule and Annex II (recycled content) — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
- EUR-Lex summary of PPWR: https://eur-lex.europa.eu/EN/legal-content/summary/packaging-and-packaging-waste-from-2026.html
- Regulation (EU) 2024/1781 (ESPR) — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng
- European Commission — Packaging waste implementation page: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en