DPP for Packaging Under PPWR
How the Packaging and Packaging Waste Regulation (EU) 2025/40 integrates with the EU DPP framework: the single data carrier 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, 12 August 2026 is the date from which the Regulation applies. Several obligations start later: the harmonised label, for example, will apply later than 12 August 2028 (see Labelling Requirements below).
The Single Data Carrier Rule
The PPWR does not create a separate digital product passport for packaging. Its integration rule is about data carriers. Under Article 12(5), where EU law requires information on the packaged product to be provided via a data carrier, a single data carrier must be used for the information required for the packaged product and for the packaging, and the two must be easily distinguishable.
Recital 70 explains the aim: no multiplication of labels on packaging. It adds that where the packaged product is covered by ESPR (Regulation (EU) 2024/1781) or other EU law requiring a digital product passport, that passport should also be used to provide the relevant packaging information. The practical implication: companies building DPPs for ESPR can plan to provide packaging information through the same passport and data carrier, rather than through a parallel system (Regulation (EU) 2025/40).
What Packaging Information Must Be Provided?
The PPWR does not list DPP data fields for packaging. The packaging information it requires is set out mainly in Article 12:
- A harmonised label on material composition, applying later than 12 August 2028 (see Labelling Requirements below)
- Reusable packaging: a label saying the packaging is reusable, plus a QR code or other data carrier with information on re-use, from 12 February 2029 at the earliest (Art. 12(2))
- Substances of concern: packaging that contains them must be digitally marked, using a methodology the Commission must adopt by 1 January 2030 (Art. 12(1) and (7))
- Optional sorting information: companies may add a QR code or other data carrier showing where each separate packaging component should go (Art. 12(1))
Recyclability Grading: Grades A to C
PPWR introduces recyclability performance grades for packaging, set out in Table 3 of Annex II. The grades and their market access implications are:
| Grade | Recyclability performance | Market Access |
|---|---|---|
| A | 95% or higher | Permitted |
| B | 80% or higher | Permitted |
| C | 70% or higher | Permitted until 1 January 2038 |
| Below 70% | Technically non-recyclable | Prohibited from 1 January 2030 at the earliest |
From 1 January 2030 at the earliest: only packaging recyclable within grades A, B or C may be placed on the EU market. The date is later if the Commission's design-for-recycling delegated acts enter into force after 1 January 2028, because the rule applies 24 months after them. It applies irrespective of recycled content: packaging may meet recycled content requirements and still be prohibited if it is not recyclable.
From 1 January 2035 at the earliest: packaging must also be recycled at scale, assessed under a methodology the Commission must set in implementing acts (Art. 6(2) and (5)).
From 1 January 2038: Only grades A and B permitted.
The manufacturer assesses recyclability on the basis of the Commission's delegated acts on design-for-recycling criteria, due by 1 January 2028, and its implementing acts on the recycled-at-scale assessment (Art. 6(3) to (5)) (Regulation (EU) 2025/40).
Mandatory Recycled Content for Plastic Packaging
PPWR establishes mandatory minimum recycled content requirements specifically for plastic packaging. These thresholds phase in from 2030:
From 1 January 2030 at the earliest, any plastic part of packaging must contain a minimum share of recycled content recovered from post-consumer plastic waste, calculated as an average per manufacturing plant and year. Article 7(1) sets the percentages: 30% for contact-sensitive packaging made mainly of PET, 10% for contact-sensitive packaging made of other plastics, 30% for single-use plastic beverage bottles and 35% for other plastic packaging. The date is later if the Commission's implementing act on the calculation method, due by 31 December 2026, enters into force after 1 January 2027.
From 1 January 2040 the minimums rise to 50%, 25%, 65% and 65% respectively (Art. 7(2)) (Regulation (EU) 2025/40).
Labelling Requirements
Under Article 12(1), packaging placed on the EU market must carry a harmonised, pictogram-based label with information on its material composition, to help consumers sort it. The Commission's implementing acts will set the label format and the digital-marking method. The label applies from 12 August 2028 or 24 months after those acts enter into force, whichever is later. The acts were due by 12 August 2026 and had not been published in the Official Journal as of 9 October 2026, so the label will apply later than 12 August 2028 (Regulation (EU) 2025/40, Art. 12).
Until then, companies should follow existing national labelling rules where they apply, and plan for the harmonised EU format to replace them once it applies.
The Broader PPWR Package
These 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 (transport packaging including for e-commerce, grouped packaging and beverages). Targets phase in from 2030 (Art. 29)
- Packaging minimisation requirements: From 1 January 2030, packaging weight and volume must be reduced to the minimum necessary (Art. 10). Grouped, transport and e-commerce packaging may have an empty space ratio of at most 50%, from 1 January 2030 at the earliest, calculated under a method the Commission must set in implementing acts (Art. 24)
- Extended Producer Responsibility: PPWR builds on existing national EPR schemes, with producer fees modulated by recyclability grade and, optionally, by recycled content (Art. 6 and Art. 7(7))
Practical Implications for Supply Chain Managers
For companies placing packaged products on the EU market from August 2026:
- Track the Commission's design-for-recycling delegated acts, due by 1 January 2028. Recyclability grades will be assessed against them, so they cannot be assessed formally yet
- If your products will carry a DPP under ESPR or other EU law, plan for that passport and its single data carrier to provide the required packaging information as well (Art. 12(5) and recital 70)
- Audit plastic packaging for recycled content ahead of the 2030 minimums, which are calculated as an average per manufacturing plant and year (Art. 7(1))
For companies with products not subject to DPP requirements: the PPWR does not require a packaging DPP. Packaging information is provided through the labels and data carriers set out in Article 12.
Sources
- Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation), including Article 6 and Annex II (recyclability grades), Article 7 (recycled content), and Article 12 and recital 70 (labelling and data carriers), 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