PPWR — Packaging and Packaging Waste Regulation

Overview

The Packaging and Packaging Waste Regulation (PPWR) — Regulation (EU) 2025/40 — replaces the Packaging Directive 94/62/EC with directly applicable EU-wide rules on packaging sustainability, labelling, recyclability, and reuse.

Legal basis

• Proposed: 30 November 2022
• Adopted: December 2024
• Entered into force: 11 February 2025
• General application date: 12 August 2026
• Replaces: Packaging Directive 94/62/EC
• Commission guidance: Commission Notice C/2026/3084, a guidance document on the Regulation published in the Official Journal on 10 June 2026. It is non-binding and does not replace, add to or amend the Regulation (EUR-Lex)

Key requirements and when they apply

• The Regulation applies from 12 August 2026 (Art. 71). From that date, food-contact packaging may not be placed on the market if it contains PFAS at or above the limit values set in Art. 5(5)
• The harmonised label on material composition is not yet required. Under Art. 12(1) it applies from 12 August 2028 or 24 months after the Commission's implementing acts on the label and on digital marking (Art. 12(6) and (7)) enter into force, whichever is later. Those 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)
• Recyclability applies later. From 1 January 2030 at the earliest, packaging must be designed for recycling and fall within recyclability grades A, B or C; from 1 January 2035 at the earliest, it must also be recycled at scale (Art. 6)
• Re-use targets apply from 1 January 2030 (Art. 29) (Regulation (EU) 2025/40)

Recyclability grades

Date	Requirement
After 12 August 2028 (not yet set)	Harmonised label on material composition (Art. 12)
1 January 2030 at the earliest	Only grades A-C may be marketed; minimum recycled content for plastic
1 January 2035 at the earliest	Recyclability must be demonstrated at scale
January 2038	Only grades A and B permitted

Reuse targets (selected)

• Transport packaging, including for e-commerce, in the listed formats (pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums, canisters, and pallet wrapping or straps): at least 40% reusable within a re-use system from 1 January 2030; operators must endeavour to reach 70% from 1 January 2040 (Art. 29(1)). Cardboard boxes, dangerous-goods packaging, custom packaging for large machinery and flexible food-contact transport packaging are exempt (Art. 29(4))
• Grouped packaging in the form of boxes, excluding cardboard: at least 10% from 1 January 2030; endeavour to reach 25% from 1 January 2040 (Art. 29(5))
• Alcoholic and non-alcoholic beverages sold by final distributors: at least 10% in reusable packaging from 1 January 2030; endeavour to reach 40% from 1 January 2040. Milk, wine and spirits are among the exclusions (Art. 29(6) and (7))

DPP integration

The PPWR sets a single data carrier rule, not a packaging DPP. Where EU law requires information on the packaged product to be provided via a data carrier, one data carrier must provide both the information required for the packaged product and the information required for the packaging, and the two must be easily distinguishable (Art. 12(5)). Recital 70 adds that where the packaged product is covered by ESPR or other EU law requiring a digital product passport, that passport should also be used to provide the relevant packaging information (Regulation (EU) 2025/40).

The PPWR does not create a separate DPP for packaging and does not list DPP data fields for packaging.

Penalties

Member States set penalties and must lay down the rules by 12 February 2027. Penalties must be effective, proportionate and dissuasive, and penalties for breaches of Articles 24 to 29 must include administrative fines (Art. 68). No EU-wide fine ceiling is specified.

Who is affected

All companies placing packaging on the EU market bear obligations — there is no size threshold:

• Manufacturers of packaging (primary obligation for design, recyclability, and labelling compliance)
• Converters and fillers — companies that fill packaging with their products
• Importers — responsible for compliance of packaging entering the EU from outside
• Brand owners — bear EPR obligations and recycled content targets
• Retailers — must ensure products they sell use compliant packaging

Extended Producer Responsibility (EPR) obligations under Art. 45 apply from the general application date.

Key articles

Article	Subject
Art. 6	Recyclable packaging: design for recycling and grades A to C from 1 January 2030 at the earliest; recycled at scale from 1 January 2035 at the earliest; grades A and B only from 1 January 2038
Art. 7	Minimum recycled content in plastic packaging, from 1 January 2030 at the earliest
Art. 12	Labelling: harmonised label on material composition, from 12 August 2028 or 24 months after the implementing acts enter into force, whichever is later (not yet set)
Art. 45	Extended Producer Responsibility — EPR scheme obligations
Art. 12(5)	Single data carrier for the packaged product and its packaging; recital 70 points to the product's DPP where one exists
Art. 68	Penalties: national rules due by 12 February 2027

Key dates

Date	Milestone
11 February 2025	Entered into force
10 June 2026	Commission guidance document published in the Official Journal (C/2026/3084)
12 August 2026	General application of the Regulation (Art. 71)
12 August 2026	Deadline for the labelling and digital-marking implementing acts (Art. 12(6) and (7)); not published in the Official Journal as of 9 October 2026
Not yet set (after 12 August 2028)	Harmonised label applies: 24 months after those implementing acts enter into force
1 January 2030 at the earliest	Only grades A-C permitted; recycled content thresholds
1 January 2035 at the earliest	Recyclability demonstrated at scale
January 2038	Only grades A-B permitted

Source

• Regulation (EU) 2025/40 — EUR-Lex
• Commission Notice C/2026/3084: Guidance document for Regulation (EU) 2025/40, OJ of 10 June 2026: EUR-Lex