EU Packaging and Packaging Waste Regulation (PPWR): what businesses need to understand as the new framework takes effect

The EU’s Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has applied across the EU since 12 August 2026.

However, 12 August was not a single compliance deadline for everything contained in the Regulation.

PPWR introduces a phased programme of change affecting packaging design, recyclability, recycled content, labelling, reuse and refill, chemicals, producer responsibility and the information that needs to move through supply chains.

Some requirements already apply. Others take effect from 2030, 2035 and beyond, while important elements of the implementation framework continue to be developed through secondary legislation.

For businesses, the challenge is therefore to understand what applies now, what is coming next and where further regulatory detail is needed before final decisions can be made.

From adoption to implementation

Regulation (EU) 2025/40 was published in the Official Journal of the European Union on 22 January 2025 and entered into force on 11 February 2025. It became applicable from 12 August 2026.

The Regulation replaces the previous Packaging and Packaging Waste Directive and establishes a directly applicable EU framework covering packaging and packaging waste.

Its scope is broad. PPWR affects packaging across its lifecycle and introduces requirements relating to areas including:

• substances in packaging;
• recyclability;
• minimum recycled content in plastic packaging;
• packaging minimisation;
• reuse and refill;
• labelling and consumer information;
• conformity assessment and technical documentation; and
• Extended Producer Responsibility (EPR).

The timetable is equally important. Some provisions apply now, while others are linked to future dates or to the adoption of delegated and implementing acts.

This means businesses should avoid treating PPWR as either something that was completed on 12 August 2026 or something that can simply be left until 2030.

12 August 2026: what applies now?

The application of PPWR from 12 August 2026 brought a number of requirements into the current compliance framework.

One important example is the overarching requirement under Article 6(1) that all packaging placed on the market must be recyclable.

However, this needs to be distinguished from the more detailed design-for-recycling requirements that follow later. These apply from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. The criteria and methodologies used to assess packaging against those requirements are being developed at EU level.

PPWR also introduces conformity assessment and documentation requirements.

Manufacturers are required to carry out the applicable conformity assessment procedure and draw up technical documentation before placing packaging on the market. Where conformity has been demonstrated, an EU declaration of conformity must be prepared.

Technical documentation must generally be retained for five years after single-use packaging has been placed on the market and for ten years for reusable packaging.

Suppliers of packaging or packaging materials also have a role. They must provide manufacturers with the information and documentation needed for manufacturers to demonstrate the conformity of the packaging.

This means PPWR compliance is not solely about changing packaging. For many organisations, it will also involve understanding where regulatory information sits within the supply chain and whether it can be accessed when required.

Recyclability: important changes from 2030 and 2035

PPWR introduces a progressively more structured approach to recyclability.

From 1 January 2030, or 24 months after the relevant delegated acts enter into force if that is later, packaging will need to comply with detailed design-for-recycling requirements.

Packaging will be assessed against recyclability performance grades. Under the framework set out in PPWR, Grade A represents recyclability of at least 95% by weight, Grade B at least 80% and Grade C at least 70%.

From 1 January 2030, or 24 months after the relevant delegated acts enter into force if that is later, packaging falling below Grade C will not meet the recyclability performance requirements for placing on the market.

A further stage follows from 2035. PPWR introduces the requirement for packaging to be recyclable at scale. The recycled-at-scale requirement applies from 1 January 2035 or five years after the relevant implementing acts enter into force, whichever is later.

This is an important distinction.

A packaging format being technically capable of recycling does not necessarily mean that it will satisfy the complete PPWR recyclability framework in future.

For organisations making packaging-design or material decisions now, particularly where development cycles are long, understanding these future criteria could therefore be important even before the requirements formally apply.

Minimum recycled content in plastic packaging

PPWR also establishes minimum levels of recycled content for plastic packaging.

The first set of targets applies from 1 January 2030, or three years after the relevant implementing act enters into force if that date is later.

The Regulation sets minimum recycled-content levels of:

• 30% for contact-sensitive packaging where PET is the major component, excluding single-use plastic beverage bottles;
• 10% for contact-sensitive packaging made from plastics other than PET, excluding single-use plastic beverage bottles;
• 30% for single-use plastic beverage bottles; and
• 35% for other plastic packaging.

The percentages are calculated using recycled content recovered from post-consumer plastic waste, subject to the detailed provisions and exemptions in the Regulation.

The targets increase further in 2040. They rise to 50% for contact-sensitive PET packaging, 25% for other contact-sensitive plastic packaging and 65% for single-use plastic beverage bottles and other plastic packaging.

For businesses, however, the percentages are only part of the issue.

Organisations will also need to understand how recycled content is calculated and verified and what information will be needed to substantiate compliance.

This could make the availability and quality of supplier information increasingly important, particularly for organisations operating complex or international supply chains.

PFAS: an immediate chemicals requirement

PPWR also has a significant chemicals dimension.

From 12 August 2026, food-contact packaging containing per- and polyfluoroalkyl substances (PFAS) at or above specified concentration limits cannot be placed on the EU market, subject to the provisions of other applicable EU legislation.

PPWR establishes three thresholds:

• 25 ppb for any PFAS measured using targeted PFAS analysis, excluding polymeric PFAS from quantification;
• 250 ppb for the sum of PFAS measured using targeted analysis, where applicable with prior degradation of precursors, excluding polymeric PFAS from quantification; and
• 50 ppm for PFAS including polymeric PFAS, alongside additional evidence requirements where total fluorine exceeds 50 mg/kg.

There is currently no harmonised EU testing methodology specifically for the PPWR PFAS limits. The European Commission has issued guidance to support businesses and enforcement authorities in applying the requirements.

The timing is also important for existing stock.

The Commission has clarified that PPWR does not provide a transitional period allowing stocks of non-compliant food-contact packaging produced before 12 August 2026 to continue to be placed on the market. Packaging placed on the market after that date must comply with the PFAS limits.

Food-contact packaging that was already placed on the market before 12 August 2026 does not need to be withdrawn solely because of the new PPWR PFAS provision.

This is a good example of why PPWR cannot be considered solely as waste or sustainability legislation. Depending on the packaging involved, compliance may require input from packaging, procurement, regulatory, sustainability and chemicals specialists.

Packaging information is becoming increasingly important

A common thread running through many of the PPWR requirements is information.

Businesses may need information about materials and composition, recycled content, substances, recyclability and the identity and responsibilities of different actors within the supply chain.

The Regulation’s conformity framework means that this information is not simply useful background. In some cases, it forms part of the evidence needed to demonstrate that packaging complies with the applicable requirements.

Businesses may therefore benefit from considering:

• what information they currently hold for each packaging format;
• what information is held by suppliers;
• whether supplier documentation is sufficiently detailed;
• who is responsible for maintaining technical documentation;
• whether evidence can be retrieved efficiently; and
• whether existing procurement and supplier-management processes will support future PPWR requirements.

For some organisations, these information flows could prove as important to implementation as physical changes to the packaging itself.

Extended Producer Responsibility

PPWR also establishes a framework for Extended Producer Responsibility (EPR).

Depending on their activities, producers placing packaging or packaged products on the market may face registration, reporting and financial obligations in Member States where packaging is made available.

This is particularly relevant for organisations operating across several EU markets, where understanding the applicable producer role and national arrangements will be important.

Further implementation detail around registration and reporting is being developed. Businesses should therefore monitor these developments alongside the requirements already established in PPWR.

Labelling and consumer information

PPWR will also introduce harmonised labelling requirements intended to help consumers understand the material composition of packaging and how it should be sorted.

These requirements do not all apply from August 2026.

For packaging generally, the harmonised labelling requirement is due to apply from 12 August 2028 or 24 months after the relevant implementing act enters into force, whichever is later.

This is another example of why PPWR implementation needs to be viewed as a timeline rather than a single compliance event.

For businesses, future labelling requirements may interact with packaging redesign cycles, artwork changes and existing product information requirements, making advance planning useful even where the final implementation date remains some way off.

Key PPWR dates

11 February 2025 – Regulation (EU) 2025/40 entered into force.

12 August 2026 – PPWR became applicable across the EU. Requirements including the general recyclability requirement and the PFAS limits for food-contact packaging apply from this date.

12 August 2028 or later – harmonised packaging labelling requirements begin to apply, subject to the timing of the relevant implementing acts.

2030 or later – detailed design-for-recycling and minimum recycled-content requirements are scheduled to begin, subject to the timing provisions associated with the relevant secondary legislation.

2035 or later – the recyclability framework develops further to include whether packaging is recycled at scale, subject to the timing of the relevant implementing acts.

2040 – higher minimum recycled-content targets apply to plastic packaging.

A regulatory framework that will continue to develop

Although PPWR now applies, the implementation framework is not complete.

Further delegated and implementing acts are important to areas including design-for-recycling criteria, recycled-at-scale methodologies, recycled-content calculation and verification, labelling and EPR registration and reporting.

This creates a balance for businesses.

Waiting until every element has been finalised could leave limited time to make changes where packaging redesign, supplier engagement, procurement or data collection is required.

At the same time, organisations should avoid making firm decisions based on assumptions about requirements where the detailed rules have not yet been finalised.

A proportionate approach is to separate PPWR implementation into three categories:

1. requirements that apply now and need to be addressed;
2. future requirements where businesses can already assess exposure and prepare; and
3. areas where further regulatory detail needs to be monitored before final decisions are made.

What should organisations be doing now?

The appropriate response will depend on the organisation, the packaging involved and its position in the supply chain.

However, useful preparatory work could include mapping packaging portfolios and packaging types, establishing economic-operator roles and responsibilities, reviewing supplier information, identifying evidence gaps and considering which packaging formats could be most affected by future recyclability and recycled-content requirements.

For food-contact packaging, the PFAS restrictions require more immediate attention.

Organisations operating across several Member States should also consider how the developing EPR framework may affect registration, reporting and other responsibilities.

The objective should not be to predict requirements that have not yet been finalised. It should be to establish a clear picture of current exposure, identify actions that can reasonably be taken now and monitor the regulatory developments that will determine later compliance decisions.

How RPA can support organisations with the Packaging and Packaging Waste Regulation (PPWR)

PPWR brings together regulatory, technical, environmental and economic considerations and interacts with areas that organisations may previously have managed separately.

RPA’s work spans chemicals and product regulation, circular economy and waste policy, regulatory analysis, socio-economic analysis and the assessment of regulatory impacts on businesses and supply chains.

We can support organisations in understanding how PPWR applies to their products and packaging, assessing regulatory and evidence requirements, identifying potential gaps and considering the implications of emerging secondary legislation.

Our combination of chemicals, environmental, economic and regulatory expertise is particularly relevant where PPWR requirements intersect with wider product, chemicals and sustainability obligations.

For organisations assessing what the Packaging and Packaging Waste Regulation means for their products, packaging or supply chains, please contact RPA to discuss the issues relevant to your business.

Further information

Regulation (EU) 2025/40 on packaging and packaging waste
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040

European Commission – Packaging and Packaging Waste Regulation
https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en

European Commission guidance on implementation of Regulation (EU) 2025/40
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026XC03084