The Packaging and Packaging Waste Regulation (PPWR) was published on 11 February 2025 and entered into force on 12 August 2026. The EU regulation aims to reduce packaging waste and increase the use of recyclable materials. As a regulation, it is directly applicable and does not need to be transposed into national law. Over the coming years, it will be further specified through several delegated acts. Most of the requirements have been mandatory since August 2026. Full implementation of the PPWR is planned by 2040.
The Objectives of the PPWR – Why Was the PPWR Introduced?
The objective of the PPWR is to significantly reduce packaging consumption in the EU, improve recyclability, and strengthen the circular economy. The PPWR includes binding requirements for recycled content in plastic packaging, reusability, compostability, and labeling obligations, as well as maximum limits for PFAS and heavy metals. Furthermore, packaging and its labeling are to be harmonized more extensively across the EU. The new packaging regulation was adopted as part of the European Green Deal and forms part of the Circular Economy Action Plan. It fits into the following legislative framework.
| Legal Basis | Relevance to the PPWR |
| Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) | The central legal framework. It sets out requirements for packaging design, labeling, recyclability, recycled content, reusable packaging, reuse, and producer obligations. It applies directly in all EU Member States. |
| Waste Framework Directive 2008/98/EC | Establishes the general principles of waste legislation (e.g. the waste hierarchy and extended producer responsibility). The PPWR builds on these principles. |
| Single-Use Plastics Directive (EU) 2019/904 (SUPD) | Contains requirements for certain single-use plastic products. The PPWR complements and amends specific provisions of this directive. |
| Regulation (EU) 2019/1020 on market surveillance | Governs market surveillance and the monitoring of compliance with PPWR requirements. |
| Packaging Act (VerpackG, Germany) | National implementation and supplementary legislation, particularly regarding registration (LUCID), participation in dual systems, and take-back obligations. It remains in force insofar as its provisions are not superseded or amended by the PPWR. |
What Are the Key Requirements of the PPWR?
Even before the adoption of the PPWR, regulations governing packaging already existed at both EU and Member State level. However, the entry into force of the PPWR introduces significant new requirements for manufacturers and other economic operators.
- All packaging must be recyclable by no later than 2030.
- Minimum recycled content requirements for plastic packaging will become mandatory.
- Stricter requirements for secondary packaging, including the reduction of empty space and the prohibition of certain unnecessary packaging types.
- Promotion of reusable packaging systems through higher deployment targets and technical requirements for reusability.
- Material restrictions, including limitations on problematic chemicals such as PFAS.
- Labeling obligations and information requirements for end consumers.
What Roles and Obligations Are Defined by the PPWR?
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) affects all economic operators that manufacture, supply, import, distribute, or provide packaging or packaged products to end users. It is therefore essential for all economic operators to clearly define and understand their respective role and the obligations associated with it.
The roles defined under the PPWR have already been in use since 2008 within the framework of CE marking obligations. A key innovation is the distinction between two primarily obligated roles: the producer and the manufacturer. In general, the obligations can be divided into technical obligations, administrative obligations, and due diligence obligations.
The PPWR distinguishes between the roles of manufacturer and producer. A manufacturer is responsible for ensuring that packaging complies with the applicable requirements of the Regulation, including the provision of technical documentation and conformity information. A producer is the economic operator that assumes extended producer responsibility obligations in a Member State, including registration, reporting, financing and participation in packaging waste management schemes. Depending on the business model and supply chain, the same legal entity may act as both manufacturer and producer.
Companies that place packaged products on the market of an EU Member State without having their own establishment in that country may be required to appoint an authorised representative for the extended producer responsibility. This representative acts on behalf of the producer with regard to certain EPR-related obligations, such as registration and compliance with national packaging waste requirements.
| Economic Operator | Definition | Legal Basis |
| Manufacturer | Designs packaging or has packaging or packaged products manufactured under its own name or trademark. | Article 3(1), No. 13, points (a)-(b), Regulation (EU) 2025/40 |
| Producer | Places packaging or packaged products on the market in an EU Member State for the first time. | Article 3(1), No. 15, points (a)-(e), Regulation (EU) 2025/40 |
| Supplier | Supplies packaging or packaging materials to producers. | Article 3(1), No. 16, Regulation (EU) 2025/40 |
| Importer | Introduces packaging from third countries into the EU. | Article 3(1), No. 17, Regulation (EU) 2025/40 |
| Distributor | Sells or otherwise makes packaging available within the EU. | Article 3(1), No. 18, Regulation (EU) 2025/40 |
| Authorized Representative | Carries out specific obligations under the PPWR on behalf of the manufacturer. | Article 3(1), No. 19, Regulation (EU) 2025/40 |
| Final Distributor | Supplies packaged products to the end consumer (e.g. through retail or e-commerce). | Article 3(1), No. 21, Regulation (EU) 2025/40 |
Deadlines and Responsibilities of the European Commission
In addition to the direct obligations imposed on companies, the PPWR provides for numerous implementation measures by the European Commission. Among other responsibilities, the Commission must establish criteria and performance grades for packaging design for recycling by 1 January 2028. By 2030, methods for assessing recyclability at industrial scale are also to be developed.
In the area of bio-based plastics, the Commission will review the state of technological development by 12 February 2028 and may subsequently submit further legislative proposals. In addition, it will gradually adopt implementing acts for the new labeling requirements and must establish a method for the digital declaration of substances of concern in packaging by 1 January 2030 at the latest.
Furthermore, by early 2027, the Commission will publish guidelines and, where appropriate, delegated acts concerning the calculation and implementation of the new reuse targets.
These measures are highly relevant for companies because many of the detailed requirements of the PPWR will only be specified through these implementing and delegated acts.
Deadlines for different economic operators in PPWR
In our article on “PPWR Exemptions for Medical Device and Pharmaceutical Companies,” we discuss additional aspects of the PPWR and explain which exemptions apply to these industries.
| Date | Topic | Legal Basis / Source |
|---|---|---|
| 11 Feb 2025 | Entry into force of the PPWR | Regulation (EU) 2025/40, Article 71. The Regulation entered into force on 11 February 2025. |
| 12 Aug 2026 | General application of the PPWR | The PPWR generally applies from 12 August 2026. |
| 12 Aug 2026 | Conformity assessment, technical documentation, Declaration of Conformity (DoC) | Manufacturer obligations and the EU Declaration of Conformity become applicable. |
| 12 Aug 2026 | Registration and core EPR obligations | Articles 44 and 45 generally become applicable. |
| 12 Feb 2028 | Reusable take-away packaging | Obligation to offer reusable packaging within a reuse system (micro-enterprises exempt). |
| 12 Feb 2028 | Requirements for certain compostable packaging | PPWR transitional provisions. |
| 1 Jan 2030 | Recycled content targets for plastic packaging (first phase) | Article 7. |
| 1 Jan 2030 | Recyclability Performance Grades (A/B/C) | Article 6. |
| 1 Jan 2030 | Packaging minimisation and additional design requirements | Article 10 and further transitional provisions. |
| 1 Jan 2035 | “Recycled at scale” requirement | Article 6. |
| 1 Jan 2038 | Minimum recyclability performance grade A or B | Article 6. |
| 1 Jan 2040 | Second phase of recycled content targets | Article 7. |
[Disclaimer]
The information provided here represents only one possible interpretation of the applicable regulations. Regulatory requirements are continuously evolving, which means that the information in this article may be incomplete or no longer fully up to date. This article does not constitute legal advice. Please refer to the official regulatory documents before making any business decisions. (Information status: September 2026)