PPWR: The EU’s new rules on packaging

Did you know that 40% of plastics and 50% of paper in the European Union are used for packaging, and that packaging accounts for 36% of municipal solid waste?

This information was shared in the Official Journal of the European Union and highlights the scale of the issue the new Packaging and Packaging Waste Regulation (PPWR) aims to address.

The PPWR (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 aims to speed up the EU's transition to a circular economy by covering the entire life cycle of packaging and replaces the Packaging and Packaging Waste Directive 94/62/EC (PPWD).

On 12 August 2026, 18 months after the PPWR entered into force, the regulation begins to generally apply. This means it’s the deadline for businesses to comply with the requirements that apply from this date. Some further requirements of the PPWR will be introduced at later dates.

According to the European Commission, “The rules aim to minimise the quantities of packaging and waste generated while lowering the use of primary raw materials and fostering the transition to a circular, sustainable and competitive economy.”

Within this regulation, there are rules on packaging labelling, recyclability, the percentage of recycled content within packaging, reusable and refillable packaging, PFAS and heavy metals, packaging minimisation and restrictions on certain single-use packaging formats.

You can read the full official document here: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste

Or you can read the official summary of the document here: Summary of: Regulation (EU) 2025/40 on packaging and packaging waste

This is a regulation, not just a directive, meaning that the same rules apply across all EU Member States. The PPWR is intended to harmonise packaging rules across the EU, creating a single set of rules rather than each country having to introduce its own version of the legislation.

While there are a growing number of purpose-driven businesses that are already taking action on the life cycle of their packaging, we are still fighting against an increasing global population and a world where the demand for products, and the packaging they come in, continues to grow. So while there are businesses doing the right thing, the gap is still increasing. The PPWR aims to help close that gap.

Businesses directly or indirectly involved in placing packaging or packaged products on the EU market need to understand this regulation thoroughly, including the role and responsibilities they have and what needs to be done by what date.

While all businesses must comply with the requirements that apply to them, understanding exactly what applies to your business is the more complex bit.

The PPWR places responsibilities all across the supply chain, with significant design and conformity responsibilities falling on the manufacturer: the business that makes the packaging or has it made and sells it under their own name or trademark.

But what’s important for all businesses to know about this regulation is that the responsibility does not end with the manufacturer; different businesses along the chain have their own obligations. This includes manufacturers, importers, distributors and fulfilment service providers, all with specific responsibilities depending on their role. 

Here’s a useful article from Coolset to understand a business's role and responsibility in PPWR - PPWR supply chain roles explained: manufacturer, importer, distributor, and producer.

Once you understand the role your business holds within the PPWR, you then need to understand what steps you need to take to comply. Some obligations apply from 12 August 2026, while others become mandatory at a later date.

These are some of the major rules that apply from 12 August 2026:

• Limits on heavy metals in packaging, and restrictions on PFAS in food-contact packaging.

• EU Declaration of Conformity (DoC) and supporting documentation for manufacturers. Before placing packaging on the market, manufacturers must complete the required checks and prepare an EU Declaration of Conformity.

• Manufacturer identification on packaging, or via a QR code or other data carrier, with importer identification also required where applicable.

• Extended Producer Responsibility (EPR) requirements, including registration in each relevant Member State. EPR fees will apply under the relevant national schemes, so understanding the requirements can help ensure businesses don't pay more than necessary.

• Requirements for businesses using reusable packaging to have a reuse system in place.

There is no general grace period for these rules after this date. However, packaging that was already placed on the market before a particular requirement was introduced may be allowed to be sold. Businesses should check the rules that apply to their particular packaging rather than assuming that all existing stock is treated in the same way.

Following these initial rules, there will be further obligations introduced over the coming years. These will include:

• Packaging will need to meet recyclability performance grades A, B or C to be placed on the market. From 2038, only grades A and B will be allowed.

• Packaging must be designed to use the minimum weight and volume necessary.

• Maximum empty-space requirements.

• Minimum recycled content targets for plastic packaging, including requirements around how recycled content is calculated and verified.

• Restrictions on certain packaging formats and uses, including certain single-use options.

• Material-composition labelling to help consumers identify how packaging should be sorted.

• Labelling requirements for reusable packaging, including information about reusability, reuse systems and collection points provided through a QR code or other digital data carrier.

As the PPWR begins to apply, there may be further amendments and updates to guidance; it’s important that all businesses impacted by packaging regulations follow the requirements closely. 

As a sustainability agency, we support any regulations that bring us closer to a low-carbon circular economy.

Here’s the European Commission’s FAQ, most recently updated on 3 August 2026, which answers a lot of questions that will help businesses understand their position and responsibilities within the PPWR: Packaging and Packaging Waste Regulation (PPWR) Frequently asked questions