On February 11, 2025, EU Regulation 2025/40 on Packaging and Packaging Waste (PPWR) officially entered into force, replacing the previous Packaging and Packaging Waste Directive (94/62/EC). The majority of the regulation’s provisions will become applicable from August 12, 2026.
The regulation is designed to significantly reduce packaging waste, encourage the use of reusable and recyclable packaging, and support the European Union’s transition toward a circular economy. It addresses the entire life cycle of packaging, including design, manufacturing, market placement, and end-of-life management such as collection and recycling.
The EU PPWR applies to all types of packaging, regardless of the material used, as well as all packaging waste. This includes packaging used across various sectors such as industrial manufacturing, retail and distribution, offices, services, and households. The regulation also applies to packaging waste generated from these sources.
Stakeholders required to comply with the regulation include manufacturers, packaging and packaging material suppliers, authorized representatives, importers, distributors, fulfillment service providers, and packaging waste management operators, all of whom must meet their respective obligations under the regulatory framework.
Sustainability Requirements for Packaging
1. Strict Restrictions on Hazardous Substances
The total concentration of lead, cadmium, mercury, and hexavalent chromium present in packaging materials or packaging components must not exceed 100 mg/kg.
Additionally, from August 12, 2026, food-contact packaging containing per- and polyfluoroalkyl substances (PFAS) above specified threshold levels will be prohibited from being placed on the EU market.
2. Mandatory Use of Recyclable Packaging
All packaging placed on the EU market must be recyclable. Manufacturers are required to evaluate the recyclability of packaging according to the criteria defined in the regulation and assign a recyclability performance grade (A, B, or C).
If the recyclability performance score of a packaging unit falls below 70%, it will be considered technically non-recyclable, and restrictions may apply to its placement on the market.
3. Minimum Recycled Content Requirements for Plastic Packaging
Plastic packaging components placed on the market must contain a minimum proportion of post-consumer recycled plastic content. This requirement is calculated as an annual average for each manufacturing facility, ensuring that manufacturers incorporate recycled materials into plastic packaging production.
|
Packaging Type |
2030 |
2040 |
|
Contact-sensitive packaging with PET as main component (excluding single-use plastic beverage bottles) |
30% |
50% |
|
Non-PET contact-sensitive plastic packaging (excluding single-use plastic beverage bottles) |
10% |
25% |
|
Single-use plastic beverage bottles |
30% |
65% |
|
Other plastic packaging |
35% |
65% |
Note: Packaging used for certain medical devices, medicinal products, compostable materials, dangerous goods, infant-specific products, veterinary medicinal products, and packaging that could pose a risk to human health is exempt from these requirements.
4. Packaging Minimization
By January 1, 2030, manufacturers and importers must ensure that packaging placed on the market is reduced to the minimum weight and volume necessary to maintain its functionality, while considering the packaging’s shape and materials.
Packaging designed to artificially increase the perceived product size or volume—such as packaging with double walls, false bottoms, or unnecessary layers—will not be permitted on the market.
5. Reusable Packaging
The regulation promotes the use of reusable packaging systems.
For example, starting January 1, 2030, economic operators using transport or sales packaging, including e-commerce distribution within the EU, must ensure that at least 40% of such packaging is reusable, provided it meets the specified regulatory requirements.
This target will increase to a minimum of 70% by January 1, 2040.
Labeling, Marking, and Information Requirements
From August 12, 2028, all packaging placed on the market must include a harmonized label that provides information about the composition of packaging materials, enabling consumers to properly sort waste for recycling.
These labels must use clear and easily understandable pictograms, ensuring accessibility, including for individuals with disabilities.
Reusable packaging must also display a label indicating that it is reusable. In addition, information about reuse systems and collection points must be provided digitally, for example through QR codes.
Harmonized labels must also be clearly affixed, printed, or engraved on waste containers in a manner that is visible, legible, and durable.
Extended Producer Responsibility (EPR)
Extended Producer Responsibility (EPR) is a key environmental policy framework within the EU. It requires producers—any natural or legal person involved in the development, manufacturing, processing, sale, handling, or import of products—to take responsibility for the environmental impacts of their products throughout the product lifecycle.
Under EPR, producers may be required to:
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Accept the return of used products and associated waste
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Ensure proper waste management and recycling
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Assume financial responsibility for waste collection and treatment
The Packaging and Packaging Waste Regulation (PPWR) requires each EU Member State’s registration authority to provide links to the producer registration authorities of other Member States, enabling producers or authorized representatives to register for EPR obligations across the EU.
Producers must submit a registration application to the competent authority in the Member State where packaging or packaged products are first placed on the market. Registration is also required when packaged products are opened in situations where the final user is not directly involved.
