EU Packaging and Packaging Waste Regulation (PPWR): What companies need to know

The EU Packaging Regulation, known as the PPWR or Packaging and Packaging Waste Regulation, fundamentally changes the regulatory requirements for packaging. It affects not only packaging manufacturers, but also brand owners, importers, distributors, online retailers, marketplaces, fulfillment service providers and companies that fill packaging or place packaging on the market.

Important: the PPWR is not an EU directive, but a directly applicable EU regulation. It entered into force on February 11, 2025 and will generally apply from August 12, 2026 to all companies in scope. However, individual obligations will apply at later deadlines, particularly from 2028, 2030 and 2035. The previous Packaging Directive 94/62/EC will largely be replaced.
 

Why the PPWR matters for companies

The PPWR has a clear objective: packaging in the EU should be reduced, made more recyclable, reused more often and increasingly produced from recycled content. This is driven by the high level of resource consumption caused by packaging. According to the European Commission, packaging accounts for around 40% of plastics used in the EU; in 2022, an average of 186.5 kg of packaging waste was generated per person.

For companies, this means that packaging compliance is becoming a key issue for market access, product design, procurement, supply chain management, data quality and reporting obligations. Any company placing packaging on the EU market will need to provide much more precise evidence of what packaging is made of, how it is designed, whether it is recyclable, what recycled content it contains and who is responsible in each Member State.
 

Who is affected by the EU Packaging Regulation?

The PPWR applies to all packaging, regardless of material, sector or origin, including imported packaging and packaged products. This includes sales packaging, grouped packaging, transport packaging, e-commerce packaging, service packaging and reusable packaging.

All companies that make available, import, distribute, fill, sell or place packaging or packaged products on the EU market are affected.

This is particularly relevant for companies such as:

• Packaging manufacturers and converters
• Brand owners and fillers
• Importers of packaged goods
• Wholesalers and retailers
• Online retailers and marketplaces
• Fulfillment service providers
• Restaurants, hotels and takeaway providers
• Companies with private-label products
• Producers within the meaning of extended producer responsibility, or EPR

The European Commission clarifies in its guidance that the “manufacturer” is not necessarily the physical producer of the packaging. For sales packaging or grouped packaging, depending on the specific setup, the filler, brand owner or a company that distributes packaging under its own name may also be considered the manufacturer. This must be distinguished from the “producer” under EPR rules, meaning the company responsible for registration, financing and reporting in a Member State.
 

Key PPWR obligations at a glance

1. Recyclability becomes a market access requirement

All packaging placed on the EU market must be recyclable in the future. The general obligation applies from the PPWR application date on August 12, 2026. From 2030, the requirements will become significantly more specific. Packaging must be assessed according to design-for-recycling criteria. From 2035, an additional assessment will be required to determine whether packaging is actually recycled at scale.

From 2030, packaging may only be placed on the market if it meets certain recyclability performance grades. From 2038, the system will become stricter. At that point, only packaging with a high recyclability grade is expected to be permitted.
 

2. Minimum recycled content targets for plastic packaging

The PPWR introduces mandatory minimum recycled content targets for many types of plastic packaging. From 2030, the following targets will apply, among others:

• 30% for contact-sensitive PET packaging, excluding single-use beverage bottles
• 10% for other contact-sensitive plastic packaging, excluding single-use beverage bottles
• 30% for single-use plastic beverage bottles
• 35% for other plastic packaging

From 2040, the targets will increase significantly, including to 50%, 25% and 65%, depending on the packaging category.

Exemptions exist, for example for certain medical packaging, medicinal product packaging, packaging for dangerous goods and certain food-law-sensitive applications. However, the European Commission’s guidance emphasizes that companies must document exemptions in a robust and verifiable way, for example in the technical documentation.
 

3. PFAS restrictions for food contact packaging

One particularly important deadline concerns PFAS in food contact packaging. From August 12, 2026, food contact packaging must not exceed certain PFAS limit values. The guidance refers, among other things, to limit values for targeted PFAS, the sum of certain PFAS and PFAS including polymeric PFAS.

Crucial for implementation: according to the current guidance, there is no general sell-off period for PFAS-related packaging placed on the market only after August 12, 2026. Packaging that was lawfully placed on the market before that date may remain on the market. However, any new placement on the market must be compliant from the deadline onward.
 

4. Packaging minimization and empty space limits

The PPWR requires companies to reduce packaging to the minimum necessary. A particularly relevant requirement is the planned limitation of empty space in grouped, transport and e-commerce packaging. From 2030, the empty space ratio for these packaging types may generally not exceed 50%. Filling materials such as paper padding, air cushions or foam are considered empty space.

For e-commerce companies, this is a key area of action. Standard box sizes, automated packaging processes and returns logistics should be reviewed in good time.
 

5. Bans on certain single-use packaging from 2030

From January 1, 2030, certain packaging formats listed in Annex V of the PPWR may no longer be placed on the market. These include certain single-use plastic packaging formats, for example in areas such as grouped sales packaging, food and beverage packaging for out-of-home consumption and very small portion packaging in specific applications.

Companies should not only check whether individual packaging formats are affected, but also whether their business models rely on formats that may need to be restricted, replaced or redesigned in the future.
 

6. New packaging labeling requirements

The PPWR introduces harmonized labeling requirements. In the future, packaging should provide clearer information on the materials it contains and how it should be disposed of correctly. For certain packaging types, additional information will be required, for example on reusability, deposit return systems or substances of concern via digital labeling.

The specific labeling requirements still depend on implementing acts. According to its implementation overview, the European Commission is working, among other things, on an implementing act for packaging labeling.
 

7. Reuse, refill and returnable packaging obligations

The PPWR includes requirements on reuse, refilling and reuse targets. These are particularly relevant for transport packaging, grouped packaging, beverage packaging and takeaway models. From 2030, reuse targets will apply to certain transport and sales packaging; quotas are also planned for beverage packaging.

For takeaway services, the PPWR provides that end customers must be able to use their own containers. Companies must take hygiene requirements into account and may reject containers that are unsuitable or unhygienic.

Currently important: in February 2026, the European Commission adopted a delegated act on exemptions for certain pallet wrappings and strapping bands in connection with 100% reuse targets. This shows that the detailed PPWR requirements are still being further specified.
 

8. EPR, registration and reporting

Extended producer responsibility remains a core area of packaging regulation. Companies that make packaging available in a Member State for the first time must register there and comply with reporting obligations. Without registration, packaging may no longer be made available in the respective Member State. Simplified reporting obligations are planned for smaller quantities.

Online marketplaces and fulfillment service providers will also be more closely involved. They must obtain certain registration information or self-declarations from producers and respond to unclear or incorrect information.
 

Key PPWR timeline for companies

The PPWR will become effective in stages and introduces several implementation deadlines for companies. The following overview shows the most important dates, from entry into force and the start of application to planned specifications and the key target years 2030, 2035 and 2040:

The European Commission points out that numerous delegated acts, implementing acts, standards and guidelines will follow in the coming years. Companies should therefore not treat the PPWR as a one-off compliance project, but as an ongoing transformation program for packaging.
 

PPWR checklist: What companies should do now

For many companies, the PPWR will not only become relevant in 2030. Some requirements apply much earlier, while others require long lead times, for example in packaging design, supplier coordination, data processes or national EPR obligations. The following checklist highlights key action areas for preparation:

• Map the packaging portfolio: analyze packaging portfolios early by material, format, colors, labels, adhesives, barriers, additives and sortability.
• Clarify roles: assess whether the company is a manufacturer, importer, distributor, producer or holds several roles at the same time under EPR rules.
• Prioritize PFAS risks: review food contact packaging in particular at an early stage, as the PFAS deadline already applies from August 12, 2026.
• Assess recyclability: analyze packaging based on design-for-recycling criteria, material combinations, labels, adhesives, barriers and sortability.
• Build a recycled content strategy: prepare availability, quality, supply contracts and evidence management for recycled plastics.
• Optimize e-commerce packaging: adapt empty space, box sizes, filling materials and automation to the upcoming requirements.
• Prepare labeling: plan artwork processes, data sources, digital labeling and packaging changes early.
• Review EPR compliance: update registration, quantity reporting, authorized representatives and national requirements for each Member State.
• Establish regulatory monitoring: regularly review FAQ, guidance, delegated acts and implementing acts.
   

Conclusion: The PPWR is both a compliance and packaging design challenge

The PPWR will shape packaging decisions much more strongly in the coming years – not only in legal departments, but also in procurement, product development, logistics, sustainability and sales. Any company placing packaging on the EU market will need to know more precisely which materials are used, how recyclable the packaging is, which recycled content targets can be achieved and what role the company plays in each Member State.

For companies, it is therefore worth taking an early and structured look at their packaging portfolio. While many requirements only apply from 2030 or later, the necessary adjustments begin much earlier: with supplier data, technical evidence, packaging designs, EPR processes and internal responsibilities. The PPWR is therefore less a single compliance deadline and more a long-term transformation process for packaging in the EU.