EU PPWR: Packaging and Packaging Waste Regulation Compliance Guide

The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, establishes harmonized requirements for packaging and packaging waste placed on the European Union market. It covers packaging design, substances of concern, recyclability, recycled content, compostability, packaging minimization, labeling, reuse, and waste prevention.

The PPWR entered into force on 11 February 2025 and applies generally from 12 August 2026, with many individual requirements introduced according to later dates specified in the Regulation. It generally repealed and replaced the previous Packaging and Packaging Waste Directive 94/62/EC from 12 August 2026, subject to the transitional provisions in the Regulation.

What is the EU PPWR?

The Packaging and Packaging Waste Regulation is the EU regulation governing packaging and packaging waste throughout the packaging life cycle.

It applies broadly to packaging placed on the EU market, regardless of the material or origin.

The Regulation establishes requirements covering the manufacture and composition of packaging, its recyclability and reusability, and the management and prevention of packaging waste.

PPWR applies across packaging categories such as:

• Plastic packaging
• Paper and cardboard packaging
• Metal packaging
• Glass packaging
• Wood packaging
• Composite packaging
• Food and beverage packaging
• E-commerce packaging
• Transport packaging
• Retail and consumer packaging

The Regulation establishes compliance responsibilities across the packaging supply chain according to the activities performed and the applicable obligations.

When Does the PPWR Apply?

The PPWR entered into force on 11 February 2025 and applies generally from 12 August 2026. Individual obligations have different implementation dates.

Requirement	Key date
PPWR generally applies	12 August 2026
PFAS restrictions for food-contact packaging	12 August 2026
Compostability requirements for specified packaging	12 February 2028
Harmonized packaging labels	From 12 August 2028*
Recyclability and recycled-content requirements	From 2030*
Packaging minimization, reuse targets, and certain single-use restrictions	From 2030
Recyclability at scale	From 2035*

*The exact application date may depend on when the relevant delegated or implementing acts enter into force.

The European Commission confirmed in August 2026 that the PPWR is applicable across the EU, while several major circularity and waste-prevention obligations will take effect later.

Why was the PPWR Introduced?

Packaging represents a significant part of the EU’s material consumption and waste stream.

The PPWR creates a common regulatory framework intended to reduce packaging waste, improve recycling, increase the use of secondary raw materials, limit certain substances of concern, and improve the functioning of the EU internal market.

This creates more detailed requirements concerning how packaging is:

• Designed
• Manufactured
• Selected
• Documented
• Labeled
• Recycled
• Reused
• Placed on the EU market

Packaging associated with imported consumer goods should therefore be included within the product compliance program.

Key PPWR Requirements for Packaging

PPWR introduces several major areas of packaging compliance.

Restrictions on Substances of Concern

Article 5 establishes requirements concerning substances contained in packaging.

Packaging must be manufactured so that the presence and concentration of substances of concern in packaging materials and components are minimized.

The Regulation also maintains a combined concentration limit for four heavy metals:

• Lead
• Cadmium
• Mercury
• Hexavalent chromium

The sum of these substances generally must not exceed 100 mg/kg in packaging or packaging components, subject to the applicable provisions and exemptions.

Article 5 also establishes specific restrictions on PFAS in food-contact packaging.

PPWR PFAS Restrictions for Food-Contact Packaging

From 12 August 2026, food-contact packaging cannot be placed on the EU market when PFAS concentrations are equal to or above the limits specified in Article 5(5).

The PPWR establishes three thresholds:

PFAS measurement	PPWR limit
Any individual targeted PFAS	25 ppb
Sum of targeted PFAS	250 ppb
PFAS, including polymeric PFAS	50 ppm

Polymeric PFAS are excluded from the first two measurements.

Where total fluorine exceeds 50 mg/kg, evidence showing the amount of fluorine attributable to PFAS or non-PFAS substances must be provided to enforcement authorities upon request.

The European Commission’s 2026 guidance recommends a stepwise testing approach. Total fluorine screening may be used first. Where total fluorine exceeds 50 mg/kg, further analysis can distinguish organic fluorine from inorganic fluorine, followed by targeted PFAS analysis where necessary.

The guidance also explains that food-contact packaging placed on the market after 12 August 2026 must comply even if it was manufactured before that date. Packaging placed on the market before 12 August 2026 may remain on the market.

This requirement is particularly relevant to packaging where fluorinated substances may have been used to provide grease or moisture resistance.

Examples include:

• Fast-food wrappers
• Takeaway containers
• Bakery paper
• Pizza boxes
• Microwave popcorn bags
• Grease-resistant paper packaging

The European Commission specifically identifies these types of food packaging when explaining the PFAS restriction.

PFAS testing and material verification are important parts of food-contact packaging compliance.

PPWR Recyclability Requirements

Article 6 requires packaging placed on the EU market to be recyclable. Compliance is assessed through two elements: design for material recycling and recyclability at scale.

From 1 January 2030, or 24 months after the relevant delegated acts enter into force, whichever is later, packaging must comply with the applicable design-for-recycling criteria and recyclability performance grades.

Packaging that falls below performance grade C will generally be prohibited from the market. From 2038, packaging will generally need to achieve at least performance grade B.

Recyclability-at-scale requirements will apply from 1 January 2035 or five years after the relevant implementing acts enter into force, whichever is later.

Exemptions apply to certain packaging categories identified in Article 6.

These requirements place greater emphasis on packaging design elements such as:

• Material combinations
• Coatings
• Adhesives
• Labels
• Sleeves
• Closures
• Inks
• Additives
• Multilayer structures

These elements should be evaluated during the design stage because individual components can influence the recyclability of the complete packaging format.

Recycled-Content Requirements for Plastic Packaging

PPWR establishes minimum recycled-content requirements for certain plastic packaging.

From 1 January 2030, or three years after the relevant implementing act enters into force, whichever is later, applicable plastic packaging must contain minimum percentages of recycled material recovered from post-consumer plastic waste.

The required percentages vary according to the packaging category. Article 7 also provides exemptions for specified packaging.

The Regulation establishes additional recycled-content targets for later implementation.

Reliable supporting information should cover:

• Plastic material type
• Packaging composition
• Recycled material content
• Source of recycled material
• Supplier declarations
• Supporting documentation

Material specifications and supplier records will become increasingly important when demonstrating compliance.

Compostable Packaging Requirements

Article 9 establishes compostability requirements for specified packaging formats.

From 12 February 2028, certain permeable tea, coffee, and other beverage bags and sticky labels attached to fruit and vegetables must be compatible with industrially controlled composting conditions, including anaerobic digestion.

Member States may require additional packaging formats to be compostable under the conditions established in Article 9. Other biodegradable packaging must allow material recycling without affecting the recyclability of other waste streams.

Applicable compostable packaging must also comply with the relevant labeling requirements.

Packaging Minimization Requirements

From 1 January 2030, packaging placed on the market must be designed so that its weight and volume are reduced to the minimum necessary for its functionality.

The assessment must take account of the packaging performance criteria in Annex IV.

Packaging reviews may cover:

• Packaging dimensions
• Material thickness
• Protective components
• Empty space
• Secondary packaging
• Transport packaging
• Decorative packaging features

The objective is to reduce unnecessary packaging material while maintaining required functions such as product protection, hygiene, transportation, and information.

Empty-Space Requirements

Excessive empty space is another area addressed by the PPWR.

This requirement is particularly relevant to:

• E-commerce packaging
• Grouped packaging
• Transport packaging

From 12 February 2028, sales packaging must be designed so that empty space is reduced to the minimum necessary for packaging functionality.

From 1 January 2030, or three years after the relevant implementing act enters into force, whichever is later, the empty-space ratio for grouped packaging, transport packaging, and e-commerce packaging generally must not exceed 50%.

The relationship between the size of the product and the external packaging used to transport it should be reviewed.

Materials that may affect the empty-space calculation include:

• Air cushions
• Bubble wrap
• Foam
• Paper fillers
• Wood wool
• Polystyrene chips
• Other void-filling materials

Space filled by these materials is treated as empty space for this requirement. Applicable calculation methods, exclusions, and exemptions must also be considered.

PPWR Packaging Labeling Requirements

PPWR introduces harmonized packaging labeling intended to make waste sorting easier for consumers.

Under Article 12, packaging placed on the market will eventually need a harmonized label containing information about its material composition.

The requirement applies from 12 August 2028 or 24 months after the relevant implementing act enters into force, whichever is later.

The harmonized system is intended to help consumers understand:

• What the packaging is made from
• How it should be sorted
• How reusable packaging should be returned, where applicable

Separate labeling requirements apply to reusable packaging from 12 February 2029 or 30 months after the relevant implementing act enters into force, whichever is later.

Reusable packaging must carry a label indicating that it is reusable. Further information about the reuse system must be available through a QR code or another standardized digital data carrier.

Existing national recycling labels should be reviewed against the harmonized PPWR labeling rules and implementing measures as they become applicable.

Reuse and Refill Requirements

PPWR establishes requirements and targets intended to increase packaging reuse and refill in specified sectors and packaging formats.

From 12 February 2027, final distributors in the hotel, restaurant, and catering sector offering takeaway beverages or prepared food must allow consumers to use their own containers, subject to the conditions and exemptions in Article 32.

From 12 February 2028, they must also offer consumers the option of obtaining those products in reusable packaging within a reuse system.

Applicable reuse targets for specified packaging formats begin from 1 January 2030.

These provisions can affect:

• Transport packaging
• Grouped packaging
• Beverage packaging
• Sales packaging
• Food and beverage distribution

The applicability of reuse requirements depends on the packaging format, business activity, and available exemptions.

Reusable packaging must also satisfy criteria that allow it to complete multiple rotations within a reuse system.

Clear specifications should cover durability, cleaning where applicable, logistics, collection, and reuse processes.

Restrictions on Certain Single-Use Packaging

From 1 January 2030, Article 25 and Annex V restrict specified single-use plastic packaging formats, subject to the stated conditions and exemptions.

Affected formats include certain packaging used for:

• Grouping products at the point of sale
• Fresh fruit and vegetables
• Food and beverages consumed within hospitality premises
• Individual portions of condiments and similar products
• Toiletries in the accommodation sector
• Very lightweight plastic carrier bags

Each packaging format should be assessed to determine whether it falls within an affected category.

Packaging portfolios should be reviewed at SKU level because PPWR obligations can vary according to the material, format, use case, and product contained within the packaging.

Technical Documentation and Conformity Assessment

PPWR establishes compliance responsibilities for packaging placed on the EU market.

The applicable conformity assessment must be completed, the required technical documentation prepared, and an EU declaration of conformity drawn up before packaging is placed on the market. Required identification and contact information must also be provided.

Supporting documentation may include:

• Packaging specifications
• Material-composition information
• Supplier declarations
• Test reports
• Chemical testing results
• Recycled-content information
• Design specifications
• Supporting calculations
• Compliance records

Compliance records should confirm that the applicable conformity assessment has been completed and the required documentation prepared.

Reliable documentation from packaging and product suppliers is therefore an important part of compliance management.

How the PPWR Applies to Packaged Products

PPWR compliance covers the packaging associated with finished products placed on the EU market, including:

• Product packaging
• Retail boxes
• Plastic bags
• Inserts
• Protective materials
• Labels
• Secondary cartons
• Transport packaging

Each relevant packaging component should be considered when establishing the compliance scope.

For packaged kitchenware, for example, the materials used for the retail box, protective bag, inserts, labels, and other packaging components should be identified. The applicable PPWR requirements should then be determined for each component.

This makes packaging supply-chain documentation increasingly important.

PPWR Compliance for Food Packaging

Food packaging deserves particular attention because several regulatory frameworks may apply simultaneously.

Under PPWR, food-contact packaging must comply with the PFAS restrictions that became applicable on 12 August 2026.

Food-contact materials may also remain subject to other applicable EU food-contact legislation and EU food-contact material testing requirements.

Products that may require review include:

• Paper cups
• Food containers
• Takeaway boxes
• Wrappers
• Grease-resistant paper
• Bakery packaging
• Disposable food packaging
• Coated paperboard

The complete finished packaging material should be reviewed, including coatings, barrier layers, and surface treatments that may introduce fluorinated substances.

How to Prepare for PPWR Compliance

A structured PPWR compliance process should be established for packaging and packaged products placed on the EU market.

1. Create a Packaging Inventory

Identify all packaging components associated with each product.

Record information such as:

• Packaging type
• Material
• Weight
• Supplier
• Intended function
• Food-contact status
• Reusable or single-use status

2. Review Material Composition

Obtain material specifications and declarations from packaging suppliers.

Pay particular attention to:

• Plastics
• Coatings
• Adhesives
• Inks
• Barrier layers
• Surface treatments
• Recycled materials

3. Identify Applicable PPWR Requirements

Determine which requirements apply to each packaging format.

Consider:

• Chemical restrictions
• PFAS requirements
• Recyclability
• Recycled content
• Compostability
• Packaging minimization
• Empty space
• Labeling
• Reuse
• Single-use restrictions

4. Verify High-Risk Packaging Through Testing

Laboratory testing may be appropriate where material declarations do not provide sufficient evidence or where specific chemical restrictions apply.

For food-contact packaging, this may include PFAS-related testing where necessary to demonstrate compliance with Article 5.

The Commission’s recommended enforcement approach begins with total fluorine screening and uses further organic-fluorine and targeted PFAS analysis where required.

5. Review Packaging Design

The packaging design review should evaluate:

• Material combinations
• Package size
• Empty space
• Components
• Labels
• Coatings
• Recyclability

Changes should be documented through controlled packaging specifications.

6. Maintain Technical Documentation

Keep supporting evidence for the packaging placed on the EU market.

Documentation should be traceable to the relevant packaging material, supplier, and product.

7. Verify Production Packaging

Packaging specifications can also be incorporated into a packaging inspection or pre-shipment inspection program.

An inspection can verify physical requirements such as:

• Packaging dimensions
• Packaging material against approved specifications
• Labels
• Markings
• Packing configuration
• Packaging quantities
• Shipping cartons

Chemical composition and other laboratory-based compliance requirements require appropriate testing or supporting technical documentation.

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PPWR compliance should be integrated into packaging design, supplier management, testing, documentation, and quality-control processes.

Current compliance efforts should focus on identifying packaging materials, confirming applicable requirements, and maintaining reliable technical documentation. Particular attention is required for PFAS restrictions in food-contact packaging, which have applied since 12 August 2026.

Longer-term PPWR obligations cover recyclability, recycled content, compostability, harmonized labeling, packaging minimization, empty-space limits, reuse, and restrictions on certain single-use packaging formats. Packaging specifications should therefore be reviewed systematically against the requirements and implementation dates that apply to each packaging type.