When did the PPWR Regulation come into force? Timetable for the introduction of new obligations
On 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR Regulation, came into force. It is worth noting that, as of that date, only some of the new requirements are in force – further obligations will be phased in until 1 January 2040, gradually replacing the provisions of the previous Directive on packaging and packaging waste. Check when the specific requirements concerning the design, labelling and placing of packaging on the market will come into force.
PPWR regulations from 12 August 2026 – new obligations for packaging manufacturers
- Restrictions on PFAS in packaging intended to come into contact with food
From 12 August 2026, it will be prohibited to place food contact packaging on the market if it contains per- and polyfluoroalkyl substances (PFAS) in concentrations equal to or higher than the limit values set out in Article 5(5) of the PPWR Regulation. In its guidelines, the European Commission notes that there is currently no harmonised methodology for testing for the presence of PFAS and recommends the use of „an approach based on state-of-the-art analytical capabilities and a meta-analysis of studies on relevant matrices with regard to PFAS”.
The PPWR Regulation does not provide for a transitional period for food contact packaging containing PFAS that was manufactured but not placed on the market before 12 August 2026. – if they do not comply with the PFAS content limits, they will not be allowed to be sold.
- Minimising the content of hazardous substances
Packaging must be manufactured in such a way as to minimise the content and concentration of potentially hazardous substances both in the packaging materials themselves and in all components of the packaging. From 12 August 2026, the sum of the concentrations of heavy metals – lead, cadmium, mercury and hexavalent chromium – in packaging or its components must not exceed 100 mg/kg.
- Preparation of an EU Declaration of Conformity
From 12 August 2026, all packaging placed on the European Union market for the first time must be accompanied by an EU declaration of conformity confirming compliance with the relevant requirements of the PPWR Regulation. The packaging manufacturer is solely responsible for carrying out the conformity assessment, preparing the technical documentation and drawing up the declaration; the manufacturer may, however, seek assistance from external bodies.
PPWR obligations from 12 February 2028 – compostable packaging
From 12 February 2028, certain packaging formats must comply with compostability requirements as set out in Article 9 of the PPWR Regulation. This obligation will apply to:
- self-adhesive labels affixed to fruit and vegetables,
- permeable bags for tea, coffee and other drinks,
- packaging for coffee, tea and other drinks, which becomes soft after use (soft-after-use).
This packaging should be designed in such a way as to allow it to be composted under controlled industrial conditions (i.e. comply with the industrial composting standards set out in Annex III to the PPWR Regulation). Each Member State may, in addition, require that the above-mentioned packaging formats placed on its market are also suitable for home composting.
In its guidelines, the European Commission states that the compostability requirement set out in Article 9(1) of the PPWR is material-neutral, i.e. it does not depend on the type of material from which the packaging in question is made.
Since when has packaging labelling in accordance with the PPWR been in force?
- 12 August 2028 – labelling of packaging
All packaging placed on the market must bear harmonised labels containing information on material composition and facilitating its correct sorting. In the case of compostable packaging, the label must also indicate its compostability, state that it is not suitable for home composting (where applicable) and specify that such packaging must not be discarded into the environment.
Transport packaging (with the exception of e-commerce packaging) and packaging covered by deposit-return schemes are exempt from the labelling requirement.
Read also: Packaging labelling in accordance with the PPWR – a proposal for new waste sorting labels
- 12 August 2028 – labelling of packaging waste bins
All containers for packaging waste must be labelled with harmonised labels to facilitate separate collection. The design of the labels affixed to the containers must correspond to the design of the labels used to mark the packaging. The aim of this regulation is to make it easier for end-users to sort used packaging into the correct waste stream.
- 12 February 2029 – labelling of reusable packaging
Reusable packaging placed on the market must bear harmonised labels indicating that it can be reused. In addition, each such package must bear a QR code or other digital data carrier that enables the package to be tracked and the number of its journeys and rotations to be determined. Furthermore, from 12 February 2029, all reusable packaging offered at points of sale must be easy to identify and distinguish from single-use packaging.
PPWR obligations from 1 January 2030 – the biggest changes in packaging design
- Design for recycling (Design for Recycling, DfR)
All packaging placed on the Community market must be suitable for material recycling and meet the requirements of one of the recycling efficiency classes – A, B or C. This classification determines the extent to which the packaging complies with design-for-recycling criteria, with Class A packaging being the most recyclable and Class C packaging the least recyclable. Packaging that does not meet the requirements of Class C, i.e. packaging with a per-unit recyclability rating of less than 70%, will be deemed unsuitable for recycling and may not be placed on the market.
- Minimum recycled content
From 1 January 2030, plastic packaging will be required to contain a specified minimum level of recycled material. The required level of recycled material will depend on the type of packaging and will be as follows:
- PET contact packaging – 30%,
- disposable bottles – 30%,
- contact packaging other than that made from PET – 10%,
- other plastic packaging – 35%.
- Discontinuation of certain packaging formats
It will be prohibited to place on the market the types of packaging listed in Annex V to the PPWR Regulation, in particular certain single-use plastic packaging. The restrictions will include, amongst other things:
| Packaging formats being phased out | Examples of packaging |
| single-use plastic bulk packaging | shrink film and film for bundling products (e.g. bottles, tins), plastic promotional wrappers |
| single-use plastic packaging for fresh, unprocessed fruit and vegetables | nets, bags, trays, containers |
| single-use plastic packaging used in the HoReCa sector | trays, disposable cups and plates, bags and boxes |
| disposable plastic packaging for food accompaniments in the HoReCa sector | sachets, cups, trays, boxes for items such as jams, sauces, coffee creamer, sugar and spices |
| single-use packaging used in the accommodation sector for individual bookings | mini hotel toiletries |
| very lightweight plastic shopping bags | thin disposable shopping bags and sachets, e.g. for packing fruit, vegetables or bread |
- Minimisation
From 1 January 2030, the weight and volume of packaging must be limited to the minimum necessary to protect the product. Double-walled packaging, false bottoms and unnecessary layers that appear to increase the volume of the product will therefore be prohibited.
The provisions of the PPWR Regulation introduce a maximum void ratio for collective, transport and e-commerce packaging of 50%. Void space includes not only air-filled spaces but also any filling materials, such as bubble wrap, polystyrene, foam, paper and other similar materials.
- Objectives for transport packaging
From 1 January 2030, companies using transport or commercial packaging for the transport of goods within the EU – including pallets, collapsible boxes and plastic crates, trays, large bulk containers, vats, drums, canisters, palletised packaging or straps used to stabilise and protect products placed on pallets, shall ensure that at least 40 % of such packaging is reusable.
The PPWR also provides for an obligation; the PPWR also stipulates that, in the case of specific transport packaging used between different business premises of the same operator, or between an operator and an affiliated or partner company, such packaging must be reusable packaging operating within a reuse system. However, in accordance with Commission Delegated Decision (EU) 2026/429, this obligation shall not apply to pallet packaging and straps used to stabilise products on pallets.
PPWR obligations from 1 January 2035 – introduction of a large-scale recycling requirement
From 2035, the assessment of packaging recyclability will be expanded to include an additional criterion – large-scale recycling. This means that packaging will not only have to meet the requirements for design for recycling, but also actually be recycled on an appropriate scale. Manufacturers will therefore be required to carry out assessments based on the quantity (mass) of packaging material that is effectively recycled. The methodology for this assessment and the thresholds for large-scale recycling in each packaging category will be set out in implementing acts adopted by the European Commission.
PPWR obligations from 1 January 2038 – more packaging is being phased out of the market
From 2038, it will be prohibited to place on the market packaging that meets the criteria for Class C, i.e. packaging that can be recycled to a degree greater than 70% but less than 80%. Consequently, only packaging belonging to classes A and B will remain on the market.
Find out more about recycling efficiency classes A, B and C >>
PPWR obligations from 1 January 2040 – stricter requirements for generators and manufacturers
- Increase in the minimum levels of recycled content
The minimum proportion of recycled material used in the production of packaging will increase to:
| Packaging type | Minimum recycled content |
| PET contact packaging | 50% |
| disposable bottles | 65% |
| contact packaging other than that made from PET | 25% |
| other plastic packaging | 65% |
- Higher reuse targets for transport packaging
Companies using specific transport and retail packaging that have so far been subject to a 40 per cent reuse target (including pallets, collapsible plastic containers and crates, trays, large bulk containers, buckets, drums, canisters, palletised packaging and load-securing straps) are aiming to use at least 70% of such packaging in a reusable format within the reuse scheme.
Contact
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