Packaging and Packaging Waste Regulation

The finalized amendments from Europe’s Packaging and Packaging Waste Regulation (PPWR) provide stringent requirements for companies manufacturing or distributing packaging or packaging materials. The PPWR targets concerns for recyclability, biodegradability, labeling, waste management, and chemicals in packaging products. 

Managing Analyst for EMEA, Kimberley De Miguel, outlines the latest regulations in our recent webinar on global packaging compliance. In this article, we summarize the primary packaging responsibilities and important deadlines detailed under the PPWR that companies need to look out for.

Packaging and Packaging Waste Regulation (PPWR)

The latest amendment to the packaging directive launched in 2022 is now published as Regulation (EU) 2025/40 in the Official Journal of the European Union. The final version has been high on the agenda for manufacturers and distributors of packaging in the EU. 

The final amendment provides specific exceptions for certain products, such as wines, spirits, and milk. 

The PPWR entered into force on 11 February 2025 and is applicable from 12 August 2026, meaning most of its provisions will become legally binding from that date. However, Article 67(5) will be applicable from 12 February 2029 to give industries additional time to transition away from expanded and extruded polystyrene EPS/XPS in food containers, such as beverage cups and multipack plastic.
 

What does the PPWR regulate? 

The PPWR introduces significant changes for companies producing or placing primary, secondary, or tertiary packaging on the EU market. It regulates the materials, associated waste, and design of packaging. The Regulation specifically applies to economic operators and producers. 

The PPWR is separated into 13 chapters, covering the core measures of: 

• Recyclability 

• Recycled content (PCR) 

• Reduction of waste 

• Reusability 

• Labeling 

• Registration and reporting 

The PPWR requires penalties to be “effective, proportionate, and dissuasive”, but the interpretation of these terms may vary across EU Member States. It does, therefore, introduce significant risks for companies once it’s implemented.

Restricted substances

Similar to the directive, substances of concern and heavy metals are regulated under the PPWR. Recycled materials must now meet stricter safety standards to avoid the accumulation of potentially harmful substances in packaging.
 

PFAS 

Aligning with the global concern on the use of PFAS in consumer products, the PPWR establishes limits for its presence in food contact packaging. The product will be prohibited from sale in the EU if it surpasses the following PFAS limits: 

• 25 ppb for any PFAS as measured with targeted PFAS analysis (excluding polymeric PFAS) 

• 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis (excluding polymeric PFAS) 

• 50 ppm for PFASs (including polymeric PFAS) 

Further, if the total fluorine content exceeds 50mg, the manufacturer, importer, or downstream user must provide proof of the fluorine content at the time of request.
 

BPA 

Bisphenol A (BPA) is regulated under Regulation (EU) No 10/2011 to restrict its use in food contact materials (FCMs), such as baby bottles. However, the PPWR extends sustainability and safety requirements to packaging containing BPA. The use of BPA and its salts is prohibited in the manufacture of specific FCMs, and other bisphenols and derivatives mustn’t contain any residual BPA.

Design

The PPWR has released several Articles regulating the design of packaging to be more sustainable.
 

Minimization and reduction 

Under the PPWR, packaging must be designed to minimize its volume and weight, while maintaining functionality and recyclability. Adding features that increase the perceived volume, such as double walls or false bottoms, or including superfluous additional packaging that’s not essential for its functionality, is prohibited. In contrast, any additional packaging weight or volume that improves its recyclability or reusability is justified and accepted. 

Manufacturers must provide documentation which describes how the product meets PPWR regulations, including: 

• How the minimum necessary weight and volume were calculated 

• Any variations between production batches for the same packaging format 

Exceptions are permitted only for products registered or protected before 11 February 2025 if the new requirements would compromise the distinctiveness or integrity of these protected designs.
 

Recyclability  

All packaging must be intended and designed so that once it becomes waste, it’s suitable for material recycling, meaning it must be: 

• Easy to collect separately 

• Sorted into designated waste streams without contaminating them 

• Recycled at scale 

The PPWR aims to standardize recyclability criteria across the EU to limit market barriers, so packaging will be graded A, B, or C based on how well its design matches the recycling criteria laid out in Table 3 and 4 of Annex II.  

Further deadlines are highlighted in the PPWR’s goals to meet EU ambitions for a more circular economy.  

• From 2030: Packaging must meet the criteria above to be considered recyclable 

• From 2035: Additional criteria based on recycled-at-scale outcomes will be incorporated. Packaging scoring below Grade C will be deemed technically non-recyclable and its market placement will be restricted as a result 

• From January 2038: Only packaging that achieves at least a Grade B can be placed on the EU market 

The provision also establishes a framework for adjusting the financial contributions that producers must pay under Extended Producer Responsibility (EPR) obligations, thus linking the economic responsibility of producers to how well their packaging is designed for recycling.
 

Recycled content (PCR) 

Packaging should be designed and manufactured for a greater substitution of primary raw materials with recycled ones. The recycled content must be recovered from post-consumer plastic waste collected from within the EU or from a third country (provided that collection standards are equivalent). 

Within this goal, the PPWR lays out mandatory recycling targets for different types of packaging, calculated per manufacturing plant and year.
 

Reusability  

Under the PPWR, “reuse” is defined as any operation by which reusable packaging is used multiple times for the same purpose with which it was conceived. Packaging must therefore be designed in such a way to support its reuse, its ability to be recycled, and to include recycled content. 

There may be compromises with additional weight or volume such as needing sturdier and thicker packaging suitable for multiple uses. 

Article 11 lays out specific criteria for different packaging types: 

Transport and sales packaging 

• By 1 January 2030, at least 40% of transport packaging should be recyclable. This includes pallets and pallet wraps, crates, drums, and canisters 

• By 1 January 2040, at least 70% of packaging should be recyclable 

Grouped packaging 

• By 2030, at least 10% of grouped packaging must be reusable (excluding cardboard) 

• By 2040, at least 25% of grouped packaging must be reusable 

Beverage packaging 

• By 2030, 10% of alcoholic and non-alcoholic beverages must be sold in reusable packaging 

• By 2040, 40% of alcoholic and non-alcoholic beverages must be sold in reusable packaging 

By 2034, the European Commission will review the effectiveness of these 2030 targets to assess the feasibility of the 2040 goals.
 

Bio-based and compostability 

Under the PPWR, the EU currently defines ‘bio-based plastics’ as: plastics made from biological resources, such as biomass feedstock, organic waste, or byproducts, irrespective of whether the plastics are biodegradable.  

‘Biodegradable plastics’ are plastics that can convert over 90% of the original material into carbon dioxide, water, and minerals via a biological process within 6 months, regardless of the feedstock used. 

By 2028, the EU will undertake a mandatory review of the technology and environmental performance of bio-based plastic packaging against existing EU sustainability benchmarks — potentially leading to new legislation on sustainability criteria, usage targets, and alternative compliance for recycled content. 

By 12 February 2028, tea and coffee bags, and sticky labels on fruit and vegetables must be compostable under industrial conditions to ensure they can be processed in bio-waste treatment facilities. 

Labeling

From 12 August 2028, packaging must include a harmonized label indicating material composition, so consumers have a clear idea of what they need to do with their packaging. 

These labels will include: 

• Pictograms for accessibility, paired with corresponding labels on waste bins 

• Digital marking for substances of concern 

• Unambiguous and clear labeling for compostable packaging 

• QR codes to identify EPR compliance 

If recycled content is displayed, it must follow EU-wide specifications. Similarly, if bio-based plastic content is displayed, it must follow harmonized rules. 

From 12 February 2029, reusable packaging must be clearly labeled as such, and distinguishable from single-use packaging for customers to immediately recognize. 

Some packaging products are exempt from these rules, including e-commerce, transport and deposit-return systems, and medical packaging if safety concerns exist.

Registration

By February 2026, the Commission will define a standard registration format to allow data transfer without vendor lock-in, using open standards and machine-readable data.
 

Representative 

The PPWR requires each Member State to appoint a competent authority by July 2025 to oversee the implementation of registration. This applies to any producer that places packaging or packaged products on the market in a Member State for the first time, and any entity that unpacks packaged products. 

Packaging producers must be registered in the Member State where they place packaging or packaged products on the EU market. If a producer isn’t established in the EU, they must appoint an authorized representative (AR) in that Member State.