PPWR in practice: what the new EU packaging regulation means for your business

In brief

• PPWR is the EU’s Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It applies directly in all EU member states.
• It has applied since 12 August 2026. The most demanding requirements, including recyclability and minimum recycled plastic content, take effect in 2030.
• It covers packaging of every material placed on the EU market, so it affects almost any company that makes, packs, imports or sells packaged products.
• The first priority is reliable packaging data across your supply chain, not redesigning packaging.

Why the EU introduced PPWR

Packaging has long been regulated for health and safety reasons. In recent years the focus has shifted to the environment, and especially to plastic. Only a small share of plastic packaging is recycled: in Finland, the recycling rate was 29% in 2023.

PPWR is the EU’s response. It aims to reduce packaging waste, make recycling easier and increase the use of recycled materials. By 2030, all packaging placed on the EU market must be recyclable.

What is the EU packaging regulation?

PPWR is the EU Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40. It replaces the earlier Packaging and Packaging Waste Directive and applies directly in every EU country without national transposition. It has applied since 12 August 2026, but most requirements, such as recyclability and minimum recycled plastic content, only take effect in 2030.

PPWR requirements and timeline

The requirements are being phased in.

12 August 2026 (already in force): Concentration limits apply to heavy metals and to PFAS in food packaging. Other substances of concern must be minimised.

Every packaging type needs technical documentation and an EU declaration of conformity (DoC). Packaging must carry a batch or type identifier and the manufacturer’s contact details.

2027: Customers can have takeaway food and drinks served in their own containers.

2028: Takeaway sellers must also offer a reusable packaging option. Harmonised EU sorting labels are introduced.

2030: All packaging must be recyclable and will be graded in recyclability classes A–C.
Plastic packaging must contain a minimum share of recycled plastic.
Packaging weight and volume must be minimised. Double walls and false bottoms are not allowed, and transport and e-commerce packaging may contain no more than 50% empty space.
Certain single-use plastic packaging is banned, and reuse targets apply to transport packaging and beverage packaging.

In addition, producers pay for the collection and recycling of packaging waste through extended producer responsibility (EPR).

Who does EU packaging regulation apply to?

PPWR applies to all packaging placed on the EU market, whatever the material. That makes it relevant to almost every company that manufactures, packs, imports or sells packaged goods. Your obligations depend on your role:

Manufacturer: the company under whose name or trademark the packaging or product is sold. This is usually the brand owner, not the company that physically makes the packaging. The manufacturer is responsible for ensuring the packaging meets the requirements.
Producer: the company that first makes the packaging available in the country where it becomes waste. The producer handles extended producer responsibility, meaning waste management fees and reporting.

Importer: ensures that packaging coming from outside the EU complies with the requirements.
Packaging supplier: must give the manufacturer the information needed for compliance.
Relief for microenterprises: if the brand owner has fewer than 10 employees and turnover or balance sheet total of no more than €2 million, and the packaging supplier is in the same country, the manufacturer’s responsibility transfers to the supplier.

A checklist: How to prepare for PPWR

According to Antro Säilä, the biggest job is not developing new packaging. It is collecting and sharing reliable packaging data along the supply chain. Customers increasingly ask about materials, origin, recyclability, recycled content and environmental impact. The EU Digital Product Passport adds to this need, as its QR code is often placed on the packaging.

Start with these steps:

1. Inventory your packaging and identify your role (manufacturer, producer, importer or supplier) for each item.
2. Request supplier data on materials and substances, such as heavy metals and PFAS in food packaging.
3. Prepare technical documentation and a declaration of conformity (DoC) for packaging where you are the manufacturer. Keep them for 5 years, or 10 years for reusable packaging.
4. Check your labelling. Packaging must show a batch or type identifier and the manufacturer’s contact details.
5. Start preparing for 2030: recyclability, recycled plastic content and reducing unnecessary empty space.

Packaging placed on the market before 12 August 2026 does not have to be withdrawn.

An industry view on implementation

Säilä considers PPWR’s goals sound but its implementation clumsy. Interpretive guidance arrived only shortly before the regulation began to apply, and many details will become clearer in the coming years. He also points out that packaging does a lot of good by protecting products and reducing waste.

Get help preparing for PPWR

Many companies that package products are now working out how to collect the necessary data across their supply chains. Our sustainability experts can help you understand the requirements and put them into practice. Get in touch!

Sources

Antro Säilä, Finnish Packaging Association: presentation, 24 September 2026

Regulation (EU) 2025/40, EUR-Lex

European Commission: PPWR guidance notice

European Commission: PPWR FAQ, 2nd edition

This article does not constitute legal advice.