PPWR is here. Is your packaging ready?
PPWR applies from 12 August 2026. It is binding in all 27 Member States and reaches almost every business that sells a physical product in Europe. Here is what it requires, who it applies to, and where to start.
What it is
Regulation (EU) 2025/40 sets sustainability and labelling requirements for packaging across its whole life cycle, production, use and waste. It replaces the packaging directive that had governed Europe since 1994. The change from a directive to a regulation is the part that matters commercially. A directive is written into national law by each country in its own way, which is how one product ended up needing different packaging and labelling in different markets. A regulation applies directly and identically across the EU.
There is a real benefit in that. Packaging that complies with PPWR can be marketed freely across the Union, and Member States cannot impose conflicting national requirements.
What it requires
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All packaging must be designed for material recycling. From 2030 it must meet a recyclability performance grade; from 2035 it must also be collected, sorted and recycled at scale; from 2038 the requirements tighten further.
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Plastic packaging must contain a minimum share of post-consumer recycled material from 2030. Exceptions apply for pharmaceutical packaging, food packaging for infants and young children, medical devices, packaging for transporting hazardous goods, and compostable plastics.
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Packaging must be reduced to the minimum weight and volume needed for function. The regulation is explicit that marketing or consumer acceptance do not justify extra weight or volume, so premium presentation is not a defence. Packaging designed to make a product look larger, such as double walls or false bottoms, is prohibited unless protected by a design right or trademark.
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From 2030, grouped, transport and e-commerce packaging must not exceed 50% empty space. Sales packaging must minimise empty space too.
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From 2030, Annex V prohibits a defined list, including single-use films used to group products at the point of sale, pre-packed fruit and vegetables under 1.5 kg, single-use food and drink packaging consumed inside hotels, bars and restaurants, individual portions of condiments, sauces, coffee creamer and sugar, small single-use hotel toiletries, and most very lightweight plastic bags.
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Reusable packaging must be designed for multiple rotations and meet safety, hygiene and recyclability requirements, and operators must run a working collection and reconditioning system. Targets from 2030: 40% of transport packaging reusable (aspirational 70% by 2040), 10% of grouped packaging (25% by 2040), and 10% of beverages in reusable packaging (40% by 2040). Large retailers must endeavour to give 10% of sales area to refill stations.
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From 2027, restaurants and cafés must let customers bring their own containers at no extra cost. From 2028, they must also offer reusable packaging at no extra cost.
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Harmonised labels on material composition and sorting, delivered largely by QR code.
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PFAS are restricted in food-contact packaging and heavy metals are capped, with a general duty to minimise substances of concern.
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Manufacturers must carry out a conformity assessment, issue an EU Declaration of Conformity and keep technical documentation for five years, ten years for reusable packaging. If non-compliance is suspected, they must take corrective action, including withdrawal or recall, and inform the authorities.
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Producers are responsible for the whole life cycle of their packaging. Fees must cover collection, sorting and recycling, must be modulated to reward better design, and must be financially transparent.
The aim
To prevent unnecessary packaging and promote reuse refill and recycling
To harmonise national rules so they stop acting as trade barriers
To support the circular economy and climate neutrality by 2050
The change from a directive to a regulation is the part that matters commercially. A directive is written into national law by each country in its own way, which is how one product ended up needing different packaging and labelling in different markets. A regulation applies directly and identically across the EU.
There is a real benefit in that. Packaging that complies with PPWR can be marketed freely across the Union, and Member States cannot impose conflicting national requirements.