PPWR
Published on:
June 30, 2026
Biki John
Senior Content Marketing Manager
A Brief History of Packaging Waste in Europe
Since the introduction of the European Union’s (EU) Packaging and Packaging Waste Directive in 1994, packaging consumption has continued to grow significantly, placing increasing pressure on waste management systems and the environment.
By 2021, Europe reached a record high of 84.3 million tonnes of packaging waste. Over the last decade, the amount of waste the average person threw away had increased by 20%.
Without additional measures, packaging waste volumes were projected to rise by nearly 19% again by 2030, threatening the EU’s climate and sustainability objectives.
In the EU, 40% of all plastic and 50% of all paper are used just for packaging. This amounts to over a third of all household waste. It is also a leading cause of pollution, as half of the litter found in the ocean comes from packaging.
In 2022, the average person in the EU produced 186.5 kg of packaging waste. To picture that, it is like filling up a large suitcase with trash every 10 days and throwing it away.
Despite earlier recycling targets and waste legislation designed to tackle the issue, packaging waste volumes continued to rise. Consequently, policymakers recognised that waste management alone could not solve the problem. Instead, a more comprehensive approach was needed that addressed packaging across its entire lifecycle, including design, material use, reuse, and recyclability.
This shift in policy thinking ultimately led to the introduction of the Packaging and Packaging Waste Regulation (PPWR).
Is PPWR a directive or a regulation?
PPWR is a regulation, not a directive.
Previously, EU packaging legislation was based on the Packaging and Packaging Waste Directive (94/62/EC). A directive sets goals at EU level but allows each Member State to create its own national laws to achieve them. As a result, packaging rules differed between countries, creating complexity for companies operating across multiple EU markets.
On the other hand, PPWR introduces a new legal approach and the differences are best explained below:
Directive vs Regulation: What are the key differences?
Directive
Regulation
What is PPWR?
PPWR, also referred to as Regulation (EU) 2025/40, is an EU-wide law that applies across all member states. It establishes harmonised rules for how packaging is designed, used, and managed across its entire lifecycle. This means that countries no longer need to translate these rules into national legislation.
The regulation acts as a market access framework for packaging placed on the EU market.
The purpose of Regulation (EU) 2025/40 is to reduce the environmental impact of packaging while supporting the transition toward a more circular economy through consistent requirements applied across all Member States
By establishing one single framework for the entire EU market, PPWR aims to remove regulatory fragmentation, simplify compliance, and ensure consistent sustainability standards for all packaging placed on the EU market.
When does PPWR come into force?
PPWR officially entered into force on 11 February 2025, with its requirements becoming mandatory from 12 August 2026. The August 2026 deadline is only the first milestone. The PPWR uses a "staggered" approach to give industries time to redesign packaging and scale up recycling infrastructure.
How Does PPWR Support the EU’s Wider Sustainability Strategy?
PPWR is not a standalone law. It forms part of the EU’s broader sustainability strategy and helps deliver key objectives under two major EU policy frameworks: the European Green Deal and the Circular Economy Action Plan.
The European Green Deal
The European Green Deal sets the EU’s long-term roadmap for becoming climate-neutral by 2050, introducing binding targets across sectors such as energy, transport, industry, and waste management. Within this strategy, packaging was identified as a major environmental pressure point due to its high resource consumption, short usage lifecycle, and growing contribution to waste and emissions.
The Circular Economy Action Plan
Adopted in 2020, the Circular Economy Action Plan focuses on keeping materials in use for as long as possible and reducing waste generation at source. A central objective is that all packaging placed on the EU market should be reusable or recyclable by 2030, supporting a shift away from linear “take-make-dispose” consumption models toward circular material flows.
Where PPWR Fits In
The PPWR acts as a key legislative instrument supporting both frameworks. By introducing harmonised rules on packaging design, reuse, recyclability, and Extended Producer Responsibility (EPR), the regulation translates the EU’s sustainability ambitions into concrete, enforceable requirements for economic operators across the packaging value chain
What are the goals of PPWR?
PPWR’s objectives include:
Waste Reduction and Prevention
PPWR aims to reduce the total volume of packaging waste generated across the EU. Measures include limiting unnecessary packaging, restricting certain formats, and encouraging reusable and refillable solutions.
Recyclable Packaging by Design
All packaging must be recyclable by 2030. Packaging must not only be designed for recycling but also capable of being collected, sorted, and recycled effectively at scale.
Increased Recycled Content
The regulation introduces minimum recycled content requirements, particularly for plastic packaging. Targets begin in 2030 and increase over time, supporting demand for high-quality recycled materials and strengthening circular material flows.
Reduction of Single-Use Packaging
Certain single-use plastic packaging formats will be phased out where more sustainable alternatives exist, helping reduce waste generation and environmental impact.
Reuse and Refill Systems
Binding reuse targets encourage businesses to adopt reusable packaging models and allow consumers to use refillable containers, supporting long-term waste prevention.
Harmonised EU Rules
PPWR establishes consistent rules across the EU, including shared definitions, standardised labelling, and aligned packaging requirements to ensure fair competition and regulatory clarity.
Economic Incentives for Sustainable Packaging
Eco-modulated EPR schemes will link fees to environmental performance, financially rewarding packaging that is easier to recycle or reuse.
High-Quality Recycling Systems
The regulation promotes recycling systems capable of producing high-quality recyclates suitable for new packaging applications, supporting a functioning circular economy.
Material Innovation
Bio-based materials are encouraged where appropriate, but recyclability and circularity remain the primary priorities.
What key requirements
does PPWR cover at a glance?
PPWR introduces harmonised rules across the EU covering packaging design, materials, recyclability, reuse, and waste management.
Given the breadth and complexity of the PPWR, the overview below focuses on key articles that contain many of the core requirements related to packaging sustainability, recyclability, labelling, material composition, reuse, and conformity obligations.
These articles are particularly relevant for economic operators preparing for the regulation’s practical and operational impact across the packaging value chain.
Article
Substances of Concern (Article 5)
Recyclable Packaging (Article 6)
Minimum Recycled Content in Plastic Packaging (Article 7)
Biobased Materials (Article 8)
Compostable Packaging (Article 9)
Packaging Minimisation (Article 10)
Reusable Packaging (Article 11)
Labelling Requirements (Article 12)
Waste Containers, Labelling Requirements (Article 13)
Restrictions on Certain Packaging Formats (Article 25)
Conformity Framework and Technical Documentation (Articles 38, Annex VII & 39)
Prevention of Packaging Waste (Article 43)
Recycling Targets (Article 52)
Regulatory Area
Sets limits on hazardous substances in packaging, including heavy metals, and introduces restrictions on intentionally added PFAS in food-contact packaging to reduce risks to human health and the environment.
Mandates that all packaging must be recyclable by 2030, introduces recyclability performance grades, and links EPR fees to recyclability performance.
Establishes binding targets for minimum levels of post-consumer recycled plastic content in packaging, with phased targets for 2030 and 2040 supported by a harmonised calculation methodology.
These materials are currently assessed identically to non-biobased packaging. This approach will be reviewed by 12 February 2028.
Defines when packaging must be industrially or home compostable and introduces harmonised standards for specific packaging formats where compostability is required.
Mandates the reduction of packaging to the minimum necessary weight, without affecting the functionality of the packaging.
Requires that packaging is designed for multiple rotations for its original use. It must ensure product safety and quality are maintained before it enters the market.
Introduces harmonised EU-wide packaging labels and waste-sorting pictograms to improve consumer understanding and support consistent disposal practices.
All recycling bins must use the same standard labels. These symbols will match the ones on packaging to help people sort their waste correctly and consistently.
Prohibits specific single-use plastic packaging formats from 2030 where they are considered unnecessary or avoidable.
Companies that place packaging on the EU market are required to have all three elements working together: Article 38 explains what is needed for conformity assessment to verify that packaging satisfies EU rules. The requirements for technical documentation are set out in Annex VII and are applied through Article 38 of the PPWR. Article 39 states that the Declaration of Conformity to have a signed statement confirming all legal criteria are met.
Establishes binding targets to reduce overall packaging waste per capita across the EU and requires Member States to implement waste-prevention measures.
Sets binding recycling targets for packaging materials, requiring Member States to achieve specified recycling rates and report progress against EU-wide objectives.
Additional Resources on PPWR
To help your team navigate the road to PPWR compliance, we have compiled our latest
deep dive resources for you to get the knowledge you need.
Blog Article
Documentation of Conformity - What You Need to Know
In this article, we explain what the declaration of conformity entails, who it affects, and what content is required.
Webinar
PPWR Without the Paperwork: Live DoC Generation and the Roadmap to 2030
Watch this session to learn how to transition from manual to scalable DoC creation and build a 2030 recyclability mandates roadmap.
How does Article 6 define the requirements for design for recycling?
Article 6 of PPWR represents a shift in how packaging is regulated, moving away from broad definitions of "recyclability" toward a strict, evidence-based framework. It requires all packaging placed on the EU market to be designed for recycling, ensuring that materials can be effectively collected, sorted, and processed into high-quality secondary raw materials.
To achieve Article 6 compliance, companies must navigate three core pillars of the regulation:
Design for Recycling Criteria
Under Article 6, packaging must meet specific Design for Recycling criteria. These criteria are being developed by the European Commission for different packaging categories to ensure that components (such as inks, adhesives, and closures) do not frustrate the recycling process.
From 1 January 2030, all packaging must comply with these criteria and will be assigned a Recyclability Performance Grade ranging from A to E:
Grades A, B, and C: Packaging is considered compliant and remains on the market.
Grades D and E: Packaging is considered non-compliant and will be prohibited from being placed on the EU market.
These grades will also be directly linked to EPR fees, meaning better-designed packaging (Grade A) will benefit from lower financial contributions, while lower grades will face higher costs.
2. Recyclability at Scale (2035 Requirements)
While 2030 focuses on the design of the packaging, Article 6 introduces a second, more rigorous hurdle: Recyclability at Scale. By 1 January 2035, it is not enough for packaging to be technically recyclable on paper; it must be proven that the packaging is actually collected, sorted, and recycled in practice across the EU.
For packaging to meet this requirement, the infrastructure in Member States must be sufficiently advanced to process the material into a quality that is high enough to be used as a substitute for primary (virgin) raw materials. Packaging that cannot be recycled at scale by this 2035 deadline will be phased out of the market.
3. Proving Compliance and Documentation
To demonstrate compliance with Article 6, economic operators must ensure that their packaging undergoes a formal conformity assessment procedure. This involves:
Technical Documentation: Compiling a technical file (as per Annex VII) that details the material composition and how it meets the design for recycling criteria.
Performance Grading: Ensuring the packaging has been correctly assessed against the A–E grading scale.
Reporting: Keeping this documentation available (5 years from the date it was placed on the market for single-use packaging, 10 years for reusable packaging) to satisfy market surveillance authorities that the packaging meets the strict environmental standards set by the regulation.
By aligning design processes with Article 6 now, companies can ensure their portfolios are "future-proofed" against the 2030 performance grading and the 2035 scale-up requirements
How will the new CEN standards guide the implementation of PPWR design for recycling?
On 15 April 2026, CEN (European Committee for Standardisation) published EN 18120-1:2026, marking a major milestone as the first part of a new European standard series on design for recycling of plastic packaging.
It provides the technical foundation for implementing the PPWR and translates regulatory goals into practical, measurable design criteria.
It is significant because it is the first EU-wide structured standard system for design for recycling of plastic packaging. It creates harmonisation across 30+ countries, with conflicting national standards to be withdrawn by October 2026.
It also establishes the technical backbone for upcoming PPWR secondary legislation (2027–2028) and future recyclability requirements becoming legally binding around 2030.
PPWR defines the “what” in terms of legal obligations, while the CEN EN 18120 series defines the “how” through technical methods, criteria and assessment protocols. Consequently, while the EN 18120 series serves as the immediate industry blueprint, the Joint Research Centre (JRC) and the European Commission will build upon this framework to draft the final secondary legislation that officially codifies the legal grading and compliance metrics.
Who does PPWR apply to?
Economic operators placing packaging or packaged products on the EU market, including manufacturers, importers, distributors, fulfilment service providers, and retailers.
All categories of packaging, including primary, secondary, tertiary, and service packaging formats.
Micro-enterprises, which may benefit from reduced administrative requirements while still needing to comply with applicable obligations under the regulation.
What are the key PPWR recyclability compliance deadlines?
The PPWR introduces a broad range of requirements across packaging sustainability, labelling, reuse, recycled content, and waste reduction. However, one of the most significant long-term shifts for businesses is the regulation’s increasing focus on packaging recyclability and Design for Recycling (DfR).
The timeline below highlights some of the most important PPWR milestones related to recyclability requirements, eco-modulation, and DfR obligations under Article 6. These developments will progressively reshape how packaging is designed, assessed, and placed on the EU market.
12 August 2026
PPWR application begins. Until the new recyclability requirements under Article 6(1) take effect, recyclability and Design for Recycling (DfR) assessments continue to follow the existing Packaging and Packaging Waste Directive (PPWD) framework and EN 13430:2004 standards.
By 1 January 2028
The European Commission is expected to adopt Delegated Acts under Article 6 introducing Design for Recycling (DfR) criteria, recyclability assessment methodologies, and recyclability performance grades (A, B, and C), with application expected from 2030.
Mid-2029
Eco-modulated EPR fees linked to packaging recyclability are expected to enter into force. This means packaging design decisions will increasingly influence compliance costs.
1 January 2030
All packaging placed on the EU market must comply with the new Design for Recycling (DfR) requirements under Article 6.
New recyclability performance requirements also begin to apply, including minimum recyclability thresholds.
1 January 2035
Packaging must be recyclable “at scale”, meaning materials must not only be technically recyclable but also effectively collected, sorted, and recycled in practice across established infrastructure.
1 January 2038
Packaging achieving less than 80% Design for Recycling performance will no longer be permitted on the EU market (effectively phasing out Recyclability Grade C, leaving only Grades A and B legal), significantly tightening packaging marketability requirements.
What are the consequences of failing to meet PPWR’s compliance deadline on 12 August 2026?
Falling short of PPWR’s requirements can create legal, financial, and commercial risks.
Restrictions on selling products in the EU
Packaging that does not comply with PPWR rules cannot lawfully circulate within the EU market. Authorities may prevent goods from entering the EU, stop distribution, or require products already available for sale to be withdrawn. This can interrupt supply chains and directly affect business performance.
Regulatory action and financial sanctions
Although PPWR establishes common EU-wide standards, penalties are enforced by individual Member States. National authorities may issue fines, impose sales prohibitions, or apply administrative measures against non-compliant businesses. Enforcement is expected to become more active as implementation deadlines take effect.
Costs linked to product withdrawal
If packaging fails to meet regulatory requirements, companies may be required to remove affected products from circulation. Beyond lost revenue, organisations may need to cover transport, handling, storage, and disposal expenses connected with unusable packaging stock.
Limits on hazardous substances in packaging
The regulation introduces strict limits on PFAS substances in food-contact packaging from 12 August 2026. Defined concentration thresholds apply (25 ppb for any single PFAS measured with targeted analysis, 250 ppb for the sum of targeted PFAS analysis, 50 ppm for total PFAS, including polymeric PFAS). Exceeding these limits may trigger investigations, legal disputes, and reputational harm.
EPR obligations across Member States
Businesses placing packaging on the EU market must enrol in EPR schemes in every country where their packaging is sold. This includes funding waste management systems, submitting required data, and demonstrating compliance with recyclability requirements.
Failure to register or report correctly may result in penalties or restrictions on market access.
Business and reputation risks
Compliance increasingly influences purchasing decisions by retailers, investors, and consumers. Companies that delay preparation may face public scrutiny and reduced commercial opportunities, while compliant organisations strengthen trust and competitive positioning.
How does Recyda help companies stay compliant with PPWR?
Recyda supports companies throughout their PPWR compliance journey by bringing packaging data, documentation, and regulatory requirements into one central platform. From preparing and consolidating packaging data to generating Declarations of Conformity and managing technical documentation across portfolios, the solution helps businesses understand what is required, identify gaps, and track progress towards upcoming deadlines.
Explore the full scope of how our Recyda PPWR Navigator solution puts you on the road to compliance.
Popular PPWR Questions Asked by Brands
Toolkit
To help your team navigate the road to PPWR compliance, we have compiled our latest deep dive resources for you to get the knowledge you need:
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