PPWR Requirements for EU Packaging
What does PPWR require for packaging sold in the EU?
Regulation (EU) 2025/40 (PPWR) has applied since 12 August 2026 [1]. It covers all packaging, whatever the material, and all packaging waste [2]. "Packaging shall only be placed on the market if it complies with this Regulation" [3]. In practice the main duties are: limits on substances, recyclability, recycled content for plastics, minimisation, harmonised labelling, conformity documentation, EPR registration, and reuse targets and format bans. Most of them start between 2028 and 2040. Only the substance limits, the reusability criteria and the manufacturer and importer obligations apply today.
Approach: I read the PPWR legal text as published on EUR-Lex, Article by Article and Annex by Annex. The Commission's delegated and implementing acts under PPWR (harmonised label, recyclability criteria, recycled-content method) are not in the datasets I searched, so I can't say which have been adopted.
Already applicable (from 12 August 2026)
- Substances (Art. 5):
- Substances of concern must be minimised.
- Lead, cadmium, mercury and hexavalent chromium together "shall not exceed 100 mg/kg".
- Food-contact packaging must not contain PFAS at or above 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, or 50 ppm for total PFAS including polymeric PFAS.
- Compliance goes in the Annex VII technical documentation [4].
- Reusable packaging criteria (Art. 11): packaging placed on the market from 11 February 2025 counts as reusable only if it meets all nine criteria in points (a) to (i). These include being designed for multiple rotations, being capable of reconditioning under Annex VI, and being recyclable under Art. 6 [5].
- Manufacturers (Art. 15):
- Before placing packaging on the market, they must carry out conformity assessment, draw up the Annex VII technical documentation and issue an EU declaration of conformity.
- They keep these for 5 years for single-use packaging and 10 years for reusable packaging.
- The packaging must carry a type, batch or serial number, plus the manufacturer's name and postal address (on the pack or via a QR code or other data carrier).
- Documents must reach an authority within 10 days of its request [6].
- The procedure is Module A, internal production control [7]. The declaration follows the Annex VIII model and must be in the language(s) the Member State requires [8].
- Supply chain:
- Suppliers must give manufacturers the information they need to show conformity [9].
- Importers must check conformity and labelling and add their own name and address [10].
- Distributors must check that the producer is on the EPR register and that the packaging is labelled [11].
- Anyone who sells packaging under their own brand, or modifies it, becomes the manufacturer [12].
- Environmental claims (Art. 14): claims about properties that PPWR regulates are allowed only if the packaging goes beyond the minimum requirements, and the claim must say what it covers (the unit, part of it, or the operator's whole range) [13].
- EPR (Arts 44-45):
- Producers must register in each Member State where they first make packaging available, and must not make it available there unless registered.
- Annual reporting is due by 1 June [14].
- Producers without an establishment in a Member State must appoint an authorised representative for EPR there by written mandate.
- Online platforms must collect producers' registration details before letting them sell [15].
- National registers are due 18 months after the Commission's first implementing act on the register format [14].
Phased requirements
| From | Requirement |
|---|---|
| 12 Feb 2028 | Tea and coffee bags and pods, and fruit stickers, must be industrially compostable (Art. 9(1)). Other biodegradable packaging must be designed for recycling [16]. Sales packaging: empty space reduced to the minimum needed [17]. HORECA take-away businesses must offer a reusable option (micro-enterprises are exempt) [18] |
| 12 Aug 2028, or 24 months after the implementing acts (whichever is later) | Harmonised material-composition label based on pictograms. Transport packaging and deposit-return packaging are excluded, but e-commerce packaging is not. Non-compliant stock made or imported before the deadline may be sold for 3 more years [19] |
| 12 Feb 2029, or 30 months after the implementing act (later) | Reusable packaging must carry a "reusable" label and a QR code or other data carrier [19] |
| 1 Jan 2029 | Member States must reach 90% separate collection of single-use plastic beverage bottles and metal beverage containers up to 3 L, through deposit-return systems [20] |
| 1 Jan 2030, or 24 months after the design-for-recycling acts (later) | Packaging must be design-for-recycling grade A, B or C. Grade A or B only from 1 Jan 2038. "Recycled at scale" applies from 2035 [21] |
| 1 Jan 2030, or 3 years after the implementing act (later) | Minimum post-consumer recycled content in plastic parts: 30% for contact-sensitive PET, 10% for other contact-sensitive plastics, 30% for single-use beverage bottles, 35% for other plastics. Rising in 2040 to 50%, 25%, 65% and 65%. Plastic parts under 5% of the unit's weight are exempt [22] |
| 1 Jan 2030 | Weight and volume minimised. No false bottoms, double walls or other features that only increase perceived volume [23]. Grouped, transport and e-commerce packaging: empty space ratio of 50% at most (or 3 years after the method act, if later) [17] |
| 1 Jan 2030 | Annex V bans [24][25]: single-use plastic multipack wraps, plastic packs for under 1.5 kg of fresh fruit and vegetables, single-use plastic for dine-in HORECA, single-use plastic portion packs (condiments, sugar and similar) in HORECA, single-use toiletry miniatures in hotels, and very lightweight plastic carrier bags. Some exceptions apply |
| 1 Jan 2030 | Reuse targets [26]: 40% reusable transport packaging (aim of 70% from 2040). 100% reusable for transport between an operator's own sites or within the same Member State. 10% reusable grouped boxes (cardboard excluded). 10% of beverages sold in reusable packaging by final distributors. Exemptions include cardboard boxes, dangerous goods, wine, spirits and milk, shops of 100 m² or less, and micro-enterprises placing 1,000 kg or less |
Main exemptions
- Recyclability (Art. 6), recycled content (Art. 7) and labelling (Art. 12) carve out certain packaging for medicinal products, medical devices and IVDs. The scope is not the same under each Article [21][22][19].
- Infant and medical-food packaging and dangerous-goods packaging are also exempt from Arts 6 and 7.
- Where PPWR conflicts with the dangerous-goods transport Directive 2008/68/EC, the Directive prevails [2].
- Directive 94/62/EC is repealed from 12 August 2026, but some of its provisions keep applying, the longest until 31 December 2029 [27].
Many of the "whichever is later" dates depend on Commission acts that were due by 12 August 2026 (labelling) and 1 January 2028 (design for recycling). If you tell me your packaging type, sector and Member States, I can narrow this to the obligations that apply to you.
When do the main requirements apply?
PPWR has applied since 12 August 2026, but that date mostly switches on the substance limits, the reusability criteria and the operator and conformity duties. The design requirements arrive in stages: labelling from 2028, the big wave of recyclability, recycled content, minimisation, format bans and reuse targets on 1 January 2030, then tighter levels in 2035, 2038 and 2040 [1]. Several of these dates move later if the Commission adopts the acts they depend on late. The rule is "whichever is the latest".
Approach: I read the dates in Regulation (EU) 2025/40 as published on EUR-Lex, Article by Article. The Commission acts that the "whichever is the latest" dates depend on are not in the datasets I searched, so I can't say whether any of those dates has already moved.
Timeline
| Date | What applies |
|---|---|
| 11 Feb 2025 | Packaging placed on the market from this date counts as reusable only if it meets all the Art. 11 criteria [5] |
| 12 Aug 2026 (in force now) | The Regulation applies generally [1]. Food-contact packaging must not be placed on the market at or above the Art. 5 PFAS limits [4]. Directive 94/62/EC is repealed, with some exceptions (see below) [27] |
| 12 Feb 2028 | Tea and coffee bags and pods (Art. 3(1)(1)(f) packaging) and sticky fruit and vegetable labels must be industrially compostable. Other packaging, including biodegradable plastics, must be designed for material recycling [16]. Empty space in sales packaging must be cut to the minimum needed [17]. HORECA take-away businesses must offer a reusable option (micro-enterprises are exempt) [18] |
| 12 Aug 2028, or 24 months after the labelling implementing acts (whichever is later) | Harmonised material-composition label. Any label on recycled content in packaging covered by Art. 7 must follow the implementing-act specifications [19] |
| 1 Jan 2029 | Member States must reach at least 90% separate collection of the Art. 50 formats, and new deposit-return systems must meet Annex X [20]. Recycled content must be calculated and verified using the Art. 7(8) method (or 24 months after that act, if later) [22] |
| 12 Feb 2029, or 30 months after the implementing act (later) | Reusable packaging must carry a "reusable" label [19]. Article 67(5) also applies from 12 Feb 2029 [1] |
| 1 Jan 2030, or 24 months after the design-for-recycling delegated acts (later) | Packaging must be recyclable within grades A, B or C [21] |
| 1 Jan 2030, or 3 years after the implementing act (later) | First minimum recycled-content levels for plastic parts [22]. Grouped, transport and e-commerce packaging: empty space ratio of 50% at most [17] |
| 1 Jan 2030 (fixed) | Weight and volume minimised [23]. Annex V format bans [24]. Reuse targets: 40% for transport packaging, 10% for grouped boxes (cardboard excluded), 10% for beverages [26] |
| 1 Jan 2035, or 5 years after the implementing acts (later) | The "recycled at scale" requirement under Art. 6 [21]. Existing deposit-return systems that missed the 90% target in 2029 must meet Annex X by this date at the latest [20] |
| 1 Jan 2038 | Packaging must be recyclable within grades A or B only [21] |
| 1 Jan 2040 | Higher minimum recycled-content levels [22]. Operators "shall endeavour" to reach 70% reusable transport packaging, 25% for grouped boxes and 40% for beverages. These are aims, not binding targets [26] |
Transitional points
- Parts of Directive 94/62/EC that still apply [27]:
- Art. 5(2)-(3), Art. 6(1)(d)-(e), Art. 6a and Art. 12(3a)-(4) apply until 31 December 2028.
- The Art. 12 provisions on sending data to the Commission apply until 31 December 2029.
- Art. 9(1)-(2), on the essential requirements, also applies until 31 December 2029.
- Decision 97/129/EC is repealed from 12 August 2028 [27].
- National format bans: Member States may keep their own restrictions on the formats in Annex V points 2 and 3 until 1 January 2030 [27].
- Innovative packaging: from 1 January 2030, innovative packaging that fails the recyclability requirements may stay on the market for up to 5 years from the end of the year it was placed on the market [21].
Commission deadlines that can move the "whichever is later" dates
- Labelling: the harmonised-label implementing acts were due by 12 August 2026 [19].
- Recycled content: the calculation method was due by 31 December 2026 [22].
- Recyclability: the design-for-recycling delegated acts are due by 1 January 2028 [21].
- Empty space ratio: the calculation method is due by 12 February 2028 [17].
If any of these acts comes into force late, the matching requirement starts later too.
What are the PFAS limits for food packaging?
Under PPWR Article 5(5), since 12 August 2026 food-contact packaging "shall not be placed on the market" if it contains PFAS at or above 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, or 50 ppm for total PFAS including polymeric PFAS [4]. For paper and cardboard food-contact materials, a stricter REACH restriction on PFHxA has also applied since 10 October 2026 [28].
Approach: I read PPWR Article 5 and its recitals in Regulation (EU) 2025/40. I also checked the REACH Annex XVII restrictions, in both the ECHA list and the consolidated REACH text, for PFAS entries that cover food contact.
PPWR Article 5(5) limits
The limits apply only "to the extent that" another Union act does not already prohibit placing such packaging on the market [4].
| Limit (packaging fails at or above it) | How it is measured |
|---|---|
| 25 ppb for any PFAS | Targeted PFAS analysis. Polymeric PFAS are not counted. |
| 250 ppb for the sum of PFAS | Sum of the targeted PFAS analysis, with prior degradation of precursors where applicable. Polymeric PFAS are not counted. |
| 50 ppm for PFAS, including polymeric PFAS | If total fluorine exceeds 50 mg/kg, the REACH manufacturer, importer or downstream user "shall, upon request" give the packaging manufacturer or importer proof of how much of the fluorine is PFAS and how much is non-PFAS. The packaging manufacturer or importer needs this for the Annex VII technical documentation. |
What counts as PFAS: any substance with at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom that has no H, Cl, Br or I attached. Substances whose only such elements are CF3-X or X-CF2-X′ (with X and X′ as listed in Article 5(5)) are excluded [4].
How you show compliance: in the Annex VII technical documentation (Art. 5(6)) [4].
Review: by 12 August 2030 the Commission "shall" assess whether to amend or repeal Article 5(5), to avoid overlap with PFAS rules under Regulations (EC) No 1935/2004 (food-contact materials), (EC) No 1907/2006 (REACH) or (EU) 2019/1021 (POPs) [4]. Recital 21 gives the reason for the restriction: PFAS hazards have no threshold, so exposure from food-contact materials is treated as an unacceptable risk [29].
REACH Annex XVII entry 79 (PFHxA): paper and cardboard
- Scope: PFHxA, its salts and PFHxA-related substances.
- Rule: from 10 October 2026 these "shall not" be placed on the market or used in "paper and cardboard used as food contact materials within the scope of Regulation (EC) No 1935/2004" at or above:
- 25 ppb for the sum of PFHxA and its salts, or
- 1,000 ppb for the sum of PFHxA-related substances,
- measured in homogeneous material.
- Transition: articles placed on the market before 10 October 2026 are exempt.
This entry is narrower than PPWR (one PFAS group, paper and board only), but it sits alongside the PPWR limits for that material. The other PFAS entry I found in Annex XVII, entry 68, has no wording on food contact in the text I read [30].
Neither text sets a test method. PPWR names only the type of analysis (targeted analysis, total fluorine). I found no harmonised analytical standard in the PPWR text.