In this Q&A we answer the common questions around PPWR to help you understand the changes to requirements for those who place packaging and packaged products on the EU market.
What is PPWR?
Regulation (EU) 2025/40 on packaging and packaging waste is the EU’s legislation covering requirements for packaging and packaged products, replacing the requirements of Directive 94/62/EC on packaging and packaging waste (PPWD).
Who does it apply to?
Requirements apply to anyone placing packaging or packaged products on the EU market (including Northern Ireland). This includes exporters of products from other countries to the EU.
Whilst EU law is not enforceable outside of the EU, anyone exporting non-compliant packaging and packaged products to the EU may face goods being rejected at EU borders. Similarly, EU distributors and those further down the supply chain may refuse to accept non-compliant packaging and packaged products.
What is classed as packaging under PPWR?
Packaging means any item for the containment, protection, handling, delivery or presentation of products. It includes single-use and reusable primary (sales) packaging, secondary (grouped) packaging and tertiary (transport) packaging.
PPWR also covers items designed to be filled at the point of sale (service packaging) and single-serve units for drinks machines, such as coffee pods.
What are the main requirements under PPWR?
Manufacturers of packaging and packaged products must ensure:
- packaging conforms with PPWR requirements via a conformity assessment procedure;
- technical documentation is drawn up;
- records are kept (5 years for single-use packaging and 10 years for reusable packaging);
- packaging is correctly labelled;
- compliance with national extended producer responsibility (EPR) schemes in individual EU countries where products are placed on the market.
A manufacturer includes anyone who has packaging or a packaged product designed or manufactured under the name or trademark, even if the packaging contains the name of another party (e.g. the original manufacturer of packaging).
Where can I find the requirements for the conformity assessment procedure and format of the declaration of conformity required by PPWR?
Conformity assessment procedure requirements, including technical documentation are detailed in Annex VII and the format for the EU declaration of conformity in Annex VIII.
When do PPWR requirements apply from?
PPWR applies from 12th August 2026, although a phased approach is being taken to implement all requirements, as per the table below. The European Commission will supplement PPWR with additional legislation to cover the longer-term requirements.
|
Date |
Requirement |
|
12.08.26 |
Main requirements apply, all packaging must meet EU design and composition standards, with a ban on packaging containing forever chemicals (PFAS) being used in food-contact packaging. |
|
12.02.27 |
Takeaways must allow consumers to use their own containers for food and drink. |
|
01.01.28 |
Waste separation labels must be printed on all waste receptables for plastic collection. EU Member States must report statistics on packaging placed on the market and progress towards targets. |
|
12.02.28 |
Takeaway businesses must offer reusable packaging for food and drink. |
|
12.08.28 |
Harmonised labelling for packaging becomes mandatory, including the material composition of packaging to enable correct recycling. |
|
01.01.29 |
All EU Member States must have implemented deposit return schemes (DRS) for single-use plastic and metal drinks containers, achieving a collection rate of 90% per year by weight. |
|
01.01.30 |
All packaging must be designed for recycling, with limits on empty space within packaging applying. Bans come into effect for individual portions of condiments and miniature toiletries in hotels. Packaging that is <70% recyclable is banned. |
|
01.01.35 |
Packaging must be recycled at scale to remain on the market (i.e. not just be recyclable in theory). A 55% recycling rate applies for most packaging materials. |
|
01.01.38 |
Packaging that is <80% recyclable is banned. |
|
01.01.40 |
Minimum recycled content targets increased (65% for plastic bottles). |
How can manufacturers comply with EPR requirements in EU Member States where they don’t operate from?
Manufacturers must appoint an ‘authorised representative’ in each EU Member State they are not established in order to fulfil the EPR requirements in that country. This applies to non-EU organisations and EU organisations which are not established in EU Member States where packaging or packaged products are made available for the first time.
Some EU Member States have de minimis thresholds for EPR, but many do not, meaning that the requirements will apply regardless of the volume of packaging or packaged products imported into that country.
Where can I get additional information and guidance on PPWR?
The European Commission offers additional information on PPWR here.
The UK’s Department for Business & Trade (DBT) has published guidance on complying with PPWR here. The DBT also offers support for UK businesses exporting goods internationally.
If you’re exporting packaging and packaged products to the EU, packaging compliance specialists such as Valpak and Ecosurety may be able to provide tailored support to ensure compliance.
