PPWR Regulation: The New EU Packaging Regulation Explained
What is the PPWR? The new EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) explained: requirements, labelling obligations, timeline from 2026, PFAS ban and how the PPWR relates to the Digital Product Passport.
PPWR Regulation: The New EU Packaging Regulation Explained
Key Takeaways
The PPWR (Packaging and Packaging Waste Regulation) is the new EU packaging regulation that affects all packaging placed on the European single market. It replaces the previous Packaging and Packaging Waste Directive (94/62/EC), turning a nationally transposed directive into a directly applicable regulation. For manufacturers, importers and retailers, this means packaging must be recyclable, contain defined recycled content, be minimised and be labelled in a harmonised way. This article gives a concise summary of what the PPWR requires, when it applies, and why it is closely related to the Digital Product Passport (DPP).
If you would first like to familiarise yourself with the Digital Product Passport, we recommend the introductory article Digital Product Passport in 15 minutes.
What is the PPWR?
The abbreviation PPWR stands for Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40 on packaging and packaging waste). The regulation was published in the Official Journal of the EU on 22 January 2025 and entered into force on 11 February 2025. The majority of its obligations apply from 12 August 2026.
The PPWR replaces the old Packaging Directive (94/62/EC). The decisive difference lies in the legal form: a directive must be transposed into national law by each Member State, which resulted in 27 different rulebooks. A regulation, by contrast, applies directly and uniformly across the entire EU. This ends the patchwork of national packaging rules.
The aim of the PPWR is to reduce the steadily growing volume of packaging waste and to align the packaging market with the principles of the circular economy. The regulation is part of the European Green Deal and the Circular Economy Action Plan, which also includes the ESPR regulation and the Digital Product Passport.
PPWR vs. the old Packaging Directive: Key differences
| Feature | Packaging Directive (94/62/EC) | PPWR Regulation (2025/40) |
|---|---|---|
| Legal form | Directive (national transposition required) | Regulation (directly applicable) |
| Recyclability | General targets | Binding design-for-recycling criteria |
| Recycled content | Not mandated | Minimum quotas for plastic packaging |
| Packaging reduction | Barely regulated | Empty space ratio and minimisation duty |
| Labelling | Nationally inconsistent | EU-wide harmonised labelling |
| Reuse | No binding targets | Binding reuse and refill targets |
The main requirements of the PPWR
The PPWR bundles a series of concrete obligations for everyone who places packaging on the market. The following points summarise the central requirements.
Recyclability of all packaging
From 2030, virtually all packaging on the EU market must be recyclable. To this end, the PPWR defines design-for-recycling criteria and introduces recyclability grades. Packaging that does not meet these criteria may no longer be placed on the market from the respective cut-off date.
Minimum recycled content
From 2030, plastic packaging must contain a minimum share of recycled material. The specific quotas vary by packaging type (for example contact-sensitive packaging, PET beverage bottles and other plastic packaging) and rise further by 2040. The exact percentages are set out in the text of the regulation.
Packaging minimisation
The PPWR prohibits unnecessary packaging and limits empty space. For grouped, transport and e-commerce packaging, an empty space ratio of no more than 50 percent applies. In addition, certain single-use packaging formats are banned, such as single-use plastic packaging for fresh fruit and vegetables under 1.5 kg or miniature toiletry packaging in hotels.
Reuse and refill targets
For certain areas (e.g. transport packaging and beverages), the PPWR introduces binding reuse targets. Companies must offer a growing share of their packaging as reusable systems.
PFAS ban in food packaging
The PPWR restricts the use of PFAS (per- and polyfluoroalkyl substances) in food-contact packaging. This restriction applies as early as 12 August 2026 and concerns packaging that comes into contact with food.
Deposit return systems (DRS)
By 2029, Member States must set up deposit return systems for single-use plastic beverage bottles and metal beverage cans, in order to achieve a 90 percent separate collection rate.
PPWR timeline: When does what apply?
| Date | Milestone |
|---|---|
| 22 January 2025 | Published in the Official Journal of the EU |
| 11 February 2025 | Regulation enters into force |
| 12 August 2026 | Start of general application, PFAS restriction for food packaging |
| approx. 2028 | Harmonised labelling obligation (following implementing acts) |
| 1 January 2029 | Deposit return systems (DRS) operational |
| 1 January 2030 | Recyclability, recycled content, packaging minimisation, reuse targets, single-use bans |
| From 2040 | Tightened recycled content quotas |
Important: Some detailed requirements will only be specified through implementing and delegated acts. The current status should therefore be checked regularly.
Labelling obligation: Where the PPWR meets the Digital Product Passport
A central building block of the PPWR is the harmonised labelling obligation. In future, packaging must be labelled in a uniform way so that consumers can sort it correctly. The labelling covers information on material composition and correct waste separation and will be standardised across the EU.
This labelling can be provided via digital data carriers such as QR codes. This is exactly where the PPWR and the Digital Product Passport overlap: both rely on machine-readable data carriers on the product or packaging, both link physical objects with structured digital data, and both increasingly use standards such as the GS1 Digital Link.
A company that structures its product data for the DPP and makes it accessible via QR codes is at the same time building the infrastructure that can also be used for PPWR labelling. Treating the two regulations separately means giving away synergies.
PPWR declaration of conformity and technical documentation
As with other product regulations, economic operators must demonstrate the conformity of their packaging. This includes technical documentation and a declaration of conformity confirming that the packaging meets the requirements of the PPWR. The declaration of conformity is a precondition for lawfully placing packaging on the EU internal market. Market surveillance authorities can request the documentation at any time.
Who is affected by the PPWR?
The PPWR affects the entire packaging value chain:
- Packaging manufacturers must meet design, recycled content and recyclability requirements.
- Fillers and brand owners who package products are responsible for the conformity of the packaging used.
- Importers must ensure that imported packaging complies with the PPWR.
- Retailers, including in e-commerce, may only pass on compliant packaging.
As with the ESPR, the rule applies that companies outside the EU are also affected as soon as their packaging is placed on the EU market.
What should businesses do now?
1. Map your packaging portfolio
Get an overview of all the packaging you use and its materials. Without a complete inventory, recycled content and recyclability requirements cannot be assessed.
2. Check recyclability
Compare your packaging against the design-for-recycling criteria. Problematic material combinations should be replaced early.
3. Build a data foundation
The PPWR requires reliable data on material composition, recycled content and recyclability. This data often comes from the same sources (ERP, PIM) as the data for the Digital Product Passport. A shared data approach saves effort.
4. Define a labelling and QR strategy
Decide early how you will implement harmonised labelling and whether you will use QR codes that can carry both PPWR and DPP information. A DPP platform such as myDPP helps to provide product and packaging data in a structured way.
5. Involve your supply chain
Recycled content and material data must be evidenced by suppliers. Talk to your suppliers early about the new data requirements.
Frequently Asked Questions (FAQ)
What is the PPWR in simple terms?
The PPWR is the new EU packaging regulation. It requires packaging to be recyclable, to contain a minimum share of recycled material, to use as little material as possible and to be labelled uniformly. The goal is less packaging waste and a functioning circular economy.
When does the PPWR apply?
The regulation entered into force on 11 February 2025. Most obligations apply from 12 August 2026, while further requirements such as recyclability and recycled content quotas take effect from 1 January 2030.
Does the PPWR also affect small businesses?
Yes. In principle, the PPWR applies to everyone who places packaging on the market. For certain obligations, there may be allowances or transition periods for small businesses, governed by the regulation and supplementary acts.
What does the PPWR have to do with the Digital Product Passport?
Both frameworks belong to the EU Circular Economy Action Plan and rely on digital, machine-readable data as well as data carriers such as QR codes on the product or packaging. The infrastructure for the DPP can therefore also be used for PPWR labelling.
When is PFAS banned in packaging?
The PFAS restriction for food-contact packaging applies from 12 August 2026.
Further reading
- Digital Product Passport in 15 minutes: what DPP is and why the EU introduces it
- ESPR Regulation: Ecodesign Requirements for Sustainable Products
- Why myDPP uses the GS1 Digital Link
- PPWR declaration of conformity: required fields, template and technical documentation
- PPWR labelling requirements: which label applies when
- PPWR Article 5: PFAS limits and heavy metals in packaging
- PPWR obligations: manufacturer, importer, distributor and micro-enterprises
- PPWR current status: deadlines, deferrals and missing acts