As from 12 August 2026, companies placing packaging on the EU market will face stricter rules relating, among other things, to recyclability, reusability, labelling, and waste management. These rules are not limited to technical product requirements but will directly affect design choices, procurement policies, supply chain structures, and contractual arrangements with suppliers and customers.

The new regulatory framework is laid down in the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40 or PPWR), which replaces the former Packaging and Packaging Waste Directive. Unlike the previous Directive, the PPWR, as a Regulation, is directly applicable in all EU Member States and therefore does not require transposition into national legislation. 

The PPWR already entered into force on 11 February 2025 and will be phased in over the coming years, with the first substantive obligations applying as from 12 August 2026. Its impact extends beyond mere product compliance and also affects internal governance and reporting obligations.

1. Objectives and scope of the PPWR

The primary objectives of the PPWR include increasing the safe use of recycled plastics in packaging and ensuring that all packaging placed on the EU market (at least 70%) is economically recyclable by 2030. To achieve these objectives, the PPWR provides for measures such as limiting the quantity of packaging and packaging waste and reducing the use of primary raw materials in packaging. Through the PPWR, the EU aims to take an important step towards achieving a climate neutral Europe by 2050.

The PPWR adopts a clear value chain approach: every party placing packaging or packaged products on the EU market, using them, or further distributing them, must correctly identify its role within the chain and comply with the related obligations.

The rules apply to the entire life cycle of all packaging placed on the EU market, regardless of the material used and the type of packaging, as well as to all packaging waste, regardless of where it is generated. The concept of “packaging” is interpreted broadly and covers any item, irrespective of the materials from which it is made, that is intended to be used by an economic operator to contain, protect, handle, deliver, or present a product to another economic operator or to an end user. For certain obligations, the PPWR provides explicit exemptions, such as for packaging used for the transport of dangerous goods or certain contact sensitive packaging of medical devices.

The economic operators are manufacturers, importers, suppliers, and distributors. Depending on the business activities, an organization may fulfil multiple roles within the packaging chain, with each role bringing distinct specific obligations.

The PPWR also imposes tasks and responsibilities on the various EU Member States, such as collecting data on packaging, reuse and recycling, as well as the implementation of registers of producers. In addition, by 12 February 2027 at the latest, Member States must implement a regime of penalties that are “effective, proportionate and dissuasive”, with the extent of the administrative fines to be determined at a later stage.

2. Obligations for the economic operators 

The PPWR primarily introduces a series of design and material requirements with which packaging and packaged products placed on the EU market must comply:

• Design for recycling: packaging must be designed with recycling as the objective. As from 2030, only packaging with recyclability grades A (at least 95% recyclable), B (at least 80%), or C (at least 70%) will be permitted. As from 2038, category C will no longer be permitted.
• Recycled packaging: minimum percentages of recycled material apply to plastic packaging, with such material originating from waste collected and recycled in accordance with EU standards.
• Limitation of empty spaces and packaging volume: excessive packaging volume and unnecessary packaging and empty space must be reduced to what is strictly necessary to ensure functionality.
• Reusable packaging: certain sectors, such as the Horeca sector, are given concrete targets for reusable and refillable packaging.
• Substances of concern: certain substances of concern in packaging are prohibited or must be strictly limited, such as PFAS above specified threshold values.

For each type of packaging, the manufacturer must carry out a conformity assessment and draw up an EU declaration of conformity and technical documentation. Such procedure and documentation must demonstrate that the packaging complies with the legal requirements.

In addition, the PPWR introduces an EU wide harmonized labelling system. A uniform label is intended to assist consumers in correctly sorting packaging materials. The label must provide information on the material composition of the packaging, including through the use of pictograms, and must take into account accessibility requirements for persons with disabilities. The responsible economic operator must ensure that the label is affixed to the packaging in a way that is visible, legible, and durable, so that it cannot be easily removed or damaged during transport, storage, or use.

3. Extended producer responsibility

In addition to the general obligations imposed on economic operators, the PPWR provides for a system of extended producer responsibility (EPR). Not only manufacturers, but also importers and distributors can, where relevant, qualify as “producer”. It is therefore advisable, for each packaging used and each market on which it is placed, to carefully analyze which party qualifies as the producer and must therefore comply with the corresponding obligations.

An entity qualifying as a producer is required to register in the register of producers of every Member State where it places packaging or packaged products on the market for the first time. In addition, the producer is responsible for financing and organizing the end of life phase of the relevant packaging, including the collection, sorting, and treatment of packaging waste, in accordance with the “polluter pays” principle. These obligations may entail additional operational, administrative, and financial implications, particularly for companies active in several Member States or dealing with diverse packaging streams.

4. Impact and preparation

As mentioned above, the PPWR will be applied in stages. The first obligations will become applicable as from 12 August 2026, while other obligations will become applicable at a later stage. For a number of provisions, the exact date of application will moreover depend on delegated and implementing acts still to be adopted by the European Commission.

Would you like a clear overview to help you navigate this phased approach? We can provide you with a chronological timeline of the PPWR obligations, tailored to your company’s activities and aligned with the obligations that are relevant to your business.

The PPWR is a comprehensive and technically complex Regulation that affects almost the entire life cycle of packaging. Moreover, many of its obligations still need to be further specified in the coming period, meaning that the regulatory framework will be progressively refined and tightened. At the same time, this offers companies a clear opportunity. Those who already think strategically about material use, packaging design, and reuse will not only be better positioned to achieve timely compliance, but also tap into the broader sustainability transition of the European market. By taking timely action, you do not only mitigate legal and operational risks, but also strengthen your market position.