PPWR 2026: What the EU Packaging Regulation Means for Your Business

From Directive to Regulation – What Changes?

The previous Packaging Directive 94/62/EC was an EU directive that had to be transposed into national law by each member state. This resulted in a patchwork of different national rules.

The PPWR regulation is an EU regulation – it applies directly and uniformly across all EU member states, without the need for national transposition. This means:

• Uniform rules across all 27 EU countries
• Same requirements for all market participants
• Less room for interpretation at the national level
• Stricter enforcement by market surveillance authorities

Who Is Affected by the PPWR Regulation?

The EU PPWR affects all economic operators involved in the packaging supply chain:

• Manufacturers: Companies that produce or commission the production of packaging
• Importers: Companies bringing packaging into the EU from third countries
• Distributors & retailers: Companies making packaging available on the EU market
• Fulfillment service providers: Service providers that store and ship packaging
• Authorized representatives: EU representatives for manufacturers based outside the EU

Key Requirements of the EU PPWR at a Glance

1. Substance Restrictions (Article 5)

The PPWR regulation sets strict limits for certain substances in packaging:

• Heavy metals: The sum concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg
• PFAS: Per- and polyfluoroalkyl substances must not exceed the specified thresholds
• REACH: All substances must comply with Regulation (EC) No 1907/2006 (REACH)

Companies must be able to demonstrate compliance with these restrictions – based on supplier declarations, safety data sheets, and where applicable, analytical test reports.

2. Declaration of Conformity (DoC)

For every packaging placed on the EU market, a Declaration of Conformity must be prepared in accordance with Annex VII. This formally confirms that the packaging meets all applicable PPWR requirements.

The DoC must contain 8 mandatory sections, including packaging identification, producer information, a detailed packaging description, and evidence of substance compliance.

3. Recyclability

The PPWR regulation introduces binding recyclability requirements for packaging. Packaging must be designed so that it can actually be recycled after use. Requirements will be tightened over time:

• From 2030: Packaging must be classified as recyclable
• From 2035: Packaging must be recyclable “at scale” (demonstrably recycled in practice)

4. Minimum Recycled Content

For plastic packaging, the PPWR regulation mandates minimum shares of recycled plastic:

• From 2030: Between 10% and 35% recycled content depending on packaging type
• From 2040: Increase to 50% to 65% depending on packaging type

Contact-sensitive packaging (e.g., food packaging) is subject to separate requirements.

5. Labeling

The EU PPWR harmonizes labeling requirements for packaging across the entire EU:

• Material identification: Standardized labeling of packaging materials
• Sorting instructions: Clear instructions for consumers on proper disposal
• Digital data carrier: QR code or comparable data carrier with extended packaging information

6. Reuse

Reuse targets are introduced for certain packaging categories. This applies in particular to transport packaging and certain beverage packaging. The exact quotas and timelines vary by packaging category.

7. Packaging Minimization

Packaging must be reduced to the necessary minimum. Excessive packaging, unnecessary empty spaces, and double walls will be restricted. The regulation defines specific criteria and maximum limits for the packaging-to-content ratio.

8. Extended Producer Responsibility (EPR)

Extended Producer Responsibility will be harmonized across the EU. Producers bear the financial responsibility for the collection, sorting, and recycling of their packaging. EPR fees will increasingly be differentiated based on environmental criteria (eco-modulation).

Timeline: Key PPWR Regulation Deadlines

Checklist: How to Prepare for the PPWR

1. Take stock: Identify all packaging in your portfolio – types, materials, and quantities
2. Collect supplier data: Request material data, REACH declarations, and safety data sheets from your packaging suppliers
3. Check substance compliance: Assess all packaging for heavy metal, PFAS, and REACH compliance
4. Create Declarations of Conformity: Prepare a DoC for each packaging in accordance with Annex VII
5. Build technical documentation: Collect and archive all supporting documents (minimum 5-year retention requirement)
6. Update labeling: Plan the transition to the new EU-wide labeling standards
7. Assess recyclability: Analyze your packaging for recyclability and identify necessary action items

Official Legal Text

The full text of Regulation (EU) 2025/40 is available in the Official Journal of the European Union:

Regulation (EU) 2025/40 – Full text on EUR-Lex