EU Packaging Rules Have Changed: A Practical Guide to PPWR Compliance

What is the PPWR? 

Regulation (EU) 2025/40 aims to reduce packaging waste, improve recyclability, increase the use of recycled materials and support reuse and refill systems. It also introduces rules on packaging minimisation, substances of concern, labelling and producer responsibility. 

The regulation affects the full packaging life cycle – from design and manufacturing to placing packaging on the market and managing it after use. 

Depending on their role, obligations may apply to: 

• packaging manufacturers; 

• producers and brand owners using packaging for their products; 

• importers bringing packaged products or packaging into the EU; 

• distributors and retailers; 

• fulfilment and e-commerce businesses; 

• suppliers of packaging materials and components; and 

• companies offering reusable or refillable packaging systems. 

A business may also have more than one role. For example, a company can be an importer for one product line and a producer using packaging for another. Mapping these roles is one of the first essential compliance steps. 

The main PPWR requirements businesses need to understand 

1. Packaging must be designed for recyclability

The PPWR sets the direction for all packaging placed on the EU market to be recyclable. From 2030, packaging will need to meet design-for-recycling criteria and fall within defined recyclability performance grades. From 2035, recyclability at scale will also become relevant. 

This means companies should examine more than the main packaging material. Inks, adhesives, coatings, labels, sleeves, closures and multi-material combinations can all affect whether a packaging format can be collected, sorted and recycled effectively. 

Waiting until 2030 to start redesigning packaging may be too late. Packaging changes often require supplier engagement, testing, production trials, artwork updates and customer approval. Businesses with large packaging portfolios should begin by identifying formats that are complex, difficult to recycle or dependent on multiple materials. 

2. Minimum recycled content for plastic packaging

From 2030, certain plastic packaging will need to contain minimum percentages of post-consumer recycled plastic. The targets vary according to packaging type, with further increases planned for 2040. 

Companies using plastic packaging will need reliable information about the origin and quantity of recycled material. Procurement specifications, supplier declarations and traceability records will therefore become increasingly important. 

The regulation includes specific categories, conditions and exemptions. Businesses should not apply one recycled-content target across their entire portfolio without first classifying each packaging format correctly. 

3. Packaging must be minimised

The PPWR requires packaging weight and volume to be reduced to the minimum necessary while maintaining functionality. Businesses need to consider product protection, hygiene, safety, transport and legal requirements – but unnecessary layers, oversized boxes and avoidable empty space will be harder to justify. 

From 2030, grouped, transport and e-commerce packaging will also be subject to a maximum empty-space ratio of 50%, subject to the detailed rules and exclusions in the regulation. 

Packaging minimisation should be evidence-based. A lighter or smaller pack is not an improvement if it increases product damage, food waste or transport losses. The aim is to find the lowest necessary packaging level while preserving performance. 

4. New labelling requirements are coming

Harmonised EU labels will be introduced to help consumers identify packaging material composition and sort waste correctly. Reusable packaging will also need appropriate information, and a QR code or another standardised digital data carrier will support access to further details in certain cases. 

Most harmonised labelling obligations will apply on a later timeline linked to the adoption of implementing measures. Businesses should monitor the final technical specifications before changing all packaging artwork. Premature redesign can create unnecessary costs if colours, pictograms or data requirements change. 

5. Restrictions on substances of concern

Packaging placed on the market must comply with limits for certain hazardous substances. The PPWR also introduces specific restrictions on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging above defined thresholds. 

This makes supplier communication and material data especially important. A general statement that packaging is “food safe” or “compliant” may not provide enough evidence for every PPWR requirement. Companies should determine which test reports, declarations or technical records are needed for the materials they use. 

6. Reuse, refill and single-use restrictions

The PPWR sets reuse targets for selected packaging categories, particularly in transport and sales packaging, and introduces restrictions for certain single-use plastic packaging formats from 2030. It also supports refill and bring-your-own-container options in the takeaway sector. 

These provisions are sector- and format-specific. They should be assessed against the exact packaging use, supply chain and available exemptions rather than treated as a general requirement for all packaging to be reusable. 

7. Technical documentation and conformity obligations

Compliance will need to be demonstrated, not simply stated. The regulation introduces conformity-assessment requirements, technical documentation and an EU declaration of conformity for packaging. 

The relevant economic operator must be able to show that packaging meets applicable requirements. Depending on the packaging, evidence may include: 

• packaging specifications and composition data; 

• drawings, descriptions and intended-use information; 

• supplier declarations and contracts; 

• test reports and calculation methods; 

• recyclability assessments; 

• recycled-content evidence; 

• packaging minimisation assessments; and 

• procedures for maintaining compliance when materials or suppliers change. 

This is one of the most important practical changes. Packaging information that is currently spread across purchasing, quality, design, sustainability and legal teams will need to become a controlled and traceable compliance file. 

Key PPWR dates at a glance 

• 11 February 2025: the PPWR entered into force. 

• 12 August 2026: most provisions started to apply generally. 

• 2028 and later: several labelling and information requirements begin to apply, depending on the adoption date of the relevant implementing acts. 

• 1 January 2030: major requirements on design for recycling, recycled content, packaging minimisation, empty space, reuse and selected single-use packaging restrictions begin to apply. 

• 2035: packaging recyclability at scale becomes a key requirement. 

• 2040: higher recycled-content and waste-reduction targets apply. 

Not every requirement follows the same date. The correct timeline depends on the packaging type, the company’s role and the secondary legislation supporting the PPWR. 

Where should businesses register and check national packaging rules? 

There is no single EU website where a company can complete every PPWR registration and reporting obligation for all Member States. The PPWR creates a common EU framework, but producer registration, extended producer responsibility (EPR), packaging reporting, fees and enforcement are administered nationally. Under the PPWR, producers must register in the producer register of each Member State where they make packaging or packaged products available for the first time. Distance sellers may also need to appoint an authorised representative in the relevant country. 

In practice, a business selling in several EU countries should check, for each market: 

• the national packaging producer register and registration procedure; 

• whether an authorised representative is required; 

• extended producer responsibility registration or membership of a producer responsibility organisation; 

• packaging quantity and material reporting rules; 

• national fees, environmental taxes or eco-modulated contributions; 

• deposit-return system obligations; and 

• the national competent authority’s PPWR guidance and implementation updates. 

Start with the European Commission’s PPWR and packaging-waste pages for EU-level rules and links to implementation resources. For national obligations, use the website of the environmental ministry, environmental authority or official producer register in the country concerned. Commercial compliance platforms may be useful for monitoring, but registration decisions should always be checked against an official national source. 

National systems are still being updated to implement the PPWR. A country may therefore continue using its existing packaging and EPR framework while developing a new PPWR producer register. Businesses should record when each official source was checked and review it regularly, particularly before entering a new market. 

A practical PPWR compliance plan 

Step 1: Identify your role 

Determine where your company acts as a manufacturer, producer, importer, distributor or fulfilment service provider. Record the role for each market and product flow. 

Step 2: Build a packaging inventory 

Create a structured list of all packaging formats, components and materials. Include product packaging, labels, closures, grouped packaging, pallets, films, straps, transport packaging and e-commerce materials. 

Step 3: Classify the requirements 

For each packaging format, identify which rules may apply: recyclability, recycled content, minimisation, labelling, substances, reuse or single-use restrictions. Document possible exemptions separately instead of assuming they apply. 

Step 4: Assess the gaps 

Compare existing information with the evidence required. Flag missing composition data, outdated test reports, unclear recycled-content claims, difficult-to-recycle structures and packaging with excessive empty space. 

Step 5: Engage suppliers 

Update packaging specifications and supplier questionnaires. Define which declarations, test methods, traceability records and change notifications suppliers must provide. 

Step 6: Prioritise redesign work 

Start with high-volume packaging and formats most likely to face compliance challenges. Allow time for testing, technical approval, sourcing changes and updated artwork. 

Step 7: Establish document control 

Assign clear ownership for technical files and declarations. Packaging changes should trigger a review of compliance evidence, not only a purchasing or design approval. 

Step 8: Review environmental claims 

Terms such as “recyclable”, “recycled”, “circular” and “sustainable packaging” should be specific, supportable and consistent with the actual packaging. PPWR compliance does not automatically validate every environmental marketing claim. 

How independent certification and verification can support packaging compliance 

There is no single certificate that automatically proves full PPWR compliance. The legal responsibility remains with the relevant economic operator. However, independent assessment can strengthen specific parts of a company’s evidence and management system. Depending on the packaging material, claim and supply chain, relevant support may include: 

• certification of responsible fibre sourcing and chain of custody for paper- and wood-based packaging; 

• verification of recycled-material or traceability claims where an applicable scheme is available; 

• environmental management system certification, such as ISO 14001; 

• life-cycle assessment and Environmental Product Declaration services to support reliable environmental data; and 

• independent review of sustainability information and supporting records. 

These services do not replace a legal PPWR assessment. They can, however, help businesses improve traceability, strengthen data quality and provide credible evidence for defined claims. 

BM Certification supports companies across international markets with independent certification, verification, assessment and training services. If you are reviewing your packaging supply chain, environmental claims or supporting management systems, our team can help you identify which independent service is relevant to your specific goals. 

Contact BM Certification to discuss the certification or verification needs connected with your packaging and sustainability strategy.

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Further Reading and Official Sources: 

• European Commission, Packaging waste: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en 

• European Commission, Packaging & Packaging Waste Regulation: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en 

• European Commission, PPWR Frequently Asked Questions, 3 August 2026: https://environment.ec.europa.eu/publications/faq-packaging-and-packaging-waste-regulation-ppwr_en 

• EUR-Lex, Regulation (EU) 2025/40: https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng