On 12 August 2026, the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, PPWR) will become fully applicable. It entered into force on 11 February 2025 and, after an 18‑month transition period, will fully replace the nearly 30‑year‑old Packaging and Packaging Waste Directive (94/62/EC). As a regulation directly applicable in all Member States, it does not require national transposition and aims to establish a unified legal framework covering the entire lifecycle of packaging.
Scope of application
The Regulation covers packaging and packaging waste of all materials (plastic, paper, metal, glass, composites, etc.) and in all scenarios (industrial, commercial, consumer, logistics), including sales packaging, grouped packaging, and transport packaging.
Obligations of manufacturers
Under Article 15 of PPWR, manufacturers must:
- Ensure packaging complies with the sustainability requirements of Articles 5 to 12;
- Before placing on the market, complete a conformity assessment and prepare technical documentation;
- After conformity is demonstrated, sign the EU Declaration of Conformity (DoC).
📌 Suppliers must provide manufacturers with all necessary compliance information and documentation.
Sustainability requirements (Articles 5 to 12)
Articles 5 to 12 of PPWR constitute the core sustainability requirements of the Regulation.
Article 5 – Restrictions on hazardous substances
The total concentration of heavy metals (lead, cadmium, mercury, hexavalent chromium) in all packaging and components shall not exceed 100 mg/kg.
For food-contact packaging, PFAS limits apply from 12 August 2026:
- any target PFAS (non-polymer) ≤ 25 ppb;
- sum of target PFAS (non-polymer) ≤ 250 ppb;
- sum of all PFAS (including polymers) ≤ 50 ppm (measured as total fluorine).
If total fluorine exceeds 50 ppm, the manufacturer or importer must provide downstream parties with proof of the fluorine source (PFAS or non-PFAS).
Article 6 – Recyclable packaging
From 12 August 2026, all packaging placed on the market must be recyclable.
From 1 January 2030, only packaging with at least 70% recyclability (grades A, B, C) may be placed on the EU market.
From 1 January 2038, only grades A and B recyclable packaging will be allowed.
Article 7 – Minimum recycled content in plastic packaging
From 1 January 2030, plastic packaging must contain a defined percentage of post‑consumer recycled (PCR) plastic.
Article 8 – Biobased feedstock in plastic packaging
The Commission must review the technical performance and environmental impact of bio‑based plastic packaging by 12 February 2028 and set sustainability requirements and usage targets for bio‑based raw materials.
Article 9 – Compostable packaging
From 12 February 2028, fruit and vegetable adhesive labels, permeable tea bags, coffee bags and beverage bags, and flexible single‑use packaging units disposed of with the content must mandatorily comply with industrial compostability standards.
Article 10 – Packaging minimisation
From 1 January 2030, manufacturers or importers must ensure that packaging is designed with its weight and volume reduced to the minimum necessary for its function, taking into account shape and materials. Packaging designed solely to increase the perceived product volume (e.g. double walls, false bottoms, extra layers) is prohibited.
Article 11 – Reusable packaging
From 11 February 2025, packaging is considered “reusable” only if it simultaneously meets all of the following: designed for multiple uses; capable of multiple trips or rotations; can be emptied/unloaded in multiple uses; can be refurbished and meet safety and hygiene requirements; and can be collected and transferred into a reuse system – with technical documentation to prove it.
Article 12 – Labelling
From 12 August 2028, packaging placed on the market must bear a uniform label containing information on its material composition.
Note: The Commission must adopt implementing acts on the uniform label design by 12 August 2026.
Other packaging labelling information requirements
- Packaging identification: The model, batch, serial number or other element allowing identification of the packaging must be indicated to ensure traceability.
- Manufacturer information: Name, registered trade name or trademark, postal address (single point of contact), and electronic contact details (if available).
- Importer information: Name, registered trademark, postal address, and electronic contact details.
How can we help you?
✅ Testing services: chemical tests for heavy metals, PFAS, total fluorine, total organic fluorine, etc.
✅ Compliance consulting: support for preparing technical documentation and the DoC.
✅ Label review: ensure your packaging labelling meets the regulatory requirements.
✅ Customised training: interpretation of the regulation and development of response strategies.
Feel free to contact us anytime!
