PPWR: What the New Rules Mean for Your Product Packaging

What Is the PPWR (Regulation (EU) 2025/40) and When Will It Take Effect?

The PPWR is a regulation adopted by the European Parliament and the European Council on 16 December 2024 as part of the EU's Circular Economy Action Plan. It replaces the Packaging and Packaging Waste Directive 94/62/EC, which had been in force since 1994.

The regulation entered into force on 11 February 2025. However, its provisions will generally apply from 12 August 2026, following an 18-month transition period. The PPWD will be repealed on the same date.

Important distinction: Unlike a directive, which requires transposition into national law, a regulation applies directly and uniformly across all EU Member States without the need for national implementing legislation. Member States are barred from introducing additional national packaging requirements unless explicitly permitted by the PPWR.

The PPWR will be rolled out gradually over more than a decade, with different obligations becoming applicable between 2026 and 2040. While 12 August 2026 marks the beginning of general application, many substantive requirements—such as recyclability grades and packaging minimisation rules—will take effect in 2028, 2029, and 2030.

The regulation applies to all packaging placed on the EU market, regardless of material, origin, or use. This includes sales packaging, grouped packaging, transport packaging, and e-commerce packaging. Non-EU businesses selling packaged products or packaging into the EU are also subject to the PPWR

PPWR Packaging Requirements: What Changes for Cardboard Packaging?

For manufacturers and users of paper and cardboard packaging, the PPWR brings significant new obligations focused on recyclability, material efficiency, and documentation.

Design for recycling is paramount. The PPWR requires packaging to be developed in such a way that it can be recycled as effectively as possible at the end of its life cycle. For cardboard packaging, this means materials, coatings, printing inks, adhesives, and finishes must be carefully evaluated for their impact on recycling processes. Packaging must be designed to be easily sortable and fully recyclable, fitting into specific waste streams.

Packaging minimisation is a core requirement. Packaging must be reduced in both volume and weight without compromising functionality. Unnecessary packaging components, excessive empty space, and designs that primarily increase perceived product volume will come under greater scrutiny. Product protection, functionality, appearance, machine runnability, and material use must be coordinated more precisely.

Substance restrictions affect cardboard packaging. The PPWR includes provisions on substances of concern, including heavy metals and PFAS. Packaging containing PFAS or critical direct printing inks will be classified as non-recyclable. Paper, board, and cardboard packaging must meet the same sorting criteria as paper-based composites.

Recycled content requirements are less stringent for paper. Binding minimum recycled-content requirements under the PPWR mainly apply to plastic packaging or plastic components. For paper and cardboard packaging, the focus is primarily on recyclability, material efficiency, design for recycling, and documentation and evidence requirements.

PPWR Recyclability Classes: What to Expect from 2030

One of the most consequential provisions of the PPWR is the introduction of mandatory recyclability performance grades. From 1 January 2030, all packaging must meet minimum recyclability performance grades.

The PPWR defines three performance grades:

• Grade A: Packaging that is at least 95% recyclable (by weight per unit)

• Grade B: Packaging that is at least 80% recyclable (by weight per unit)

• Grade C: Packaging that is at least 70% recyclable (by weight per unit)

From 2030, packaging below Grade C will be prohibited from being placed on the EU market. From 1 January 2038, only packaging meeting Grade A or B will be acceptable.

These grades apply to all packaging materials—cardboard, plastics, glass, and metals alike. Packaging must not only be technically recyclable but also capable of being collected, sorted, and reprocessed at scale.

The recyclability assessment will be conducted according to design-for-recycling criteria developed by the European Commission. The minimum threshold for Grade C corresponds to a recyclability rate of at least 70%

E-Commerce Packaging Under PPWR: New Limits on Empty Space

E-commerce packaging faces particularly stringent new rules under the PPWR, with limits on empty space designed to reduce waste and improve shipping efficiency.

The empty space ratio must not exceed 50%. Under Article 10 of the PPWR, the empty space ratio in grouped, transport, and e-commerce packaging used for the supply of products to final distributors or end users shall not exceed 50%. Some sources indicate the limit is 40%, reflecting different interpretations of the phased implementation.

Filling materials count as empty space. Space filled by filling materials such as paper cuttings, air cushions, bubble wrap, sponge fillers, foam fillers, wood wool, polystyrene, or Styrofoam chips is considered empty space. This prevents brands from circumventing the rule by using excessive void fill.

The rule applies from August 2026. The empty space restrictions become applicable from 12 August 2026, with further tightening expected by 2030.

Non-compliance carries penalties. Without solutions to effectively rightsize packaging at scale, logistics operations are at risk of incurring penalties that will soon be coming into force.

Understanding PPWR Harmonised Packaging Labels

The PPWR introduces harmonised labelling requirements to improve consumer sorting and recycling.

Harmonised labels will be mandatory from August 2028. From 12 August 2028, packaging placed on the market must bear harmonised pictogram labels indicating recyclability and sorting instructions. These labels must be accessible to all users, including people with disabilities.

The labelling system is based on text-free pictograms. The European Commission will adopt implementing acts defining the harmonised labels by 12 August 2026. Industry coalitions have called for a pragmatic approach with maximum flexibility, supporting text-free pictograms available in achromatic or monochromatic versions that integrate with existing packaging designs.

Digital labelling is also permitted. A QR code or another type of standardised, open digital data carrier may be placed on the packaging to provide information on the destination of each separate component of the packaging and to facilitate consumer sorting.

Reusable packaging labels will follow. From 12 February 2029, packaging placed on the EU market must bear a label informing whether the packaging is reusable. The EU Digital Product Passport will also play a role in providing traceability information.

Compostable packaging must be clearly labelled. Labels must indicate that the material is compostable, that it is not suitable for home composting, and that compostable packaging is not to be discarded in nature.

PFAS and Heavy Metals: Restricted Substances in Packaging

Article 5 of the PPWR sets out strict restrictions on substances of concern in packaging, with particular attention to heavy metals and PFAS (per- and polyfluoroalkyl substances).

Heavy metals are subject to a strict total limit. The combined total of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg per item of packaging or packaging component. This limit applies to all packaging, regardless of its intended use. The restriction takes effect from 12 August 2026.

PFAS in food-contact packaging are restricted from August 2026. From 12 August 2026, food-contact packaging may no longer be placed on the market if it reaches or exceeds specific limit values:

• 25 ppb for individual PFAS (polymeric PFAS excluded)

• 250 ppb for the sum of PFAS (targeted analyses; polymeric PFAS excluded)

• 50 ppm for PFAS including polymeric PFAS

No quantity thresholds or de minimis limits apply. As soon as packaging is placed on the market, the limit values must be complied with—regardless of company size or number of units. No distinction is made as to whether PFAS were intentionally added or unintentionally present.

Additional documentation requirements exist. If the total fluorine content of packaging exceeds 50 mg/kg, manufacturers or importers must, upon request, be able to demonstrate what proportion of the fluorine is attributable to PFAS and what proportion to non-PFAS substances.

What Is the PPWR Declaration of Conformity and Why Does It Matter?

From 12 August 2026, no packaging may be placed on the EU market unless it is supported by a valid Declaration of Conformity (DoC) and complete technical documentation.

The DoC is a legally binding self-declaration. It is the producer's written statement that a specific packaging item meets the requirements of Articles 5 to 12 of the PPWR. By signing the DoC, the producer assumes full legal responsibility for the conformity of the packaging.

The PPWR deliberately does not use CE marking for packaging. Recital 109 explains that a CE mark on packaging could be confused with product-related CE markings. PPWR conformity is instead demonstrated exclusively through the DoC and the underlying technical documentation.

Mandatory contents of the DoC are specified in Annex VIII. These include:

• Unique identification number of the declaration

• Name and address of the producer

• Declaration that the DoC is issued under the sole responsibility of the producer

• Unique identification of the packaging, including type, batch, serial number, or other traceability elements

• Description of the packaging, including materials and essential characteristics

• Declaration of conformity with explicit reference to Regulation (EU) 2025/40

Technical documentation must be prepared and retained. This typically includes a description of the packaging, conceptual design, drawings, materials used, explanations of how the packaging functions, relevant specifications, a qualitative assessment, and test reports.

Retention periods apply. Documentation must be retained for five years for single-use packaging and ten years for reusable packaging

Who Is Responsible for PPWR Compliance?

Responsibility under the PPWR is shared across the packaging supply chain, with primary accountability resting with the manufacturer.

The manufacturer is any economic operator who manufactures packaging or packaged products, has them designed or manufactured under its own name or trademark, and places them on the EU market for the first time. This includes brand owners, retailers with private labels, and importers. Online retailers may also fall under the manufacturer's responsibility.

Importers must ensure compliance has been demonstrated before placing packaging on the market. They must obtain and hold a copy of the manufacturer's DoC and ensure that the technical documentation is available to market surveillance authorities upon request.

Distributors must also ensure compliance has been demonstrated before placing packaging on the market.

Suppliers must provide the necessary data and documentation to support compliance.

The PPWR applies to non-EU businesses selling packaged products or packaging into the EU. Non-compliant goods risk being rejected at EU borders or subject to enforcement action once on the market.

How Can You Still Use “Sustainable” Claims on Packaging?

The PPWR does not prohibit the use of sustainability claims on packaging, but it introduces stricter requirements for substantiation and transparency.

Claims must be accurate and verifiable. Any sustainability claim—such as "recyclable," "compostable," or "made from recycled content"—must be supported by evidence that can be provided to authorities upon request. The technical documentation required for the DoC provides a framework for substantiating such claims.

Claims must align with PPWR definitions. The PPWR establishes specific definitions for terms such as "recyclable," "reusable," and "compostable." Sustainability claims must use these terms consistently with their regulatory definitions.

Harmonised labelling will provide clarity. The introduction of harmonised labels for recyclability and sorting will reduce confusion and provide consumers with clear, standardised information.

Avoid misleading claims. The PPWR's focus on transparency and documentation means that unsubstantiated or misleading sustainability claims carry increased risk. Brands should ensure their claims are accurate, specific, and supported by evidence.

When Should You Review and Update Your Packaging?

The time to act is now. While some compliance deadlines may feel distant, packaging redesign, supply chain adjustments, and regulatory approvals take significant time.

Immediate priorities (by 12 August 2026):

• Ensure compliance with substance restrictions, including heavy metals and PFAS in food-contact packaging

• Register with appropriate Extended Producer Responsibility (EPR) organisations for each EU Member State where products will appear

• Prepare the Declaration of Conformity and technical documentation for each packaging type

• Implement packaging minimisation measures, including empty space limits for e-commerce packaging

Short-term priorities (2027–2028):

• Prepare for harmonised labelling requirements from 12 August 2028

• Address single-use plastic format restrictions

• Prepare for reuse and refill obligations in the HORECA sector

Medium-term priorities (2030):

• Ensure all packaging meets minimum Grade C recyclability

• Meet minimum recycled content requirements for plastic packaging

• Achieve packaging waste reduction targets

• Meet reuse and refill targets

Long-term priorities (2035–2040):

• Ensure all packaging meets Grade B or above recyclability from 2038

• Meet increased minimum recycled content targets

• Achieve packaging waste reduction targets of 10% by 2035 and 15% by 2040

Conclusion

The PPWR represents a fundamental transformation of packaging regulation in the European Union. For businesses that place packaging on the EU market—whether based in Europe or exporting from abroad—compliance is not optional. The regulation imposes binding requirements across the entire packaging life cycle, from substance restrictions and recyclability mandates to packaging minimisation, harmonised labelling, and comprehensive documentation.

The phased timeline provides some breathing room, but the most significant deadlines are approaching rapidly. Businesses that begin preparing now—reviewing their packaging portfolios, engaging with suppliers, and building the necessary documentation systems—will be best positioned to meet the new requirements and maintain access to the EU market.

Packaging is no longer just about protection and presentation. Under the PPWR, it is about sustainability, transparency, and accountability. The brands that embrace these changes will not only comply with the law but also build trust with increasingly environmentally conscious consumers.