PPWR requirements explained

PPWR, the EU packaging regulation, has applied since 12 August 2026, but its requirements do not all start that day. Some bite immediately, others arrive in 2028, 2030 and as late as 2040.

PPWR treats packaging as a regulated product. It sets rules for what a pack is made of, what it says on it and the paperwork that proves both, and the manufacturer signs off on all of it. This guide walks through each part with the date it starts.

Key PPWR requirements and their start dates

Below are the requirements of Regulation (EU) 2025/40 that land on companies, in the order they start.

"At the earliest" marks the requirements that start on a fixed date or a set time after a Commission act, whichever comes later. The section on what is still being decided lists those acts.

The table follows the text of Regulation (EU) 2025/40 on EUR-Lex, which has applied in every EU country since 12 August 2026 without any national law needed. It replaced the old Packaging Directive 94/62/EC, and the glossary entry on what PPWR is covers that background.

What PPWR requires of the packaging itself

Articles 5 to 11 set the rules for what a pack is made of and how it is built. They cover all packaging, whatever the material, and they are the requirements the EU declaration of conformity confirms.

The rules bite when a pack is "placed on the market", which means the first time it is supplied in the EU, empty or filled, so they land on the company that does that.

Restricted substances under Article 5

Since 12 August 2026 the sum of lead, cadmium, mercury and hexavalent chromium in any packaging or packaging part may not exceed 100 mg/kg.

Food-contact packaging also faces limits on PFAS, the forever chemicals, from the same date. It may not be placed on the market at 25 ppb or more for any single PFAS, 250 ppb or more for the sum of PFAS, or 50 ppm or more for all PFAS including polymers.

Recyclability grades under Article 6

All packaging has to be recyclable. Recyclability is expressed as a grade, A, B or C, set by criteria the Commission must adopt by 1 January 2028.

From 1 January 2030, or 24 months after those criteria come into force if that is later, packaging below grade C may not be placed on the market. From 1 January 2038 the bar rises to grade A or B.

From 1 January 2035 at the earliest, packaging must also be recycled at scale. That means at least 55% of that kind of packaging, or 30% for wood, actually gets recycled across the EU each year, so a pack that is recyclable only in theory no longer counts.

Recycled content in plastic under Article 7

Every plastic part of packaging needs a minimum share of post-consumer recycled content, counted as an average per manufacturing plant and year. Contact-sensitive packaging, the packaging for food, animal feed, medicines, cosmetics, medical devices and food supplements, gets lower targets.

Below are the four minimums, first from 1 January 2030 at the earliest and then from 1 January 2040.

1. Contact-sensitive packaging mainly made of PET (not drinks bottles). 30% from 2030, 50% from 2040.
2. Contact-sensitive packaging of other plastics. 10% from 2030, 25% from 2040.
3. Single-use plastic drinks bottles. 30% from 2030, 65% from 2040.
4. All other plastic packaging. 35% from 2030, 65% from 2040.

The 2030 tier starts on 1 January 2030 or three years after the Commission's calculation rules come into force, whichever is later. The guide to PPWR requirements for plastic packaging goes through the exemptions.

Design rules for specific packs under Articles 9 to 11

Three more design rules apply to specific packs or claims.

1. Compostable. By 12 February 2028, tea bags, single-serve coffee and tea units and the sticky labels on fruit and vegetables must suit industrial composting. Other packaging must be designed for recycling.
2. Minimised. By 1 January 2030, the manufacturer or importer must keep weight and volume to what the pack needs to work. Double walls, false bottoms and layers that only make a product look bigger are not allowed, with narrow exceptions for protected designs.
3. Reusable. Packaging sold as reusable must meet nine conditions, among them being designed for as many rotations as possible. A minimum number of rotations is due by 12 February 2027.

How PPWR packaging must be labelled

Labelling sits in Article 12, with the manufacturer's own details in Article 15. Some of it applies today and some of it waits for a Commission act.

Below are the four labelling rules and when each one starts.

1. Maker's details, now. Since 12 August 2026 the manufacturer's name, trade name or trademark and postal address must be on the pack, or behind a QR code or a similar digital code. The pack also needs a type, batch or serial number so it can be traced.
2. Material label, from 12 August 2028 at the earliest. A harmonised label based on pictograms tells consumers what the pack is made of, so they can sort it.
3. Reusable label, from 12 February 2029 at the earliest. Reusable packaging must say so, with more detail behind a QR code.
4. Old stock. Packaging made or imported before a label date may still be sold for three years after it.

The material label also ends the old plastic codes such as PET 1 and PP 5, which the guide to plastic recycling codes under PPWR explains.

Which packaging formats PPWR bans or caps

Chapter V of PPWR goes past the design of a single pack and limits whole formats.

Below are the six single-use formats PPWR bans from 1 January 2030.

1. Single-use plastic grouping packaging used at the point of sale to bundle bottles, cans, tins, pots, tubs and packets.
2. Single-use plastic packaging for fresh fruit and vegetables in packs under 1.5 kg.
3. Single-use plastic packaging for food and drink filled and eaten on the premises of hotels, restaurants and cafés.
4. Single-use plastic portions of sauces, sugar, creamer and condiments in those same premises.
5. Single-use toiletry packaging in hotels and other accommodation.
6. Very lightweight plastic carrier bags, with exceptions for hygiene and loose food.

Two caps start the same day. The first is about air in the box. Grouped packaging (the outer pack bundling several items, like a six-pack wrap), transport packaging and e-commerce packaging may hold at most 50% empty space, and paper fill, air cushions and bubble wrap count as empty.

At least 40% of transport packaging used inside the EU, such as pallets, plastic crates and drums, must be reusable within a reuse system, with an aim of 70% from 2040. Cardboard boxes are exempt from that target.

Who carries each PPWR duty in the supply chain

PPWR puts most duties on the manufacturer and gives the companies further down the chain a duty to check.

Below are the four roles and what each one owes.

1. Manufacturer. Whoever makes the packaging, or has it made under their own name or trademark. The manufacturer makes sure the pack meets articles 5 to 12 and draws up the paperwork.
2. Importer. Places packaging from outside the EU on the market only after checking that the manufacturer did the assessment and documentation, and that labels and maker details are in place.
3. Distributor. Checks that the producer is registered for EPR, the pack is labelled and the maker details are on it.
4. Importer or distributor who rebrands or changes the pack. Becomes the manufacturer and takes on every manufacturer duty.

There is one relief for the smallest brands. When a micro-enterprise has packaging made under its own name by a supplier located in the EU, that supplier counts as the manufacturer instead.

The paperwork every PPWR pack needs

Before a pack goes on the market, its manufacturer has to prove it meets the rules and put that in writing.

Below are the three documents and what each one does.

The technical documentation is what an authority asks for when it doubts a declaration, so it has to exist before the pack ships, not after.

Both the documentation and the declaration are kept for 5 years for single-use packaging and 10 years for reusable packaging, counted from the day the pack was placed on the market.

Much of the evidence comes from suppliers, and the guide on requesting packaging data from suppliers covers that step.

Where EPR fits next to PPWR

PPWR also carries the EU's rules on extended producer responsibility, the system where producers pay for the packaging waste they create. It runs alongside the product requirements above, not instead of them.

Below are the three EPR rules that land on companies.

1. Register in each country. Producers register in every EU country where they first make packaging available.
2. Pay for the waste. They carry extended producer responsibility for that packaging, usually through a producer responsibility organisation.
3. Expect deposit systems. EU countries must collect 90% of single-use plastic bottles and metal drinks cans up to three litres separately by 1 January 2029, usually through a deposit return system.

A company can be fully registered for EPR and still miss every requirement above, because the two answer different questions. EPR asks what you put on the market, and the product rules ask whether it meets the standard.

PPWR rules that are still being decided

Several requirements depend on acts the Commission still has to adopt, so their exact content or start date is open. As of October 2026, five of them matter most to packaging companies.

Below are the five acts, each with its legal deadline.

The label act is the one already late. As of 5 October 2026 the European Commission's planning page showed it in preparation, with adoption planned for the fourth quarter of 2026.

The European Commission's packaging waste page is where these acts appear once they are published. Where a start date reads "at the earliest" in the table above, it moves when the act behind it is late.

What to do about PPWR now

PPWR already applies, so some work cannot wait, while the 2030 rules need redesign time that starts well before 2030.

Below are the five steps that put a packaging company in a sound position.

1. List your packaging. Write down every packaging type you place on the market, including shipping boxes and transport packaging, since each type needs its own paperwork.
2. Check the 2026 rules. Get your suppliers to confirm the heavy metal limits for every pack and the PFAS limits for food packaging, in writing.
3. Mark every pack. Make sure each one shows your name and postal address, or a QR code leading to them, plus a type or batch number.
4. Write the paperwork. Build the technical documentation and sign an EU declaration of conformity for each packaging type before it ships.
5. Plan the 2030 changes. Flag packs that may miss a recyclability grade, the recycled plastic minimums or the 50% empty space cap, or that use a banned format, and schedule the redesigns.

How Declare fits the PPWR requirements

Every design and labelling rule in articles 5 to 12 ends in one document, the EU declaration of conformity. The guide to the EU declaration of conformity walks through it field by field.

Repax Declare builds that declaration for each packaging type, with all 8 Annex VIII fields and the signature block, a QR code linking to the live declaration and a new version whenever the pack changes.

Declare does not make packaging compliant. The pack itself still has to meet articles 5 to 12, and that stays the manufacturer's responsibility under article 15. Declare makes the declaration correct, traceable and ready when an authority asks.

Frequently asked questions about PPWR requirements

Below are the six questions packaging companies ask most often about what PPWR requires.

When do the PPWR requirements start to apply?

PPWR has applied since 12 August 2026, and the substance limits, the paperwork and the maker's details started that day. Other requirements follow in steps, with the sorting label from 2028, recyclability and recycled content from 2030 and the strictest targets in 2038 and 2040.

Does PPWR apply to small companies?

Yes. The packaging requirements have no size threshold. The one relief is for micro-enterprises, because when a micro-enterprise has packaging made under its own name by a supplier in the EU, that supplier counts as the manufacturer for the duties in article 15.

Do I need a third-party certificate under PPWR?

No. PPWR uses Module A, internal production control, so the manufacturer assesses the packaging and declares it compliant on their own responsibility. No notified body is involved, but the evidence must sit in the technical documentation.

Is PPWR the same as EPR?

No. EPR is about paying for the packaging waste you create, through registration and fees in each country. PPWR adds product rules on top, so the packaging itself must meet set standards and the manufacturer must declare that it does.

Which PPWR requirements are not final yet?

Recyclability grades, the recycled content calculation, the harmonised label, reuse rotations and the empty space method all wait on Commission acts. As of October 2026 the label act was planned for the fourth quarter of 2026.

What does the EU declaration of conformity have to cover?

It states that the packaging meets the requirements in articles 5 to 12 of PPWR, from substances and recyclability to labelling. It follows the Annex VIII model with 8 numbered fields and a signature block, and is kept for 5 or 10 years.