The PPWR requirements for plastic packaging come to six in total, phased in from 2026 through to 2038. Everything from the Declaration of Conformity to recycled-content targets applies to it.
Plastic is the material the regulation works hardest to change, so on top of the duties every packaging type shares it also carries the recycled-content and recyclability rules. This page walks through the full set and when each one starts.
Which PPWR requirements apply to plastic packaging?
Plastic carries six requirements, phasing in between 2026 and 2038. The timeline below shows when each one starts to bite.
The table below is the quick reference. It lists all six requirements, confirms that each one applies to plastic packaging, and gives the date each starts to bite. The sections after it explain what every requirement means in practice.
| Requirement | Applies to plastic | From |
|---|---|---|
| EU Declaration of Conformity plus technical documentation | Yes | 12 August 2026 |
| Substances of concern (heavy metals, and PFAS for food-contact) | Yes | 12 August 2026 |
| Harmonised labelling | Yes | 12 August 2028 |
| Design for recycling and recyclability grades | Yes | grades from 2030, class B minimum from 2038 |
| Minimum recycled content | Yes, plastic only | 2030, higher tier 2040 |
| Packaging minimisation and empty-space limits | Yes | 2030 |
What each requirement means for plastic
Here is what each of the six requirements asks of a plastic pack.
The Declaration of Conformity
This is the anchor requirement. From 12 August 2026 every plastic packaging type you place on the market needs a signed declaration and an Annex VII technical documentation file behind it. Without them the packaging cannot legally be on the market.
Substances of concern
These cap the heavy metals in the packaging (lead, cadmium, mercury and hexavalent chromium together, not above 100 mg/kg). For food-contact plastic, the PFAS limits also apply from 12 August 2026.
Harmonised labelling
This arrives from 12 August 2028. Plastic packaging will need to carry standardised material and sorting information in the EU-wide format set by implementing acts.
Design for recycling
Plastic packaging must meet recyclability grades from 2030, and reach at least class B from 2038. Packaging that cannot be graded is phased off the market over that period.
Minimum recycled content
This is the plastic-specific requirement. From 2030, plastic packaging must contain a set share of post-consumer recycled plastic, rising again in 2040. The targets vary by category, and the detail sits on our Article 7 guide.
Minimisation
Plastic packaging must be no heavier or larger than it needs to be from 2030, with limits on empty space in grouped, transport and e-commerce packaging.
How the six rules land on two plastic items
The six requirements are the same for every plastic pack, but how much work each one takes depends on the format. A PET drinks bottle and a multilayer film pouch, both plastic, show the gap.
Take a PET drinks bottle. It needs the same declaration, substance checks, recyclability grade, recycled content, minimisation and labelling as anything else, and most of that is routine.
PET is one of the most widely recycled plastics, so the bottle meets its recyclability grade comfortably. Recycled PET is available to buy, so the recycled-content target due in 2030 is realistic too. Its real job is paperwork, not redesign.
A multilayer film pouch, the kind used for snacks or refills, faces exactly the same six rules. The difference is recyclability.
A pouch bonds several thin layers together, and those layers are hard to separate and recycle. So the recyclability grade from 2030 is the requirement that takes real design work, often a move to a single-material film.
Everything else, the declaration, the substance limits and the label, lands the same way it does for the bottle.
So the useful planning question for plastic is not which rules apply, all six do, but which rule will cost you redesign time. For most rigid plastic that is a light lift. For flexible, multi-layer formats, recyclability is the one to start on now.
What does not apply to plastic packaging?
Two things people expect to hit plastic actually do not.
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General compostability is not required. Article 9 only mandates compostability for a narrow list (tea and coffee bags, fruit and vegetable stickers), not plastic packaging at large.
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Bio-based content is not required either. The regulation asks the Commission to study bio-based plastic by February 2028, but there is no obligation on producers today.
What your Declaration of Conformity must attest for plastic
Your Declaration of Conformity has to state that the plastic packaging meets each requirement that applies to it on the relevant date.
In practice that means the evidence has to be ready in the technical documentation file, covering the recyclability assessment, recycled-content records from 2030, substance compliance, and the labelling sample.
Building and versioning that declaration as the rules phase in is exactly the manual work Repax Declare is built to remove.
How to get plastic packaging ready
You do not have to solve all six requirements at once, they phase in over more than a decade. Working in deadline order keeps the effort where the clock is closest.
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List every plastic pack you place on the market. One declaration covers one packaging type, so the first job is simply knowing how many types you have. Bottles, trays, films, caps and pouches each count.
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Check the substance limits first. Heavy metals, and PFAS for food-contact plastic, both bite on 12 August 2026. Confirm with your supplier that each pack sits under the limits before that date.
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Draw up the declaration for each type. This is the 12 August 2026 obligation. Our guide on how to create an EU Declaration of Conformity walks through the declaration and the technical file behind it.
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Plan the recyclability and recycled-content work early. Neither bites until 2030, but a redesign takes time. Flag any pack that is hard to recycle now, so you are not redesigning against a deadline.
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Keep each declaration current. A declaration describes the packaging as it is. Change the material, the size or the supplier and the declaration has to be re-issued.
The real work PPWR creates for plastic is getting from a list of packs to a correct, up-to-date declaration for every one of them, so starting that list early is what keeps it manageable.
How this connects to the wider rules
Plastic sits under the same regime as every other material, it just carries more of it. The requirements that apply to all packaging, like the recyclability rules, sit alongside the plastic-specific recycled-content target.
The full regulation is on EUR-Lex, and the European Commission keeps an overview on its packaging waste pages.
PPWR and plastic packaging questions answered
The questions we hear most about how PPWR treats plastic packaging.
Does PPWR apply to all plastic packaging?
Yes. Every plastic packaging type placed on the EU market is in scope, from bottles and trays to films and pouches, primary, secondary and transport packaging alike.
When do the plastic recycled-content rules start?
The minimum recycled-content targets apply from 1 January 2030, with a higher tier from 2040. They are separate from the 12 August 2026 date when the Declaration of Conformity obligation begins.
Does plastic packaging have to be compostable under PPWR?
No. General compostability is not required for plastic packaging. Article 9 only mandates it for a narrow list of items such as tea and coffee bags and fruit and vegetable stickers.
What has to be ready for plastic packaging by 12 August 2026?
A signed EU Declaration of Conformity and an Annex VII technical documentation file for each plastic packaging type, plus compliance with the substance limits and manufacturer identification on the packaging.
Do the recyclability grades apply to plastic straight away?
No. Recyclability grades apply from 2030, and plastic packaging must reach at least class B from 2038. The Declaration of Conformity obligation itself starts earlier, in 2026.
