With less than two months remaining until the first mandatory requirements of the EU Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40) take effect, companies should ensure they are fully prepared for compliance. From 12 August 2026, the first provisions of the PPWR will become directly applicable across all EU Member States, and packaged products that do not comply with the new requirements may no longer be placed on the EU market.
As a Regulation, the PPWR replaces the previous Packaging and Packaging Waste Directive (94/62/EC) and is directly applicable in all EU Member States without the need for national transposition. Consequently, companies placing packaged products on the EU market will be required to comply with a single harmonised regulatory framework across the EU.
Who Will Be Affected?
The PPWR applies not only to packaging manufacturers, but also to:
- Manufacturers of packaged products
- Importers and distributors
- E-commerce operators
- Non-EU manufacturers exporting products to the EU
- Authorized representatives
In other words, all economic operators placing packaged products on the EU market will be subject to the Regulation.
PPWR Implementation Timeline
The PPWR will be implemented in phases rather than all at once.
11 February 2025 – 11 August 2026 | Transition Period
During this period, companies are expected to review their packaging portfolio, assess packaging materials, evaluate hazardous substances, identify alternative materials where necessary, initiate Extended Producer Responsibility (EPR) registration procedures, and prepare for the upcoming labelling requirements.
12 August 2026 – 11 February 2028 | First Mandatory Compliance Phase
The following requirements will become applicable:
- Compliance with heavy metal concentration limits for packaging;
- PFAS restrictions for food contact packaging;
- Completion of conformity assessment procedures;
- Preparation of the EU Declaration of Conformity (DoC);
- Preparation and maintenance of technical documentation;
- Completion of Extended Producer Responsibility (EPR) registration, where applicable;
- Initial implementation of restrictions on certain single-use plastic packaging.
12 February 2028 – 31 December 2029
Additional provisions concerning compostable packaging, harmonised labelling, deposit return systems (DRS), and packaging minimisation will begin to apply.
1 January 2030 – 10 January 2038
The most comprehensive PPWR obligations will enter into force, including mandatory recycled content targets, recyclability performance grades, and packaging reduction requirements.
From 11 January 2038
The final implementation stage will begin, with only packaging demonstrating high recyclability performance expected to meet the Regulation’s long-term sustainability objectives.
Key Compliance Requirements from 12 August 2026
During the first implementation phase, companies should pay particular attention to the following requirements:
Heavy Metal Limits
The combined concentration of lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr(VI)) must not exceed 100 mg/kg (0.01%) in packaging.
PFAS Restrictions
For food contact packaging, the following limits will apply:
- Individual PFAS: ≤25 ppb
- Sum of PFAS: ≤250 ppb
- Total fluorine from polymeric PFAS: ≤50 ppm
- Total fluorine: ≤50 mg/kg
If these limits are exceeded, the source of fluorine must be demonstrated.
Technical Documentation and EU Declaration of Conformity
Companies must complete conformity assessments, prepare technical documentation, and issue an EU Declaration of Conformity (DoC). Technical documentation should include packaging design information, technical drawings, material specifications, and supporting test reports.
Extended Producer Responsibility (EPR)
Non-EU companies placing packaged products on the EU market must register with the relevant Extended Producer Responsibility (EPR) schemes in the countries where their products are marketed and fulfil the applicable reporting and financial obligations.
Preparation for 2030 and Beyond Should Start Today
Although many PPWR requirements will only become applicable in 2028 and 2030, preparations should already be underway. Future obligations include recyclability performance grading, minimum recycled plastic content targets, compostable packaging requirements, digital product information, harmonised labelling, packaging minimisation, and restrictions on certain single-use packaging formats.
Since compliance with these requirements will often require packaging redesign, material substitution, and supply chain adjustments, companies are encouraged to begin their compliance planning well in advance of the applicable deadlines.