PPWR Regulation 2026: Deadlines, Obligations and Factsheet for Download
Laws & Regulations
The PPWR (Regulation (EU) 2025/40) is the new EU packaging regulation. It entered into force on 11 February 2025, and most obligations apply from 12 August 2026. It affects every company placing packaging on the EU market. This article explains the deadlines, obligations per role, and how to prepare. A free factsheet at the end sums up the key points.
What is the PPWR?
The PPWR (Packaging and Packaging Waste Regulation) is an EU regulation and therefore applies directly in all 27 member states, without first being transposed into national law. That is the fundamental difference from the previous Packaging Directive 94/62/EC, which each member state could interpret and turn into its own legislation. From the date of application on 12 August 2026, the same requirements apply simultaneously in Germany, France, Poland and every other EU market. Companies can no longer point to a missing national implementing law: authorities and courts apply the regulation directly. The full text of the regulation is available on EUR-Lex.
PPWR, the Packaging Directive and the German VerpackG: how do they connect?
The old Directive 94/62/EC was implemented in Germany through the Packaging Act (VerpackG). The PPWR replaces that mechanism. In Germany, the new Packaging Law Implementation Act (VerpackDG) takes its place, but it now only provides the enforcement framework, meaning responsibilities, penalties and the link to existing national structures. The legislative process is complete: the Bundestag passed the VerpackDG on 11 June 2026, the Bundesrat approved it on 10 July 2026, and it was promulgated in the Federal Law Gazette on 17 July 2026. It enters into force alongside the PPWR on 12 August 2026. Much of what companies know stays in place: the LUCID packaging register and registration with the Central Agency Packaging Register (ZSVR) continue to apply. The German Federal Environment Ministry summarises the national framework.
What are the goals of the PPWR?
The PPWR aims to reduce packaging waste, improve recyclability and strengthen the circular economy in Europe. Specifically, it requires member states to cut per-capita packaging waste against the 2018 reference year, by at least 5 percent by 2030, 10 percent by 2035 and 15 percent by 2040. The regulation is part of the European Green Deal and the EU Circular Economy Action Plan. The European Commission provides an overview of the objectives and legal framework. It sets a framework that looks at packaging across the entire lifecycle, from design and material choice through to disposal.
Who does the PPWR apply to?
The obligations under the PPWR do not depend on company size in a blanket way, but on the role in the supply chain for each specific product. There is no general exemption for small and medium-sized enterprises and no de minimis threshold. Anyone who places packaging or packaged products on the EU market falls under the regulation. The key provision is Article 3, which defines the economic operators and assigns specific obligations to each.
Role | Who this is | Core obligations |
|---|---|---|
Producer | Manufactures packaging or packaged products, or has them made, and places them on the market first under its own name | Ensure conformity, issue a declaration of conformity, keep technical documentation |
Producer (in the sense of extended producer responsibility) | Economic operator that first makes packaging available in a member state | Registration, coverage of EPR costs for collection and recycling |
Importer | Brings packaging or packaged products into the EU from a third country | Check conformity and labelling, obtain supplier documentation |
Distributor | Makes packaging available on the market without being producer or importer | Verify that labelling and conformity documents are in place |
Fulfilment service provider | Handles storage, packing or shipping for third parties | Due diligence regarding the packaging it handles |
Does the PPWR also apply to small companies and online retailers?
Yes. Online retailers place shipping packaging on the market and therefore fall under the regulation. The PPWR also brings online platforms into scope: from the date of application, they must verify the registration and EPR details of the retailers active on them (Article 45). For cross-border direct sales to end users in another member state, an authorised representative must be appointed for each country of sale from 12 August 2026. A point often overlooked in practice: a company can hold several roles at once for a given package, for example producer for its own product packaging and importer for bought-in goods. Incorrect classification is one of the central compliance risks, because the specific obligations depend on it.
When does the PPWR apply? All deadlines at a glance
Two dates need to be distinguished. Entry into force on 11 February 2025 marks the legal starting point of the regulation. The date of application on 12 August 2026 is the point from which most obligations actually have to be applied. Many detailed requirements take effect later and are tied to delegated and implementing acts that the European Commission issues step by step. If such an act is delayed, the associated deadline shifts accordingly.
Date | What applies |
|---|---|
11 February 2025 | Entry into force of the regulation |
12 August 2026 | Date of application: packaging minimisation, substance restrictions, PFAS limits for food contact, first reuse obligations, EPR and registration duties |
12 August 2028 | Earliest start of harmonised labelling (depending on the related implementing act) |
1 January 2030 | Recyclability (at least Grade C), minimum recycled content, empty space limit, binding reuse targets |
1 January 2035 | Recyclability "at scale" to be demonstrated |
1 January 2038 | Only packaging from Grade B upwards permitted; Grade C is phased out |
2040 | Tightened recycled-content rates and a 15 percent waste reduction target |
Whether the date of application will still be postponed is a common question. Several industry associations had called for a delay to January 2027. The European Commission, however, has explicitly ruled out a formal postponement and has only signalled pragmatic transitional solutions within the existing legal framework. The 12 August 2026 deadline stands. Anyone waiting for a delay risks being left without a valid declaration of conformity and losing market access.
What obligations and requirements does the PPWR introduce?
The substantive requirements of the PPWR are spread across several articles and take effect in stages. The following sections summarise the requirements most relevant to companies.
Substance requirements (Article 5)
For substances of concern, a combined limit of 100 mg/kg applies to lead, cadmium, mercury and hexavalent chromium. For food-contact packaging, PFAS limits apply from 12 August 2026: no more than 25 ppb per individual substance and 250 ppb in total, plus a threshold of 50 ppm for PFAS including polymeric PFAS. If the total fluorine content exceeds 50 mg/kg, evidence of the origin of the fluorine is required. The DIHK factsheet on the PPWR summarises the details.
Recyclability (Article 6)
From 1 January 2030, every package must be recyclable and meet at least the requirements of Grade C. The regulation assesses recyclability through performance grades that reflect the share of a packaging unit that is recyclable by weight. Grade A stands for at least 95 percent, Grade B for at least 80 percent, Grade C for at least 70 percent. Packaging that falls below the Grade C value counts as non-recyclable and may no longer be placed on the market from 2030.
Performance grade | Recyclable share (by weight) | Market access |
|---|---|---|
Grade A | ≥ 95 percent | permanently permitted |
Grade B | ≥ 80 percent | permanently permitted |
Grade C | ≥ 70 percent | permitted until end of 2037, then phased out |
below Grade C | < 70 percent | no longer permitted from 2030 |
From 1 January 2035, a second stage is added: packaging must then not only be recyclable by design, but demonstrably recycled "at scale", meaning through established collection and sorting infrastructure. From 1 January 2038, the threshold rises again, and only packaging from Grade B upwards is permitted. Note that the precise assessment methodology and the design-for-recycling criteria will only be set out in a delegated act that the Commission must present by 1 January 2028. For the interpretation of individual provisions, the Commission published a guidance document on the PPWR in March 2026. The specific classification of individual packaging should therefore be checked against the final act.
Minimum recycled content (Article 7)
From 2030, binding minimum shares of post-consumer recycled content (PCR) apply to plastic packaging. Only recyclate from household or commercial waste after use counts; production waste is not credited. The shares vary by category: 30 percent for contact-sensitive packaging with PET as the main component, 10 percent for contact-sensitive packaging made of other plastics, 30 percent for single-use plastic beverage bottles and 35 percent for other plastic packaging. By 2040, these values rise to 50, 25, 65 and 65 percent. Plastic parts that make up less than 5 percent of the packaging weight are exempt. A separate act specifies the exact calculation and verification methodology.
Packaging minimisation (Articles 10, 24 and 25)
Packaging must be reduced to the functional minimum in weight, volume and empty space. Oversized packaging with double walls, false bottoms or unnecessary layers that suggest a larger product volume is not permitted. For grouped, transport and e-commerce packaging, an empty space limit applies from 2030: the empty space share may not exceed 50 percent. Filling material such as air cushions, paper shreds or foam counts as empty space here. The minimisation duty itself already applies from 12 August 2026, even though the exact method for calculating the empty space share will only be set out in an implementing act.
Reuse and refill (Articles 11 and 29)
From 12 August 2026, companies must provide a reuse system for certain packaging formats that offers incentives for return and meets the requirements of Annex VI. From 2030, binding reuse targets are added, such as 40 percent for transport packaging within the EU. Article 11 defines when packaging counts as reusable: it must be able to go through several use cycles, be embedded in a return system and be traceable. These requirements sit alongside the Single-Use Plastics Directive (SUPD) and the national reusable-option obligation, but do not replace them.
Labelling and QR code (Articles 12 and 13)
The PPWR introduces harmonised labelling of material composition, which becomes mandatory at the earliest from 12 August 2028. The exact start depends on the related implementing act and falls 24 months after it enters into force. For certain information, such as on reuse, digital information via QR code or another open data carrier is required. This labelling creates the link to the digital product passport, through which packaging information is to become machine-readable in future.
Extended producer responsibility (EPR) and declaration of conformity
Producers bear the full cost of collecting, sorting and recycling their packaging and must register. For each packaging type, an EU declaration of conformity (DoC) must also be issued, based on a conformity assessment. The associated technical documentation must be kept for five years, and for ten years in the case of reusable packaging. In practice, the DoC is a frequently underestimated driver of effort, because it has to be produced per packaging type and backed with reliable data from the supply chain. Importers who do not receive a compliant DoC from their suppliers must either switch suppliers or take on the producer role themselves and issue the DoC.
What should companies do now? Implementation in five steps
The biggest effort under the PPWR rarely lies in a single detailed requirement, but in building structured, audit-proof packaging data. Companies that fail to create a reliable data basis in 2026 will run into short-notice ad-hoc projects under time pressure in 2029 and 2030. The following five steps form a workable sequence.
First, clarify your own role for each package, meaning whether the company is producer, EPR producer, importer or distributor. The specific obligations follow from that. The second step is to inventory the packaging portfolio: formats, volumes, materials and weights per component are recorded in full. Third, supplier data must be obtained so that recycled content and recyclability can be demonstrated, which depends on reliable communication along the supply chain. Fourth, the EPR and registration obligations must be clarified for each EU market, in Germany through LUCID and the ZSVR. And fifth, declarations of conformity and technical documentation are prepared, ideally coordinated early with suppliers, because that is where the required data originates.
What penalties apply?
The PPWR provides for corporate fines in the event of breaches. Member states could set further penalties by February 2027, such as product recalls, distribution bans or public announcements. In practice, the heaviest consequence is that non-compliant packaging may no longer be placed on the market from the date of application. This amounts to an effective market ban and affects not only the packaging itself, but also the product packaged in it. On top of this comes the reputational risk with trading partners, who increasingly demand compliant packaging.
All deadlines and obligations at a glance: the PPWR factsheet
Anyone implementing the PPWR in day-to-day work needs the key data quickly to hand, without going through the full text of the regulation or this article every time. That is exactly why we have condensed the most important content into a compact factsheet: the two key dates, the obligations for each role, the required documentation, the deadlines from 2026 to 2040, and the five preparation steps, each on an overview page.
The factsheet contains no additional information beyond this article. It bundles the content so that you can use it as an overview at your desk, share it within your team or draw on it for internal coordination. You can download it free of charge via the form at the end of this page.
Frequently asked questions about the PPWR
What is the PPWR in simple terms?
The PPWR is the EU Packaging and Packaging Waste Regulation (EU) 2025/40. It sets EU-wide, uniform rules for how packaging must be designed, labelled and disposed of. The goals are less waste, more recyclable packaging and a stronger circular economy. Because it is a regulation that applies directly, it does not first need to be translated into national law and binds companies in every member state.
When does the PPWR apply?
The PPWR entered into force on 11 February 2025, and most obligations apply from 12 August 2026. Many detailed requirements take effect later and are tied to delegated acts, such as recyclability and minimum recycled content from 2030. A postponement to 2027 called for by industry associations has been rejected by the European Commission. The 12 August 2026 deadline is therefore fixed.
Will the PPWR date of application still be postponed?
No. Several industry associations had called for a delay to January 2027, but the European Commission has explicitly ruled out a formal postponement. Only pragmatic transitional solutions within the existing legal framework are on the table. Companies should plan for 12 August 2026 as a binding date and not count on an extension, otherwise market access is at risk.
Who does the PPWR apply to?
The PPWR applies to every company that places packaging or packaged products on the EU market. The obligations depend on the role in the supply chain, meaning whether a company is producer, EPR producer, importer or distributor, not on size. There is no general exemption for small and medium-sized enterprises. A company can also hold several roles for a given package.
What is the difference between the PPWR and the German VerpackG?
The German Packaging Act (VerpackG) implemented the old EU Directive 94/62/EC. As a regulation, the PPWR applies directly and replaces that implementation mechanism. In Germany, the new Packaging Law Implementation Act (VerpackDG) now only governs enforcement, meaning responsibilities and penalties. The LUCID register and registration with the Central Agency Packaging Register remain in place.
Which packaging must be recyclable from 2030?
From 1 January 2030, every package must be recyclable and reach at least Grade C, meaning at least 70 percent recyclable by weight. Packaging below that may no longer be placed on the market. From 2035, recyclability must be demonstrated at scale, and from 2038 only packaging from Grade B upwards is permitted. A delegated act sets out the exact methodology.
What penalties apply for breaching the PPWR?
The PPWR provides for corporate fines, the level of which member states set nationally. Possible product recalls, distribution bans and public announcements are added to this. In practice, the heaviest consequence is that non-compliant packaging may no longer be placed on the market from the date of application. This also affects the product packaged in it and can block market access entirely.
