PPWR Regulation 2026: Deadlines, Obligations and Factsheet for Download
Laws & Regulations
The PPWR (Regulation (EU) 2025/40) is the new EU Packaging and Packaging Waste Regulation. It has been in force since 11 February 2025, and most obligations apply from 12 August 2026. Every company that places packaging on the EU market is affected. This article explains the deadlines, the obligations by role and the steps to prepare. A free factsheet at the end of the page summarises all 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 needing to be transposed into national law first. This sets it apart from the previous Packaging Directive 94/62/EC, which each member state could interpret and cast into its own laws. From the application date of 12 August 2026, the same requirements apply simultaneously in Germany, France, Poland and every other EU market. Companies can no longer argue that a national implementing act is still missing: authorities and courts apply the regulation directly. The full text of the regulation is available from the EU 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 this mechanism. In Germany, the new Packaging Law Implementation Act (VerpackDG) takes the place of the VerpackG, but only provides the enforcement framework, meaning responsibilities, penalties and the link to existing national structures. The legislative process is complete: the Bundestag adopted 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 at the same time as the PPWR on 12 August 2026. Much that is familiar remains in place for companies: the LUCID packaging register and registration with the Central Agency Packaging Register (ZSVR) continue to apply. Details on the national framework are summarised by the German Federal Environment Ministry.
What are the objectives 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 baseline, namely 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. An overview of the objectives and legal framework is provided by the European Commission. It thereby sets a framework that considers packaging across its entire life cycle, from design and material choice to disposal.
Who does the PPWR apply to?
The obligations of the PPWR do not follow company size in a blanket manner, but apply product by product according to the role in the supply chain. 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 decisive provision is Article 3, which defines the economic operators and assigns specific obligations to each.
Role | Who this is | Core obligations |
|---|---|---|
Producer (manufacturer of packaging) | Manufactures packaging or packaged products, or has them manufactured, and places them on the market for the first time under its own name | Ensure conformity, issue the declaration of conformity, keep technical documentation |
Producer (in the sense of extended producer responsibility) | Economic operator that makes packaging available in a member state for the first time | Registration, assuming the EPR costs for collection and recycling |
Importer | Brings packaging or packaged products into the EU from a third country | Check conformity and labelling, obtain documentation from suppliers |
Distributor | Makes packaging available on the market without being producer or importer | Check whether labelling and conformity documents are in place |
Fulfilment service provider | Handles storage, packaging or shipping for third parties | Due-diligence obligations regarding the packaging handled |
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. In addition, the PPWR places obligations on online platforms: from the application date 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 packaging, for example producer for its own product packaging and importer for purchased 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 application date of 12 August 2026 is the point from which most obligations actually have to be applied. Many detailed requirements, however, take effect later and are tied to delegated and implementing acts that the EU Commission provides 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 | Application date: substance restrictions, PFAS limits for food contact, first reuse obligations, EPR and registration obligations |
12 August 2028 | Earliest start of harmonised labelling (depending on the associated implementing act) |
1 January 2030 | Packaging minimisation (Article 10), recyclability (min. Grade C), minimum recycled content, empty-space limit, binding reuse targets |
1 January 2035 | Recyclability "at scale" must be demonstrated |
1 January 2038 | Only packaging of Grade B or higher permitted; Grade C is phased out |
2040 | Tightened recycled-content targets and 15 percent waste reduction target |
Whether the application date will still be postponed is a frequent question. Several industry associations had called for a postponement to January 2027. The EU Commission, however, expressly rejected a formal delay and only held out the prospect of pragmatic transitional solutions within the existing legal framework. The deadline of 12 August 2026 stands. Anyone waiting for a postponement risks being left without a valid declaration of conformity and thereby losing market access.
What obligations and requirements does the PPWR bring?
The material requirements of the PPWR are spread across several articles and take effect in a staggered manner. The following sections summarise the most important requirements for companies.
Substance requirements (Article 5)
For substances of concern, a combined limit of 100 mg/kg applies for lead, cadmium, mercury and hexavalent chromium. For packaging in contact with food, 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 total fluorine exceeds 50 mg/kg, evidence of the origin of the fluorine is required. The details are summarised in the DIHK information sheet on the PPWR.
Recyclability (Article 6)
From 1 January 2030, every packaging 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 is considered 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 the 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 of Grade B or higher is permitted. Note that the exact assessment methodology and the design-for-recycling criteria will only be set by a delegated act, which the Commission must present by 1 January 2028. To interpret 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 recyclate (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 account for less than 5 percent of the packaging weight are exempt. The exact calculation and verification methodology is specified in a separate act.
Packaging minimisation (Articles 10, 24 and 25)
Packaging is to be reduced to the functionally necessary minimum of weight, volume and empty space. Deceptive packaging with double walls, false bottoms or unnecessary layers that feign a larger product volume is not permitted. For grouped, transport and e-commerce packaging, an empty-space limit applies from 1 January 2030: the empty-space ratio may not exceed 50 percent. Filling material such as air cushions, paper cuttings or foam counts as empty space here. The minimisation obligation under Article 10 likewise applies from 1 January 2030; until then, the previous essential requirements of the Packaging Directive continue to apply. In addition, the Commission will only set the exact method for calculating the empty-space ratio by way of an implementing act.
Reuse and refill (Articles 11 and 29)
From 12 August 2026, companies must maintain 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, for example 40 percent for transport packaging within the EU. Article 11 sets out when packaging counts as reusable: it must be able to go through several cycles of use, be integrated into a return system and be traceable. These requirements sit alongside the Single-Use Plastics Directive (SUPD) and the national reuse-offer 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 associated implementing act and falls 24 months after its entry into force. For certain information, such as reusability, digital information via QR code or another open data carrier is required. This labelling establishes 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 costs of collection, sorting and recycling of their packaging and must register. In addition, an EU declaration of conformity (DoC) must be issued for each packaging type, based on a conformity assessment. The associated technical documentation must be kept for five years, and for reusable packaging ten years. In practice, the DoC is a frequently underestimated cost driver, because it has to be drawn up per packaging type and backed by reliable data from the supply chain. Importers who do not receive a compliant DoC from their suppliers must either change suppliers or take on the producer role themselves and issue the DoC.
What should companies do now? Implementation in five steps
The greatest effort under the PPWR rarely lies in a single detailed requirement, but in building structured, audit-proof packaging data. Those who 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 practical sequence.
First, clarify your own role for each packaging, that is, check whether the company is a producer, manufacturer, importer or distributor. The specific obligations follow from this. The second step is to take stock of the packaging portfolio: formats, quantities, materials and weights per component are recorded in full. Third, obtain supplier data so that recycled-content levels and recyclability can be demonstrated. This requires reliable communication along the supply chain. Fourth, clarify the EPR and registration obligations for each EU market, in Germany via LUCID and the ZSVR. And fifth, prepare declarations of conformity and technical documentation, ideally coordinated early with suppliers, because the required data originates there.
What penalties apply?
The PPWR provides for corporate fines in the event of breaches. Member states were able to lay down further penalties by February 2027, such as product recalls, sales bans or public notices. In practice, the most serious consequence is that non-compliant packaging may no longer be placed on the market from the application date. This amounts to a de facto market ban and affects not only the packaging itself but also the product it contains. According to the Commission's enforcement guidance in the PPWR FAQ (2nd edition, August 2026), however, enforcement immediately after the application date is not meant to disrupt trade abruptly: where non-compliance is identified, authorities first request corrective action within a reasonable timeframe before resorting to sales bans or market withdrawals. On top of this comes the reputational risk towards 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 figures quickly at hand, without going through the full text of the regulation or this article every time. That is exactly why we have summarised the most important content in a compact factsheet: the two key dates, the obligations by role, the required evidence, the deadlines from 2026 to 2040 and the five preparation steps, each on one 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 workplace, share it within the 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, better recyclable packaging and a strengthened circular economy. Because it applies directly as a regulation, it does not first have to be translated into national law and binds companies in all member states directly.
When does the PPWR apply?
The PPWR has been in force since 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. The EU Commission rejected a postponement to 2027 that had been called for by industry associations. The deadline of 12 August 2026 is therefore fixed.
Will the PPWR application date still be postponed?
No. Several industry associations had called for a deferral to January 2027, but the EU Commission expressly rejected a formal postponement. Only pragmatic transitional solutions within the existing legal framework are in prospect. Companies should plan for 12 August 2026 as a binding date and not count on an extension, because 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 follow the role in the supply chain, that is, whether a company is a producer, manufacturer, importer or distributor, not the size. There is no general exemption for small and medium-sized enterprises. A company can also hold several roles for a given packaging.
What is the difference between the PPWR and the German VerpackG?
The German Packaging Act (VerpackG) implemented the old EU Directive 94/62/EC. The PPWR, as a regulation, applies directly and replaces this implementation mechanism. In Germany, the new Packaging Law Implementation Act (VerpackDG) only governs enforcement, that is, 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 packaging 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 of Grade B or higher is permitted. The exact methodology is set by a delegated act.
What penalties apply for breaches of the PPWR?
The PPWR provides for corporate fines, the level of which member states set nationally. Added to this are possible product recalls, sales bans and public notices. In practice, the most serious consequence is that non-compliant packaging may no longer be placed on the market from the application date. This also affects the product it contains and can block market access entirely.
