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The EU Packaging Regulation PPWR
What companies need to know now about the Packaging and Packaging Waste Regulation
The new EU Packaging Regulation applies from 12 August 2026. By then, the first measures must have been implemented.
Below, we explain what the PPWR is, what objectives it pursues, which obligations must be fulfilled, and what the PPWR means in practice for different economic operators. You will also learn how Interzero can support you in implementing your PPWR obligations.
Note: This post is for general informational purposes only and is not a substitute for legal advice.
What is the PPWR?
The PPWR (Packaging and Packaging Waste Regulation) is the new EU Packaging Regulation. It replaces the European Directive on packaging and packaging waste of 20 December 1994 (Directive 94/62/EC of the European Parliament and of the Council).
The new EU Packaging Regulation formally entered into force on 11 February 2025 and must be applied from 12 August 2026. Certain measures are subject to later deadlines.
The PPWR Regulation applies directly in the EU Member States. This means it is binding without needing to be transposed into national law. Member States must promptly adopt national legislation to implement the regulatory mandates, in Germany, for example, in the form of the Packaging Law Implementation Act.
The legal basis can be found in EUR-Lex (official website of the European Union).
Request the comprehensive white paper with the PPWR summary as a PDF today.
Objectives of the PPWR
The EU Packaging Regulation (PPWR) is a key building block for greater sustainability in Europe and supports the objective of climate neutrality by 2050. It combines climate protection, resource efficiency and waste prevention in a holistic approach. Its objective is to promote a sustainable circular economy and to minimise the negative environmental impacts of packaging by placing greater responsibility on manufacturers and other operators.
The most important objectives include:
- Reduce packaging waste: Reduce packaging waste per capita in the EU Member States and avoid unnecessary and oversized packaging.
- Increase the reuse of packaging through the use of reusable and refill systems.
- Strengthen recycling and the circular economy: All packaging is to be recyclable by 2030. Recyclability should already be taken into account during packaging design (Design for Recycling).
- Increase the use of recyclates: Use more recycled plastics in packaging and thereby reduce the consumption of primary raw materials.
- Improve labelling: Harmonised labels should make it easier for consumers to separate and dispose of packaging correctly.
- Uniform standards in all Member States: The PPWR creates clear, harmonised requirements for companies and is intended to provide greater legal certainty.
The key roles under the PPWR
The first important step for companies under the PPWR is to understand their role and therefore their obligations.
Important: A company may hold several roles at the same time, for example manufacturer and producer.
- The manufacturer produces packaging or packaged products, or has them designed or produced under its own name or trademark. The manufacturer must ensure that the packaging complies with the sustainability and labelling requirements.
- The producer makes packaging or packaged products available for the first time in the EU Member State where the packaging becomes waste. This role may be held by the manufacturer, importer or distributor. The producer is responsible for EPR obligations in the Member States.
- The importer places packaging from a third country (non-EU) on the EU market for the first time. An importer may only place packaging on the market if it is PPWR-compliant.
- The distributor sells packaging or packaged products on but is not a manufacturer or importer. The distributor must check that labelling is present and that the packaging is compliant.
- The supplier supplies packaging or packaging material to a manufacturer and provides important data for PPWR documentation, such as information on material composition, technical data sheets and test reports.
Our white paper gives you a clear overview of the different requirements and roles under the European Packaging Regulation. Request it now free of charge!
The key obligations at a glance and timeline
The PPWR requires companies to invest in environmentally friendly materials, smart designs and seamless compliance processes. Companies that adapt early secure market access, minimise risks and position themselves as sustainable pioneers.
Note: Not all PPWR requirements must be implemented from 12 August 2026. We have compiled the key points.
PPWR documentation (technical documentation, declaration of conformity and conformity assessment)
Deadlines: first obligations from 12 August 2026
Who is affected? Manufacturers; distributors and importers must ensure that documentation is available
Key content:
- All packaging placed on the market in the EU must undergo a conformity assessment procedure.
- Technical documentation and a PPWR declaration of conformity must be prepared for packaging.
- Only PPWR-compliant packaging may be placed on the market.
How can Interzero support you? To simplify the conformity process, Interzero has created the online tool “Check for Recycling”, which allows you to digitally manage and assess your packaging and create declarations of conformity.
Are you missing important information about your packaging, or do you need to optimise it? Our packaging experts will be happy to support you and provide specific recommendations as part of packaging optimisation.
PPWR and EPR (Extended Producer Responsibility)
Deadlines: EPR obligations remain in place and will be more strongly harmonised across the EU through the PPWR; in the future, EPR fees will be eco-modulated more strongly based on the recyclability of packaging
Who is affected? Depending on the constellation, manufacturers, importers or distributors may qualify as the EPR-obligated producer. They must fulfil the applicable national EPR obligations, in particular registration, participation in a system or financing of packaging waste management, and quantity reporting.
Key content:
- EPR obligations generally remain in place; however, the PPWR harmonises them more strongly across the EU and adds further requirements.
- For cross-border distribution, an EPR authorised representative may be required in the respective EU Member State. The specific obligation depends in particular on where the company is established and in which Member States it first makes packaging available.
- EPR fees are to be differentiated more strongly according to the environmental properties of the packaging. In particular, the recyclability performance grade will influence future financial EPR contributions.
- Quantity-based EPR contributions will not generally be abolished; rather, stronger eco-modulation of contributions will be added.
How can Interzero support you?
Interzero organises Europe-wide packaging licensing and advises you on all EPR topics. For small to medium quantities, our digital service Lizenzero is the right solution.
PPWR, chemicals and material compliance
Deadlines: 12 August 2026: new PFAS limits for food-contact packaging; further requirements will follow
Who is affected? Suppliers must provide the basic material data; manufacturers must document compliance with limit values and other requirements in the PPWR documentation and make it available to distributors and importers
Key content:
- General chemicals legislation remains in place.
- Limit values for heavy metals (lead, cadmium, mercury, hexavalent chromium) from Directive 94/62/EC are incorporated into the PPWR.
- New PFAS limits for packaging intended to come into contact with food.
How can Interzero support you? If you need help analysing your packaging materials or have questions about PFAS, REACH and related topics, our internationally accredited competence centre is the right point of contact.
Recyclability and Design for Recycling
Deadlines: from 12 August 2026: principle of minimising the environmental impact of packaging; specific measures must be implemented by 2030
Who is affected? Primary responsibility lies with the manufacturer
Key content:
- From August 2026, the principle will already apply that packaging must be designed in such a way that its impact on the environment and resources is minimised.
- Specific and harmonised Design for Recycling criteria (DfR) and assessment methods are to be defined by the European Commission by January 2028.
- Assessment of recyclability in grades A-C from 2030
- From January 2030, packaging below grade C will no longer be permitted.
- From January 2035, recycled at scale will enter into force, taking the actual recycling infrastructure into account.
- From January 2038, packaging in grade C may no longer be sold.
How can Interzero support you? With its own laboratory expertise, Interzero covers the entire spectrum of packaging optimisation, from packaging analysis and recyclability assessment to packaging development. We also offer training on request. Simply contact us!
PPWR and recyclates
Deadlines: minimum recycled content requirements from 2030
Who is affected? The manufacturer must prove that the required shares are met; material suppliers must provide manufacturers with data on recycled content; packaging manufacturers must process recyclates
Key content:
- Minimum shares of post-consumer recyclate (PCR) for most plastic packaging.
- Quotas apply from 2030 and will be increased further by 2040.
How can Interzero support you? Interzero can supply companies with recyclates from its own plants and provide comprehensive advice on the topic.
The full white paper on the study Circular Packaging 2030 - Strategies Against PCR Scarcity contains detailed market figures and recommendations for action and is available to download free of charge.
PPWR labelling obligations and consumer information
Deadlines:
- 12 August 2026: manufacturer/importer identification
- by August 2026: publication of the harmonised labelling rules by the European Commission, implementation by 2028
Who is affected? in principle, manufacturers; importers must also be clearly identifiable
Key content:
- Important now: By August 2026, manufacturers must ensure that information identifying them and identifying the packaging is provided on the packaging or in an accompanying document.
- Further harmonised labelling rules on material composition, correct separation, reusability and other aspects will follow and must be incorporated into packaging design by 2028.
How can Interzero support you? Our packaging design experts will be happy to support you with the design of your packaging.
PPWR and packaging waste prevention
Deadlines: from 12 August 2026: prevention of oversized packaging without a technical function; specific requirements from 2030
Who is affected? primary responsibility lies with the manufacturer, who must demonstrably reduce material use
Key content: :
- The PPWR prohibits packaging characteristics that merely serve to increase the perceived product volume.
- From 2030, empty space in grouped packaging, transport packaging or e-commerce packaging may not exceed 50%.
- From 2030, certain single-use plastic packaging will be banned in areas where unpackaged alternatives or reuse systems are directly applicable.
- Binding reuse targets for certain types of packaging.
How can Interzero support you? As part of a packaging analysis, our packaging experts can identify weaknesses and work with you to develop legally compliant packaging.
Compostability and bio-based materials
Deadlines: from 12 August 2028: binding requirements for compostable packaging
Who is affected? Primary responsibility lies with the manufacturer
Key content:
- Compostability will be mandatory for certain packaging, for example tea bags, coffee pads and labels on fruit and vegetables. Industrial composting is decisive.
- Compostable packaging must be labelled sufficiently.
- No general advantage for bio-based materials: Packaging should be assessed on the basis of its recyclability and circularity, not its material origin.
PPWR: reusable packaging and reuse systems
Deadlines: binding reuse quotas from 2030
Who is affected? The manufacturer develops and produces packaging; other operators, such as suppliers and operators of reuse systems, must be involved
Key content:
- Reusable packaging should have priority over single-use packaging where this is ecologically and economically appropriate.
- What matters is a functioning return system, not the theoretical possibility of multiple use.
- Specific reuse quotas from 2030.
Packaging affected
In principle, the PPWR Regulation affects all packaging placed on the EU market, regardless of material, sector or whether it is empty or filled. This includes sales packaging, grouped packaging, transport packaging, e-commerce packaging, service packaging and primary production packaging. All materials, such as plastic, paper/cardboard, glass, metal and wood, are affected, although certain PPWR requirements apply only to specific materials.
Particularly affected are:
- Plastic packaging: recycled content, recyclability, PFAS restrictions where applicable
- Transport packaging: reuse quotas, empty-space limits
- E-commerce packaging: limitation of empty space, max. 50% from 2030
- Beverage packaging: recycled-content requirements, deposit systems, separate collection and, in some cases, reuse targets
- Compostable packaging: requirements for industrial compostability and labelling
- Food packaging: partial exemptions or specific requirements, for example for recycled content in food-contact materials and new PFAS limits
Note: Special rules and exemptions from individual obligations, not from the PPWR as a whole, exist only to a very limited extent, for example in the medical sector or for packaging with special hygiene or safety requirements.
Risks of non-compliance
The risks of non-compliance with the PPWR are significant. Because it is an EU regulation, its requirements apply directly in all Member States. However, concrete enforcement, such as fines or sanctions, is carried out by national authorities, which define the relevant provisions and penalty frameworks.
Possible consequences include:
- Market surveillance measures: Authorities may challenge non-compliant packaging, require corrective measures or prohibit placing it on the market.
- Fines and sanctions: Member States must establish effective, proportionate and dissuasive sanctions. The amount and type vary depending on national law.
- Sales and supply stops: Non-compliant packaging may be withdrawn from the market or may no longer be placed on the market. This can lead to production or supply interruptions.
- Civil-law and contractual risks: Breaches may trigger contractual violations, warranty claims or claims for damages, particularly where supply contracts require PPWR compliance.
- Reputational and competitive risks: Recalls, public objections or reports of insufficient sustainability may impair the trust of customers, business partners and investors.
What companies should do now
Regardless of sector or packaging type, companies should act early to:
- understand their role within the PPWR framework,
- clearly define responsibilities for the PPWR,
- fully record their packaging portfolio digitally,
- build the required technical documentation and compliance processes,
- systematically assess packaging in terms of packaging minimisation, recyclability, use of recyclates and reuse potential,
- involve suppliers in data collection and evidence management,
- continuously monitor future developments under the PPWR, such as delegated and implementing acts, and implement measures accordingly.
Contact us - we will be happy to advise you!
PPWR consulting from Interzero
Do you need support implementing your legal obligations and are you looking for practical solutions? Interzero has been your experienced partner for sustainability and the circular economy for more than 35 years and operates internationally. Benefit from our comprehensive expertise and extensive network, and rely on a strong partner for all PPWR-related questions.
Do you have questions about the new EU PPWR?
Elena Ehmann
Consulting Expert
PPWR FAQ
- Why is a Europe-wide packaging regulation necessary?
- High levels of packaging waste: According to European Commission data, around 180 kg of packaging waste is generated per person each year on average, and packaging consists largely of virgin materials. Around 40% of plastics and 50% of paper in the EU are used for packaging, and an increase of 19% by 2030 is expected if no corresponding countermeasures are taken. The PPWR aims to reduce consumption and promote the circular economy.
- Inconsistent laws and approaches: Across the EU, there are currently very different approaches and rules at national level for the collection, reduction and recycling of packaging. Some countries are frontrunners, while others are lagging behind, particularly with regard to recycling rates. Internationally active manufacturers and retailers repeatedly face the challenge of knowing and complying with the rules in each individual country. This also applies to online retailers shipping abroad. Article 1 of the Regulation defines the objective of raising and harmonising the legal framework in the individual countries. Ask us for advice if you export products to other European countries and have questions about the EU Packaging Regulation.
- Who is affected by the PPWR?
The Regulation affects almost all companies that manufacture, import, fill, distribute or place packaging on the EU market for the first time. This includes producers, retailers, importers, e-commerce companies and brand owners.
- When does the PPWR enter into force?
The PPWR entered into force in early 2025. Most rules apply from 12 August 2026. For individual requirements, for example on recyclability, recycled content or reuse quotas, staggered transition periods apply until 2030 and beyond.
- Who does the EU Packaging Regulation apply to?
The EU Packaging Regulation PPWR is binding for packaging placed on the market in the EU. This applies to packaging manufactured in the EU as well as packaging imported into the EU from third countries.
- Do existing packaging formats need to be adapted?
In many cases, yes. Companies should check whether their packaging meets the future requirements for recyclability, material use, labelling and documentation. Early analysis helps avoid later adjustment costs.
- What does "Design for Recycling" mean?
In the future, packaging must be designed so that it can be efficiently collected, sorted and recycled. Material combinations that make recycling more difficult should be reduced. Companies should therefore review the recyclability of their packaging at an early stage.
- What are the benefits of preparing early?
Companies can reduce legal risks, make packaging fit for the future and plan necessary changes in product development and procurement in good time. Costs caused by later adjustments can also often be avoided.
