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The EU Packaging and Packaging Waste Regulation (PPWR)
What companies now need to know about the Packaging and Packaging Waste Regulation
The new EU Packaging and Packaging Waste Regulation has applied since 12 August 2026. Initial compliance measures had to be implemented by this date.
In this article, we explain what the PPWR is, covering its objectives, the duties it involves and its specific requirements for a variety of economic operators.
We also outline the ways in which Interzero can help you to fulfil 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 EU’s new packaging legislation. This Regulation replaces and repeals the EU Packaging and Packaging Waste Directive (European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste).
The new EU PPWR entered into force on 11 February 2025 and has been generally applicable since 12 August 2026. Some requirements have later dates for their application.
The PPWR is directly applicable in EU member states, which means that its provisions are immediately binding and do not require transposition into national law. Member states must promptly adopt measures for their national implementation responsibilities (in Germany, this takes the form of the Packaging Law Implementation Act, VerpackDG).
The text of the Regulation can be found on EUR-Lex (official website of the European Union).
Request your copy of our comprehensive whitepaper that summarises the PPWR for you (PDF).
Objectives of the PPWR
The PPWR forms a core part of Europe’s strategy for achieving greater sustainability and supports the goal of becoming climate neutral by 2050. The Regulation represents a unified approach to climate change mitigation, resource efficiency and waste prevention. Overall, it aims to promote the sustainable circular economy and to minimise the negative environmental impacts of packaging by including provisions that require manufacturers and other actors to take greater responsibility.
Key objectives of the PPWR include:
- Reducing packaging waste: Reducing per-capita packaging waste in EU member states, and avoiding unnecessary and oversized packaging.
- Increasing the reuse of packaging by deploying multi-use and refill systems.
- Strengthening recycling and the circular economy: All packaging should be recyclable by 2030. This recyclability should already be accounted for at the packaging design stage (‘Design for Recycling’).
- Boost the use of recycled content: Increased use of recycled plastics in packaging, thereby reducing the consumption of primary raw materials.
- Improved labelling: Standardised labelling intends to make it easier for consumers to separate and dispose of packaging properly.
- Uniform standards in all member states: The PPWR has created clear, harmonised rules for economic operators that are designed to ensure legal compliance.
Key roles as defined by the PPWR
For economic operators, the first and most important step is to identify their role and therefore their duties.
Please note: An economic operator can hold multiple roles simultaneously, e.g. manufacturer and producer.
- The manufacturer makes packaging or packaged products, or commissions a third party to design or manufacture these under the manufacturer’s own name or trademark. The manufacturer must ensure that the packaging conforms to sustainability and labelling requirements.
- The producer is the first party to place packaging or packaged products on the market in the EU member state in which the packaging becomes waste. This role is played by the manufacturer, importer or distributor. The producer is responsible for compliance with EPR duties in the member states.
- The importer is the first operator who places packaging from a third country (non-EU) on the EU market. This operator may only place packaging on the market that is PPWR-compliant.
- The distributor makes packaging or packaged products available on the market but is not a manufacturer or an importer. This operator must verify that labelling is present and that packaging is compliant.
- The supplier supplies packaging or packaging material to a manufacturer and makes important data for PPWR documentation available (e.g. information about material composition, technical data sheets, test reports).
Our white paper gives you a clear overview of the various requirements and roles defined by the EU Packaging and Packaging Waste Regulation. Request your free copy today!
Overview of key duties and phased application timetable
The PPWR requires companies to invest in environmentally friendly materials, smart designs and the establishment of end-to-end compliance processes. Early movers stand to secure market access, minimise risks and position themselves as sustainability champions.
Please note: Only some of the PPWR requirements must be met by 12 August 2026. We have summarised the most important points here.
PPWR documentation (technical documentation, declaration of conformity and conformity assessment)
Deadline: First duties to be fulfilled by 12 August 2026
Who is affected? Manufacturers; distributors and importers must ensure required documentation is in place
Key points:
- All packaging placed on the market in the EU must have completed a conformity assessment procedure.
- Technical documentation together with a PPWR declaration of conformity must be prepared for packaging.
- All packaging placed on the market must be PPWR-compliant.
For further details, see: PPWR documentation
How can Interzero help out? To simplify the conformity process, Interzero has created its Check for Recycling tool. You can use this online service to manage your packaging, have your packaging assessed and create declarations of conformity.
Is important information for your packaging missing? Do you need to optimise your packaging? Our packaging experts will be happy to help and provide you with targeted recommendations for action as part of a packaging optimisation service.
PPWR and extended producer responsibility (EPR)
Deadline: The PPWR keeps EPR duties in place and has improved their harmonisation within the EU. In the future, fees paid under EPR will increasingly be eco-modulated to reflect packaging recyclability.
Who is affected? The ‘producer’ referred to by EPR can potentially be the manufacturer, importer or distributor. These operators must fulfil their applicable national EPR duties, which include registration, system participation (or financing of packaging disposal) and quantity declarations.
Key points:
- While EPR duties are carried over unchanged from earlier legislation, the PPWR strengthens their EU-wide harmonisation and includes additional provisions.
- For cross-border distribution, an authorised EPR representative may be required in the respective EU member state. In particular, the specific duty will depend on where the company is domiciled and the member states in which it is first placing packaging on the market.
- EPR fees will also more strongly reflect a packaging’s environmental properties. The recyclability performance grade, in particular, will influence producers’ financial contributions under EPR.
- Quantity-based EPR contributions will not be abolished as such, but stronger eco-modulation will be applied to these contributions.
How can Interzero help out?
Interzero organises packaging licensing across Europe and can advise you on all EPR topics. Our digital Lizenzero service is the ideal solution for small- to medium-sized volumes.
PPWR, chemicals and material conformity
Deadline: New limits on PFAS in food contact packaging apply from 12 August 2026; further requirements to follow
Who is affected? Suppliers must provide the basic material data. Manufacturers must specify compliance with limits, etc. in PPWR documentation and make this documentation available to distributors and importers
Key points:
- No major changes to previous chemicals legislation.
- Limits for heavy metals (lead, cadmium, mercury, hexavalent chromium) are retained and applied from Directive 94/62/EC by the PPWR.
- New limits on PFAS in packaging with food contact.
For further details, see: PPWR and chemicals
How can Interzero help out? If you need help with the analysis of your packaging materials or have questions on PFAS, REACH, etc., our internationally accredited Centre of Competence is the right point of contact.
Recyclability and Design for Recycling
Deadline: from 12 August 2026: Basic principle of minimising environmental impacts from packaging; specific measures must be implemented by 2030
Who is affected? Manufacturer bears primary responsibility
Key points:
- The basic principle that packaging must be designed to minimise its impact on the environment and natural resources already applies from August 2026.
- Specific and harmonised Design for Recycling (DfR) criteria and assessment methods are to be defined by the EU Commission by January 2028.
- Recyclability performance grades (A–C) by 2030
- From January 2030, packaging with a grade lower than C cannot be placed on the market.
- From January 2035, ‘Recycled at Scale’ then applies (which takes actual recycling infrastructure into account).
- From January 2038, packaging with a grade of C or less can no longer be sold.
How can Interzero help out? Interzero maintains an in-house laboratory that covers the entire spectrum of packaging optimisation processes – from packaging analysis and the assessment of recyclability to packaging development services. Training is also available on request. Please get in touch!
PPWR and recyclates
Deadline: Minimum recycled-content requirements from 2030
Who is affected? Manufacturers must demonstrate compliance with percentages; material suppliers must provide manufacturers with data about recycled-content percentages; producers must process recycled content.
Key points:
- Minimum percentages for post-consumer recycled (PCR) content for most plastic packaging.
- Targets apply from 2030 and will increase from 2040.
How can Interzero help out? Interzero can provide companies with recyclates from its own facilities and offers comprehensive advice on the topic.
Our full-length white paper on the study ‘Circular Packaging 2030 – Strategies addressing PCR scarcity’ includes detailed market figures and recommendations for action, and is available as a free download.
PPWR labelling requirements and consumer information
Deadline:
- Manufacturer/importer labelling by August 12 2026
- Application of the harmonised labelling rules from the EU Commission by August 2026, implementation by 2028
Who is affected? Both manufacturers and importers must be unambiguously identifiable
Key points:
- Prompt action needed: By August 2026, manufacturers must ensure that information identifying their business and the packaging is available either on the packaging or an accompanying document.
- Additional harmonised labelling rules addressing material composition, correct separation, reusability, etc. will follow and must be accounted for by the packaging design (2028).
How can Interzero support you? Our packaging experts will be happy to offer their support for the the design of your packaging.
PPWR and packaging waste prevention
Deadline: from 12 August 2026: Avoidance of outsized packaging without a technical function; specific requirements from 2030
Who is affected? Primary responsibility is borne by the manufacturer, who must demonstrably reduce the use of material.
Key points:
- PPWR prohibits packaging features that only serve to increase the apparent product volume.
- From 2030, the empty space within secondary packaging, transport packaging or packaging for electronic retail goods must not exceed 50%.
- From 2030, the PPWR prohibits certain single-use plastic packaging in areas where unpackaged alternatives or multi-use systems are directly applicable.
- Binding multi-use targets for certain types of packaging.
How can Interzero help out? Our packaging experts can use a packaging analysis to discover weaknesses and then work with your team to develop legally compliant packaging.
Compostability and bio-based materials
Deadline: Binding requirements for compostable packaging from 12 August 2028
Who is affected? Manufacturer bears primary responsibility
Key points:
- Compostability is mandatory for certain kinds of packaging (e.g. tea bags, coffee pads, labels on fruit/vegetables). Suitability for industrial composting is required.
- Compostable packaging must be appropriately labelled.
- Bio-based materials are not automatically ‘better’: Packaging is to be assessed in terms of recyclability and circularity rather than the origin of constituent materials.
PPWR: Multi-use packaging and re-use systems
Deadline: Binding re-use targets from 2030 onwards
Who is affected? Manufacturers who design and produce packaging; other parties such as suppliers and operators of re-use systems must also be involved.
Key content:
- Reusable packaging should be preferred to single-use packaging where this is ecologically and economically justifiable.
- What matters is a functional take-back system and not the theoretical possibility of reusability.
- Specific reusability targets from 2030.
Affected packaging
The PPWR is generally applicable to all packaging that is placed on the EU market – regardless of its materials, the individual industry, or whether the packaging is empty or filled. This includes sales packaging, secondary and transport packaging, e-commerce and service packaging, and primary production packaging. All materials are affected (plastics, paper/cardboard, glass, metal, wood, etc.), although individual PPWR requirements only apply to certain materials.
Key packaging types affected are:
- Plastic packaging: Recycled-content percentage, recyclability, PFAS limits (if relevant)
- Transport packaging: Reusability targets, empty-space targets
- E-commerce packaging: Limits on empty space (max 50% from 2030)
- Beverage packaging: Recycled-content targets, deposit systems, separate collection, (partial) multi-use targets
- Compostable packaging: Requirements for industrial-scale compostability and labelling
- Food packaging: Some exceptions as well as special requirements, e.g. in the case of recycled-content percentages for food contact materials, new PFAS limits.
Please note: There are very few exceptions or exemptions from individual duties (and never the PPWR as a whole). Some examples include the healthcare sector, or packaging with special hygiene or safety requirements.
Risks of non-compliance
Failing to implement PPWR requirements entails significant risks. The PPWR is an EU Regulation and its provisions therefore apply directly to operators in all member states. Enforcement of the Regulation (fines, penalties, etc.) is carried out by the national authorities, who define the corresponding rules and penalty schemes.
Possible actions:
- Market surveillance measures: Authorities can challenge non-compliant packaging, demand corrective action be taken or prohibit its placement on the market.
- Fines and penalties: Member states must set out penalties that are effective, proportionate and dissuasive. The level and type will depend on the respective national law.
- Prohibitions of sale or delivery: Non-compliant packaging may be withdrawn from the market or prohibited from being placed on the market. This can lead to interruptions in production or supply.
- Risks under civil and contract law: Infringements can trigger breaches of contract, claims under warranty or claims for compensation – especially if delivery agreements are predicated on PPWR compliance.
- Reputational and competition risks: Recalls, public complaints or media reports about poor sustainability performance can damage a company in the eyes of customers, business partners or investors.
What companies need to do
Companies should act promptly, regardless of industry or packaging type:
- Identify their role in the PPWR framework
- Clearly define responsibilities for the PPWR
- Fully digitalise their packaging portfolio
- Compile the necessary technical documentation, set up compliance processes
- Systematically assess packaging in terms of packaging minimisation, recyclability, recycled content and reusability potential
- Include suppliers in data collection and documentation processes
- Monitor future developments regarding the PPWR (e.g. delegated acts and implementing acts) and take action as appropriate.
Our team is ready to advise and assist - get in touch today!
PPWR consulting services from Interzero
Need assistance for the fulfilment of your legal duties and looking for practical solutions? For over 35 years, Interzero has been an experienced partner for sustainability and the circular economy for customers worldwide. Benefit from our comprehensive expertise and extensive network, and rely on our competent team of experts to answer all of your PPWR questions. Contact us today – we’re at your service!
Do you have questions about the new EU PPWR?
Elena Ehmann
Consulting Expert
PPWR FAQ
- To which types of packaging does the EU Packaging Directive apply?
The EU Packaging and Packaging Waste Regulation (PPWR) applies to packaging that is placed on the market within the EU. This means all packaging manufactured within the European Union or imported into the EU from third countries.
- When does the PPWR enter into force?
The PPWR entered into force at the beginning of 2025. Most of its provisions have been applicable since 12 August 2026. Phased transition periods up to 2030 and beyond apply to individual requirements – such as recyclability, recycled-content percentages or reusability targets.
- Who is affected by the PPWR?
The Regulation affects almost all companies that manufacture, import, fill or distribute packaging, or are the first to place it on the EU market. These include producers, dealers, importers, e-commerce companies and brand owners.
- Does existing packaging need to be modified?
Yes, in many cases. Companies should check to confirm that their packaging fulfils future PPWR requirements in terms of recyclability, use of materials, labelling and documentation. Prompt analysis now will help to avoid costs for modification later.
- Why did the EU decide to adopt new packaging legislation?
Huge amount of packaging waste: Figures from the European Commission show that about 180 kg of packaging waste is produced per person, per year on average, and most of this waste consists of virgin materials. Some 40 percent of all plastics and 50 percent of all paper is used for packaging within the EU, with a 19 percent rise forecast here by 2030 if no countermeasures are introduced. The PPWR therefore aims to reduce this consumption while promoting the circular economy.
Inconsistent legislation and approaches: At national level, there are a great many approaches and regulations in force across the EU at the moment for the collection, reduction and recycling of packaging. Some countries are leading the way while others play catch-up, especially in terms of recycling rates. International producers and traders are faced with the never-ending challenge of knowing the specific regulations in each country and acting accordingly. The same is true for domestic e-commerce businesses who ship to other EU countries. Article 1 of the new Regulation defines the objective to both improve and harmonise the legal situation in the individual member states. We’ll be happy to advise you if you export products to other European countries and have questions about the EU Packaging and Packaging Waste Regulation.
- What does ‘Design for Recycling’ mean?
In the future, packaging must be designed to ensure that it can be collected, sorted and recycled efficiently. Combinations of materials that make recycling more difficult are to be reduced. Companies should therefore review their packaging in good time to confirm its recyclability.
- What are the advantages of early preparation?
Companies can reduce legal risks, design packaging to be fit for the future, and plan the necessary changes in product design and procurement well in advance of compliance deadlines. In many cases, this also avoids the costs involved in later changeovers.
