PPWR at a Glance: New EU Packaging Waste Regulation
What You Need to Know About the PPWR Regulation
Do the PPWR and its requirements seem like a complete mystery to you? Would you like to understand which requirements, deadlines, and legal foundations now apply to your company and its packaging? Then our knowledge article is just what you need!
The plastics processing industry and packaging manufacturers are facing an exciting yet challenging time. With the introduction of the new European Packaging Regulation (PPWR), the way we design and use packaging is undergoing a fundamental transformation. In this article, we take a closer look at what the PPWR entails, which rules apply from when, and why investing in bio-based and recycled plastics is worthwhile.
PPWR in a Nutshell for Quick Readers
The new European Packaging Regulation, known as PPWR (Packaging and Packaging Waste Regulation), aims to reduce the growing volume of packaging waste in the EU and prevent its increase by 2030 through a functioning circular economy. As of February 11, 2025, it replaces the current Packaging Directive, introducing stricter regulations and ensuring uniform implementation across member states. Over the next 18 months (until August 12, 2026), initial requirements must be put into practice to drive a sustainable transformation. Find out below what this means for you and which deadlines must be met. (Status February 2025)
Contents
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- What is the Packaging and Packaging Waste Regulation PPWR?
- How does the PPWR contribute to the circular economy? Goals of the Packaging and Packaging Waste Regulation PPWR
- When does the Packaging Waste Regulation PPWR come into effect? Dates & Deadlines
- Webinar: PPWR Packaging Waste Regulation – All deadlines, rules and requirements at a glance
- What does this mean for my packaging? What rules are included in the Packaging and Packaging Waste Regulation PPWR?
- Requirements for Substances in Packaging (Art. 5)
- Recyclability of Packaging (Art. 6)
- Minimum Recycled Content for Plastic Packaging (Art. 7)
- Bio-based Plastics (Art. 8)
- Compostable Packaging (Art. 9)
- Minimization of Packaging & Waste Prevention (Art. 10)
- Packaging Labeling and Transparency (Art. 12 & 13)
- Ban on Certain Single-Use Packaging (Art. 25 & Annex 5)
- Increased Share of Reusable and Reuse (Art. 11 & 29)
- Refill and Reuse Obligations (Art. 32 & 33)
- Extended Producer Responsibility (Art. 44 ff.)
- Deposit Requirements
- What role do bioplastics and recyclates play in implementing the PPWR?
- Five simple recommendations for action
What is the Packaging and Packaging Waste Regulation PPWR?
The EU has plans to significantly improve the sustainability of packaging. This is especially evident in the Packaging & Packaging Waste Regulation (PPWR). The regulation sets clear requirements for packaging and packaging waste made from all materials placed on the market in the EU. It includes, among other things, requirements for packaging design, regulations for reuse systems, and measures for waste management.
A key difference from the previous EU Packaging Directive (94/62/EC) lies in the legal form: While the directive could be individually interpreted by member states and implemented into national law, the PPWR is a regulation that applies uniformly and directly in all 27 EU countries. This removes the possibility for national adjustments, leading to a stronger harmonization of rules within the EU. It applies to companies based in the EU as well as those importing packaging into the EU, covering both domestic and imported products.
Whether the PPWR will indeed help eliminate the European patchwork in the field of circular economy remains to be seen. However, one thing is certain: The new regulation brings extensive and far-reaching obligations for all actors along the packaging lifecycle.
How does the PPWR contribute to the circular economy? Goals of the Packaging and Packaging Waste Regulation PPWR
The PPWR is a key element of the EU’s environmental policy agenda. At its core are the EU’s comprehensive efforts to promote the circular economy, use resources efficiently, and reduce overall waste production. Embedded in the European Green Deal, the PPWR aims to minimize the environmental impact of packaging by reducing waste volumes and promoting reuse and recycling through concrete measures and requirements. In this context, waste reduction is not only an environmental protection issue but also a crucial part of the EU’s international commitments. As part of the Paris Agreement, the EU pursues ambitious environmental goals and considers waste minimization a vital step in combating climate change.
The PPWR aims to establish a uniform framework with regulations for all EU member states. By harmonizing these rules, the environmental impact of packaging is to be reduced while simultaneously promoting sustainable development within the EU.
The main objectives of the Packaging and Packaging Waste Regulation PPWR are:
- Reduction of packaging waste (minimization of packaging)
- Promotion of recycling (requirements for recyclability, minimum recycled content, Design4Recycling)
- Improvement of environmental compatibility (reuse obligations, regulations on reuse)
- Increase in transparency (uniform labeling requirements, prohibitions)
When does the Packaging and Packaging Waste Regulation PPWR come into effect? Dates & Deadlines
The European Packaging and Packaging Waste Regulation (PPWR) was adopted by the European Council in December 2024, following approval by the European Parliament in November. The PPWR was officially published in the EU Official Journal under number 2025/40 on January 22, 2025. It formally entered into force on February 12, 2025. After an 18-month transition and implementation period, the regulation will be applied, meaning that most of the PPWR’s provisions will take effect from August 12, 2026, and must be followed in all EU member states. At this point, the previous Packaging Directive 94/62/EC will largely be repealed. However, not all provisions of the PPWR must be implemented immediately—some requirements will come into force gradually between 2026 and 2040.
Webinar: PPWR Packaging Waste Regulation – All deadlines, rules and requirements at a glance
In our webinar on 26.03.2025 you will learn everything about the regulations and deadlines of the EU Packaging Waste Regulation PPWR. Patrick Zimmermann, our expert, will show you how you can make your packaging more environmentally friendly and recyclable by using our extensive range of bio-based, biodegradable and recycled plastics. In addition, our recycling expert will critically analyze the Packaging Waste Regulation PPWR and highlight the resulting possibilities and opportunities, but also the limits.
What does this mean for my packaging? What rules does the Packaging Waste Regulation PPWR include?
The regulation sets specific goals and measures to strengthen the circular economy. Here is an overview of what this means for your packaging or product:
Requirements for Substances in Packaging (Art. 5)
Article 5 of the PPWR establishes specific requirements for substances in packaging to reduce environmental impact and enhance consumer safety. These requirements include limit values for certain chemicals such as lead, cadmium, mercury, and hexavalent chromium. Additionally, there is a marketing ban on food packaging if it reaches or exceeds certain PFAS limits.
Recyclability of Packaging (Art. 6)
From 2030, all packaging must be recyclable or reusable
The PPWR sets specific design requirements and ambitious targets to ensure that, by 2030, all packaging is either reusable or recyclable after use. Packaging is considered recyclable if it can be processed into secondary raw materials of such high quality that they can replace primary raw materials. Moreover, packaging must be collected, sorted, and processed in a way that does not compromise the recyclability of other waste streams. As of January 1, 2035, packaging must be recycled on a large scale to promote the circular economy.
Classification of Recyclability
A classification system for the recyclability of packaging is being introduced, distinguishing between performance levels A, B, and C. Packaging with a recyclability rate below 70% will no longer be considered recyclable and may not be placed on the market starting in 2030. From 2038, this ban will be extended to class C, meaning packaging with a recyclability rate of less than 80%.
Establishment of Design Criteria
The Packaging and Packaging Waste Regulation PPWR promotes the Design4Recycling approach, which prioritizes reusability and material recycling. Companies should now thoroughly review their packaging designs and make adjustments where necessary and feasible. This is also financially beneficial, as the PPWR sets the framework for an eco-based adjustment of disposal fees. In the future, packaging that is easier and more efficient to recycle will incur lower disposal costs compared to less recyclable alternatives. The EU Commission plans to publish the “Design for Recycling Guidelines” by January 1, 2028. The specific implementation will be determined by individual member states and must be enforced 1.5 years later. This creates a clear incentive to promote environmentally friendly packaging solutions.
Use of Recycled Materials / Minimum Recycled Content for Plastic Packaging (Art. 7)
The regulation mandates a significantly higher use of recycled materials in packaging. The EU has set fixed minimum recycled content percentages for different types of packaging and materials to close material loops and reduce the demand for new primary raw materials. The recycled content is calculated annually per packaging type and format for each manufacturing facility. A corresponding proof of compliance must be provided as part of the technical documentation.
Minimum Post-Consumer Recycled Content (PCR) Requirements for Plastic Packaging from 2030:
- 30% (50% by 2040) for contact-sensitive PET packaging (excluding beverage bottles)
- 10% (25% by 2040) for contact-sensitive packaging made of materials other than PET (excluding beverage bottles)
- 30% (65% by 2040) for single-use plastic beverage bottles
- 35% (65% by 2040) for plastic packaging not covered by the above categories
For packaging made from the following raw materials, the minimum recycled content requirements will apply from 2030:
- Glass: At least 50% recycled content
- Paper and cardboard: At least 70% recycled content
- Metal: At least 25% recycled content
According to the EU Packaging Regulation, packaging containing plastic must include a mandatory minimum proportion of post-consumer recycled content (PCR) from 2030, with a few exceptions. However, the increased use of PCR presents challenges, particularly regarding the availability and quality of recycled materials. Learn more about recycled materials here!
Bio-based Plastics (Art. 8) – A Missed Opportunity?
Unlike the use of recycled plastics, the Packaging and Packaging Waste Regulation PPWR does not set any requirements for the use of bio-based plastics yet. However, by February 12, 2028, the Commission will assess whether bio-based plastics should be recognized as an alternative to recycled plastics for meeting quota requirements. In addition, the legislative proposal could include sustainability requirements as well as targets for increasing the use of bio-based raw materials.
Want to start using bio-based plastics and reduce greenhouse gas emissions already today?
The equal treatment of bio-based and recycled plastics makes sense from several reasons: There is already a shortage of high-quality, food-contact-compliant recycled materials, and these supply bottlenecks will likely intensify in the future. Secondly, bio-based plastics play a crucial role in reducing CO₂ emissions and decreasing dependence on fossil-based materials. This was a missed opportunity to equate a practical, highly recyclable, and innovative solution with recycled materials. Bio-based drop-in plastics (such as bio-PE) are not just an alternative to recyclates but an essential part of the EU’s transition to sustainable packaging systems.
Compostable Packaging (Art. 9)
According to Article 9 of the Packaging and Packaging Waste Regulation PPWR, certain types of packaging must be compostable from February 12, 2028, to ensure biodegradability. These include tea bags, coffee pads and stickers for fruits and vegetables.
Additionally, individual member states may mandate further applications to be compostable, such as very lightweight carrier bags (e.g., for bio-waste collection) or coffee capsules. This is allowed if a suitable collection and disposal infrastructure is available and additional requirements are met. If certain applications were already required to be compostable in a member state before the PPWR takes effect, these regulations may remain in place.
Discover our portfolio of certified home and industrially compostable plastics. For agricultural and nature-based applications, we even offer certified soil-degradable plastics!
Minimization of Packaging & Waste Prevention (Art. 10)
The Packaging and Packaging Waste Regulation PPWR aims to minimize excessive packaging and significantly reduce the overall amount of packaging waste. Within the framework of the EU Packaging Regulation (Art. 43), the EU sets clear reduction targets for packaging waste: 5% reduction by 2030, 10% by 2035, and 15% by 2040.
In addition, member states must meet mandatory recycling targets by 2030, depending on the material type (plastic, glass, metal, wood, paper, and cardboard).
In addition to waste prevention, these targets should primarily be achieved by avoiding unnecessary and excessive packaging as well as by reducing packaging volume and sizes. Innovative, modular packaging designs that facilitate reuse and recycling should also be promoted.
From January 1, 2030, packaging must be reduced to the required minimum size to prevent material waste (ban on double walls, false bottoms, unnecessary layers, misleading packaging, etc.). Additionally, Article 24 includes requirements for void space limitation. From January 1, 2030, the void space (air & filling materials) in secondary, transport, and shipping packaging must not exceed 50%. However, packaging must still meet requirements for product protection, logistics, functionality, as well as hygiene and safety standards.
Packaging Labeling and Transparency (Art. 12 & 13)
From August 12, 2028, packaging must be clearly labeled with a harmonized label to inform consumers about recyclability and the correct disposal method. This aims to facilitate recycling and reduce the amount of improperly disposed packaging waste.
Special labeling requirements will apply to compostable packaging, substances of concern, and reusable packaging. The specific details will be determined through further implementing acts.
Ban on Certain Single-Use Packaging (Art. 25 & Annex 5)
From January 1, 2030, economic operators may no longer place packaging formats listed in Annex V of the PPWR on the market. The Packaging and Packaging Waste Regulation PPWR builds on the EU Directive on Single-Use Plastics and establishes additional bans on the use of single-use plastic packaging. However, since Annex 5 includes a variety of exceptions to the individual bans, it is worth taking a closer look at the details.
Bans from January 1, 2030:
- Single-use plastic outer packaging for bundling goods at the point of sale
- Single-use plastic packaging for fresh, unprocessed fruit & vegetables under 1.5 kg
- Single-use plastic packaging for food and beverages consumed on-site in the hospitality industry
- Single-use plastic packaging for single servings of condiments, sauces, coffee cream, sugar, and spices
- Ban on single-use packaging (e.g., toiletries) in hotels
- Ban on very lightweight plastic carrier bags under 15µm
The bans in Article 25 and Annex V, however, do not apply to composite packaging with a plastic content of up to 5%. Unlike the SUPD, such packaging formats are not defined as plastic products in the PPWR. Therefore, paper packaging coated with plastic can still be marketed despite the bans. However, these are not “more environmentally friendly” than well-recyclable plastic packaging. On the contrary, the plastic coating disrupts the otherwise effective paper recycling process.
In addition to the restrictions already set out in Annex V, Article 67 introduces some new bans that complement the EU Single-Use Plastics Directive (SUPD). Here are the key points:
- Ban on shrink film for luggage
- Ban on polystyrene chips as filling material
- Ban on multi-pack plastic rings as outer packaging
- Ban on packaging made from extruded polystyrene (XPS) for ready-to-eat food and beverages. This closes an important legal gap in the SUPD, which initially only included a ban on expanded polystyrene (EPS).
Increased Share of Reusable and Reuse (Art. 11 & 29)
The European Packaging Regulation (PPWR) includes comprehensive measures to promote the reuse of packaging and the establishment of reuse systems. This includes incentives and requirements for manufacturers and retailers to set up and use reuse systems. The Packaging and Packaging Waste Regulation PPWR introduces a mandatory regulation that, from August 12, 2026, a so-called reuse system for reusable packaging must be in place. Particularly noteworthy are the comprehensive changes to the mandatory reuse obligations, which specifically apply to industrial and commercial packaging. Additionally, there are new requirements for certain takeaway food and beverages, which must allow for refilling and include the obligation to provide reusable options.
From 2030, the following mandatory reuse rates will be established for certain packaging types—subject to certain exceptions:
- 10% for beverage packaging (40% in 2040)
- 40% for transport, sales, and e-commerce packaging (70% in 2040)
- 10% for outer packaging (25% in 2040)
A reuse requirement also applies to transport, sales, and e-commerce packaging used within the EU to transport products between different locations of a company. Additionally, all packaging used within a member state must be reusable packaging. Exemptions from these quotas include materials such as paper and cardboard, as well as packaging for items like dangerous goods, large machinery, etc. The PPWR also contains very detailed reuse requirements for beverage packaging, many of which come with exceptions. Packaging manufacturers and users should closely review the regulations.
To prove compliance with the reuse requirements, companies using the specified packaging formats must submit an annual report with detailed data to the relevant authority in their member state starting from 2030. The exact method for calculating the reuse rates will be established by the European Commission in an implementing act by June 30, 2027.
Refill and Reuse Obligations for the Takeaway Sector (Art. 32 & 33)
From February 12, 2027, food service establishments will be required to offer their customers the option to refill hot or cold beverages, as well as ready-to-eat meals, in containers brought by the consumers themselves. The liability issues in case of food safety concerns will be passed on by the Commission to the member states, so the implementation is still pending.
One year later, starting February 12, 2028, the takeaway of food and beverages must also be allowed in reusable packaging (within a reuse system). This takeaway option must not be more expensive or have unfavorable conditions for the consumer.
Exceptions to these obligations apply to small businesses (fewer than 10 employees and annual turnover or total balance sheet of up to 2 million euros).
Unlike the SUPD, the Packaging and Packaging Waste Regulation PPWR does not contain a mandatory reuse quota for food and beverages. Food service establishments are only required to aim for offering 10% of their products in reusable packaging by 2030. However, member states may introduce such mandatory reuse quotas at the national level. The obligations arising from the SUPD, such as the reuse requirement in Germany, will still apply and be expanded upon with the Packaging and Packaging Waste Regulation PPWR regulations.
Promotion of More Sustainable Packaging Solutions through EPR Systems (Extended Producer Responsibility) (Art. 44 ff.)
The PPWR introduces the concept of Extended Producer Responsibility (EPR), which obligates companies to consider the entire lifecycle of their packaging. This includes design, use, and disposal. Manufacturers must ensure that their packaging is easily recyclable and bear the costs for the collection, recovery, and recycling. At the same time, businesses are encouraged to develop and use more environmentally friendly packaging solutions. The implementation of the EPR obligations in Germany is expected to take place in the next revision of the Packaging Act, starting in autumn 2025.
Deposit Requirements
Overall, the PPWR aims to strengthen the circular economy in the EU by setting clear guidelines for reducing packaging waste, promoting recycling, and increasing the use of recycled materials. This is an important step towards a more sustainable and resource-efficient economy. Read here for 8 simple ideas for a more sustainable product!
What role Do Bioplastics and Recycled Materials play in implementing the Packaging Waste Regulation PPWR?
The role of bioplastics and recycled materials in implementing the Packaging and Packaging Waste Regulation (PPWR) is central, as both approaches can contribute to achieving the goals of the regulation, but their roles are different:
Bioplastics made from renewable resources help reduce dependence on fossil resources. This aligns with the PPWR’s objective to minimize the ecological footprint of packaging. Bioplastics with certified compostability can be significant for specific applications, such as food packaging, where organic residues often make recycling difficult. However, the PPWR specifies that biodegradable packaging should only be used in clearly defined cases (see above).
The PPWR calls for an increased share of recycled materials in new packaging. This will play an especially important role in plastic packaging to strengthen the circular economy and reduce dependence on primary materials. Recycled materials enable the closure of the loop, as they extend the lifecycle of plastics by being reintroduced into the production process as materials. This aligns with the goals of the PPWR, which aims to reduce waste and increase resource efficiency.This is why the PPWR defines, among other requirements, specified minimum recycled contents for plastic packaging (see above).
Five Recommendations for the EU Packaging Waste Regulation (PPWR)
- Review your current packaging designs for recyclability and efficiency.
- Develop strategies to integrate recycled materials or bioplastics meaningfully into your packaging.
- Stay up to date with legal requirements and document your sustainability efforts.
- Collaborate with experts to adapt your packaging to the requirements of the PPWR.
- Develop concepts that go beyond the legal minimum requirements to position yourself as an industry leader.
Time is running out…! Start now!
The clock is ticking: With just over five years left until the final provisions take effect in 2030, many companies will need years to build a closed-loop system that is not only PPWR-compliant but also economically viable. Early adaptation of your products and processes is crucial to remain competitive and capitalize on the opportunities the new regulations present.
Take action now and contact us today to be well-prepared! As circular economy specialists, we can help you find the right recycled or bio-based material for your product that meets PPWR requirements.
