PPWR – the European Packaging Regulation
Packaging protects products from spoiling and makes them transportable, but it consumes valuable resources and causes waste. To limit the environmental impact, the European Union has issued the PPWR. We explain what it means and what you need to bear in mind.
Europe consumes large quantities of packaging. In mathematical terms, it is 186 kilograms per citizen of the European Union. And consumption is increasing: by 2030, consumption is expected to increase by 19 % and for plastic packaging, the increase is as much as 46 %. This is associated with a high consumption of energy and raw materials – and in the end, large quantities of packaging waste remain, which should be used sensibly.
The European Union is responding to these challenges with the “Packaging and Packaging Waste Regulation (PPWR)". It addresses all types of packaging and aims to limit the consumption of packaging, promote reuse, and advance recycling and the circular economy of packaging, among other things.
Areas of regulation – what issues will the PPWR address?
The PPWR aims to define basic rules for extended producer responsibility (EPR) that apply uniformly throughout the EU. This will bring advantages for industry: instead of having to comply with separate rules for each member state, harmonization will noticeably simplify business.
In addition, the PPWR regulates the basic technical conditions that packaging must meet, in some cases in great detail. In future, packaging must be designed to be recyclable and made from recycled materials/recyclates wherever possible.
The PPWR covers the following technical and administrative aspects:
Example of coffee capsules
Before the PPWR came into force, coffee capsules (more precisely defined as “beverage system capsules”) that are not empty after use were not considered to be packaging. They therefore did not have to be disposed of through the dual system and could be disposed of with residual waste after use. The PPWR changes this: in the future, coffee capsules will be considered packaging, regardless of whether they still contain coffee grounds or not. Incidentally, this also applies to coffee pods and tea bags.
Who is considered to be a manufacturer? (art. 3)
Any producer, importer or distributor who, irrespective of the method of sale, is established in an EU-Member State and makes (unfilled) transport, service or primary production packaging or packaged products in packaging other than those mentioned above available on the market for the first time in that Member State.
The same applies to producers, importers or distributors who are established in an EU-Member State or third country and directly supply end users in another Member State.
A manufacturer is also someone who is established in an EU-Member State and unpacks packaged products without being the final consumer, unless another person mentioned above is the producer.
As a rule, manufacturers are responsible for fulfilling the PPWR requirements, such as system participation.
Free movement of goods (art. 4)
Packaging may only be placed on the market if it complies with this Ordinance (see also EU-declaration of conformity).
National sustainability or information requirements that go beyond this Ordinance must not impede the free movement of goods.
This gives the Member States limited leeway. However, this is not intended to restrict the free movement of goods in the single market.
Requirements for substances in packaging (art. 5)
Packaging must be produced in such a way that the presence and concentration of substances of concern is reduced to a minimum. This also includes the presence or formation of microplastics. The Commission is authorized to restrict the use of hazardous substances if they hinder the recycling of materials. Furthermore, a cumulative limit value of 100 mg/kg, which has been in place for years, still applies to lead, cadmium, mercury and hexavalent chromium.
Notwithstanding the restrictions in other regulations such as the REACH Regulation, packaging that comes into contact with food must not contain perfluorinated and polyfluorinated alkyl substances (PFAS) in certain concentrations. Packaging that exceeds the limits specified in the regulation may no longer be placed on the market from August 2026.
Recycable packaging (art. 6)
In 2030, only packaging that is classified as recyclable may be placed on the market. This means complying with recycling-friendly design criteria (DfR criteria), which will be expanded in 2035 to include the technical criterion “recycling at scale” (RaS).
This is intended to ensure that the packaging is actually “recycled at scale” by the collection, sorting and recycling infrastructures in operation. Specifically, the PPWR specifies a recycling rate at Union level of at least 55 % for the 12 categories listed in Annex II Table 2 (various plastics, PPC, liquid cartons, metals, glass and other materials). For wooden packaging, 30 % applies.
Packaging is considered recyclable if it
- is designed for recycling,
- can be effectively and efficiently collected separately and sorted into specific waste streams
- without affecting the recyclability of other waste streams and
- the secondary raw materials produced from it are of sufficient quality to replace primary raw materials.
Performance levels and prohibitions
Depending on the degree of recyclability, the PPWR differentiates between various levels of recyclability, with 70 % being the limit from which packaging is considered recyclable.
From 2030, non-recyclable packaging will be banned, i.e. all packaging that does not comply with performance levels A, B or C and is therefore less than 70 % recyclable will be considered technically non-recyclable and prohibited to be placed on the market.
Here are the binding quotas and timetables, which will gradually increase from 2030:
Minimum recycled content in plastic packaging (art. 7)
A circular economy means keeping raw materials in a cycle. Instead of extracting them from the earth's crust for a single use and then disposing of them at the end, they are used again and again to manufacture new products. Products are made from circular raw materials instead of fossil raw materials. Of course, this also applies to packaging. This is nothing new for some packaging materials, such as glass and some metals. However, the use of so-called recyclates in plastic packaging is negligible. The PPWR wants to change this and is therefore prescribing quotas for the use of recyclates in packaging for the first time.
Details of these provisions are also not yet fully known or decided. By the end of 2026, the European Commission will issue delegated acts on calculation and verification methods.
In addition, the Commission will assess whether the targets are realistic in this form. By January 1, 2028, it will review whether deviations due to availability, safety risks or excessive prices are to be made by delegated act.
Recycled content may be taken into account in EPR fees (from around mid-2028)
The following plastic packaging is excluded from the targets for the use of recycled materials:
- packaging for medical products, baby/child nutrition,
- compostable plastic packaging,
- plastic packaging with food contact where there are concerns about health risks to humans due to migration (non-compliance with EC 1935/2004),
- packaging with a plastic content of < 5 %.
Biobased feedstock in plastic packing (art. 8)
By February 12, 2028, the Commission will review the status of technological development and the environmental compatibility of bio-based plastic packaging.
Depending on the outcome, there may be a draft law in which
- Sustainability requirements for biobased feedstock in plastic packaging
- targets for the use of such feedstock in plastic packaging and
- optionally the recognition of biobased feedstock in the calculation of recycled content
are defined.
Compostable packaging (art. 9)
The PPWR sets out clear guidelines for the treatment of compostable packaging to promote environmentally friendly waste management. Compostable packaging should only be used where it makes sense for the circular economy, and it must meet specific standards to ensure that it can be efficiently broken down in industrial composting facilities.
From February 12, 2028
- non-empty, permeable or softening beverage bags, e.g. for tea or coffee, as well as single-serve packaging for tea, coffee and other beverages that is not completely empty and
- adhesive labels attached to fruit and vegetables,
must be compostable under industrially controlled conditions in biowaste treatment plants and - if nationally required - also suitable for home composting. Conversely, this packaging is exempt from the recyclability requirements of article 6.
Member states can require nationally that
- beverage system capsules (unless made of metal) and lightweight and very lightweight plastic carrier bags must be compostable and
- protection applies to compostable packaging introduced before the application of the PPWR, i.e. before August 12, 2026.
Packaging minimisation (art. 10)
The PPWR also sets out requirements for minimizing packaging from 2030. This includes reducing weight and volume to a minimum, i.e.
- a ban on packaging that only aims to “increase the perceived volume of the product”, in particular double walls, double bottoms and unnecessary layers (although various EU-protected brands will be protected).
Whereby, at the instigation of the Commission, detailed standards for determining (e.g. proportion of empty space, wall thicknesses) are to be developed by the European standardization organizations by 12 February 2027.
From 2030, there will also be a ban on excessive packaging, so-called 'deceptive packaging' (Art. 24 with recourse to Art. 10).
For outer packaging, transport packaging or packaging for e-commerce (shipping packaging) that is delivered to final distributors or end consumers, the following applies
- Empty space percentage ≤ 50 % (space between primary sales packaging and secondary packaging),
- until February 2028 adoption of delegated acts for assessment,
- does not apply to primary packaging (but prohibition of “deceptive packaging”).
Reusable packaging (art. 11 in combination with art. 29)
Reusing packaging is an important way of avoiding packaging waste. There have long been more options than just filling drinks in reusable plastic or glass bottles. Packaging that is used to transport products from one plant to another or directly to the customer must also be designed in such a way that it can be used several times.
When the PPWR comes into force, conditions will be attached for the first time to the classification of packaging as reusable, which will be supplemented by a delegated act by February 2027, in which specific minimum cycles will be prescribed for common packaging formats.
In principle, packaging is considered reusable if it:
- can be reused or refilled several times,
- can be emptied, unloaded, refilled or refilled without compromising the quality and safety of the packaged product,
- can be unloaded, refilled or refilled without damage and in compliance with safety and hygiene regulations and
- are recyclable if they become waste.
The PPWR sets out requirements for the reuse of sales packaging as well as for transport, sales and e-commerce packaging and for transport and sales packaging used within companies.
Labelling of packing (art. 12 and 13)
In order to ensure better sorting by end consumers and thus higher recycling, packaging must be labeled with standardized EU-wide pictograms based on its material composition from August 2028.
However, the exact design of the labels is still pending. A first, non-final draft is shown opposite.
Two years earlier, i.e. by August 2026, the Commission will adopt implementing acts to define both the assessment criteria and the graphic presentation.
The harmonized labeling of single-use plastic beverage bottles and single-use metal beverage containers with a capacity of up to three liters each, which have to participate in deposit or return systems, will also become mandatory. Six months later (February 2029), the labeling obligation will also include reusable packaging outside of the aforementioned systems, which must also be provided with a QR code containing further end consumer information.
Information on the recycled content, bio-based plastic content or participation in extended producer responsibility systems, such as the Green Dot, is voluntary, but must meet various requirements.
There is no provision for labeling transport packaging, but there is for e-commerce packaging.
EU-declaration of conformity & technical documentation (art. 39)
The requirements for packaging specified in the regulation are to be determined by standardized EU-wide testing and verification procedures and recorded by the respective obligated manufacturer through self-assessment in the form of technical documentation. Ultimately, each manufacturer must draw up an EU Declaration of Conformity in accordance with Annex VIII for each packaging, in which the compliance of the packaging with the requirements of Articles 5 - 12 of the PPWR is confirmed.
This includes the following areas:
- Requirements for substances in packaging (art. 5)
- Recyclable packaging (art. 6)
- Minimum recycled content in plastic packaging (art. 7)
- Biobased feedstock in plastic packaging (art. 8)
- Compostable packaging (art. 9)
- Packaging minimisation (art. 10)
- Reusable packaging (art. 11)
- Labelling of packaging (art. 12)
If the existing procedures and standards do not provide sufficient results, the Commission is empowered to adopt corresponding delegated acts.
While the declaration of compliance only has to be submitted at the request of national authorities, importers, distributors or fulfillment service providers, for example, must check it in each case, as they are prohibited from continuing to make non-compliant packaging available on the market.
