Which packaging rules apply to you?

The PPWR, Regulation (EU) 2025/40 on packaging and packaging waste, is the EU law that sets one set of rules for all packaging on the EU market, in force since 11 February 2025 and applicable since 12 August 2026 (Art. 71). As a regulation it applies directly in all 27 Member States without national transposition, and it repealed the Packaging Directive 94/62/EC with effect from 12 August 2026 while keeping four parts of that Directive for a transition until 2028 or 2029. Further obligations follow in steps until 1 January 2040, and several of them start only after the European Commission adopts a delegated or implementing act.

The Regulation binds every operator in the packaging chain: the manufacturer that proves conformity, the supplier of packaging materials, the importer, the distributor, the fulfilment service provider and the producer that registers and pays for extended producer responsibility (EPR) in each Member State. It sets limits for PFAS in food-contact packaging (25 ppb, 250 ppb and 50 ppm) and for heavy metals (100 mg/kg), recyclability grades A, B and C, recycled content targets for plastic packaging, a 50 % maximum empty space ratio, harmonised labels, six format restrictions and re-use targets. Member States keep their own producer registers, competent authorities and penalty rules.

This page explains what the PPWR is and what it replaces, maps the eight parts of the Regulation, sets out who must comply, lists the key dates from 2025 to 2040 with the article behind each date, summarises the requirements in the order of the Regulation and the duties of each operator, and shows how the national layer works in Germany, France and the other 25 Member States. Every statement cites its article; questions about a specific product go to the competent authority of the Member State concerned.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources. Every date and article reference is checked; see our methodology and fact-checking.

What Is the PPWR?

PPWR stands for Packaging and Packaging Waste Regulation, the short name of Regulation (EU) 2025/40 of 19 December 2024, published in OJ L, 2025/40, 22.1.2025 (CELEX 32025R0040). Its full title is Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. The PPWR is the single EU-wide rulebook for how packaging is designed, labelled, placed on the market, collected and recycled. Its legal basis is Article 114 of the Treaty on the Functioning of the European Union (TFEU), the internal-market legal basis, and Article 4(2) of the PPWR bars Member States from prohibiting, restricting or impeding packaging that complies with Articles 5 to 12.

How large is the Regulation? Besides 188 recitals, the text has the four structural counts listed below.

• Chapters: 13, including Chapter II on sustainability requirements (Art. 5 to 11), Chapter V on excessive packaging, format restrictions and re-use (Art. 24 to 33) and Chapter VIII on packaging and packaging waste management (Art. 40 to 57).
• Articles: 71, ending with Art. 71 on entry into force and application.
• Annexes: 13, from Annex I, an indicative list of packaging examples, to Annex XIII, the correlation table with Directive 94/62/EC.
• Definitions: 71 numbered points in Art. 3(1), including the manufacturer (point 13), the producer (point 15) and the importer (point 17).

The Commission proposed the Regulation as COM(2022) 677 on 30 November 2022 (procedure 2022/0396(COD)). The European Parliament adopted its first-reading position on 24 April 2024, the Council adopted the act on 16 December 2024, and it was signed on 19 December 2024. As of 24 October 2026 the PPWR is not amended: the only consolidated version is the original text, and none of the 7 corrigenda published between 22 May 2025 and 18 September 2026 corrects the English language version.

Is the PPWR a regulation or a directive?

The PPWR is a regulation: binding in its entirety and directly applicable in all Member States, with no national transposition (Art. 71 PPWR). Its predecessor, Directive 94/62/EC, had to be transposed into national law in each Member State. Since 12 August 2026 the same wording of Regulation (EU) 2025/40 applies in all 27 Member States, and the terms "PPWR directive" or "EU packaging directive" refer to a law that is repealed.

Direct application does not remove national law. Member States designate the competent authorities, run the producer registers, set national EPR rules inside the framework of Articles 44 to 47 and lay down penalty rules by 12 February 2027 (Art. 68). Germany, for example, replaced its Verpackungsgesetz with the Verpackungsrecht-Durchführungsgesetz (VerpackDG), which applies from 12 August 2026. National acts of this kind add registers, schemes and penalties; they do not restate the product requirements of the Regulation.

What does the PPWR replace?

The PPWR replaces Directive 94/62/EC on packaging and packaging waste, repealed with effect from 12 August 2026 with four carry-overs in Article 70(1) of the PPWR. The Packaging Directive 94/62/EC (OJ L 365, 31.12.1994, p. 10) was in force for more than 31 years. Article 70(1) keeps four parts of it: (a) the material identification rule in Art. 8(2) of the Directive until 30 months after the Art. 12(6) implementing act enters into force; (b) the minimisation essential requirement, with the EN 13428:2004 presumption, until 31 December 2029; (c) Art. 5(2) and (3), 6(1)(d) and (e) and 6a of the Directive until 31 December 2028; and (d) its reporting rules in Art. 12(3a) to (4) until 31 December 2028, with data transmission until 31 December 2029.

Decision 97/129/EC on the material identification system is repealed separately, with effect from 12 August 2028 (Art. 70(2)). The Single-Use Plastics Directive (EU) 2019/904 is amended, not repealed (Art. 67). References to Directive 94/62/EC in other acts are read through the Annex XIII correlation table (Art. 70(5)), and what carries over article by article is set out in PPWR vs the Packaging Directive 94/62/EC.

What Does the PPWR Cover? The Regulation in Eight Parts

The PPWR covers eight areas, from the legal text and its dates to product requirements, re-use, EPR, packaging waste, operator compliance and national rules. The table below maps the PPWR legal text, the PPWR timeline, the PPWR requirements for packaging, the PPWR reuse targets, EU packaging EPR under the PPWR, EU packaging waste, PPWR compliance and PPWR in the 27 member states to their articles. It then lists the cross-cutting pages: PPWR by packaging material, PPWR by sector, PPWR by packaging type, PPWR compared, PPWR tools, PPWR compliance services and PPWR news. The eight parts together cover all 71 articles and 13 annexes, in the order of the Regulation.

Who Must Comply with the PPWR?

The PPWR applies to all packaging, regardless of material, and to all packaging waste, whether it arises in industry, other manufacturing, retail or distribution, offices, services or households (Art. 2(1) PPWR). Packaging is an item, irrespective of the materials from which it is made, that an economic operator uses for the containment, protection, handling or delivery of products, among the functions listed in Art. 3(1)(1). Annex I gives an indicative list of examples; according to Commission Notice C/2026/3084, inclusion in Annex I alone does not make an item packaging.

Which companies does that bind? Six operators carry duties under the PPWR, listed below.

• Manufacturers (Art. 3(1)(13)): carry out the conformity assessment, draw up the technical documentation and the EU declaration of conformity (Art. 15).
• Suppliers of packaging or packaging materials: give the manufacturer the information and documents it needs to show conformity (Art. 16).
• Importers (Art. 3(1)(17)): established in the Union, check the manufacturer's documents before placing packaging from a third country on the market and add their own contact details (Art. 18(2), (3)).
• Distributors: verify that the producer is registered and that the packaging is labelled (Art. 19(2)).
• Fulfilment service providers: keep packaging compliant while they handle it (Art. 20) and check the producer's registration when the contract is concluded (Art. 45(7)).
• Producers (Art. 3(1)(15), cases (a) to (e)): register in each Member State where they first make packaging available, report and finance EPR (Art. 44, 45).

One company often holds two roles. An importer established in the Union is bound by the product duties of Art. 18 and, in the Member State where it first makes the packaging available, is also the producer for EPR. There is one producer per packaging unit per Member State of first making available.

In Northern Ireland the PPWR applies under the Windsor Framework, except for the provisions listed in Commission Notice C/2025/946 (OJ C, 4.2.2025), among them Articles 29 to 33 on re-use and Articles 41 to 55 on packaging waste management.

Does the PPWR apply to companies outside the EU?

Yes, through the packaging they sell into the EU: the EU importer carries the product duties, and a third-country seller is the EPR producer only when it supplies end users in a Member State directly (Art. 3(1)(15)(c), (d), Art. 18 PPWR). An importer is a natural or legal person established in the Union that places packaging from a third country on the market (Art. 3(1)(17)), so a company with no EU establishment is never the importer.

A third-country seller that supplies a business customer in the EU is not the producer: the EU importer or distributor is. The checks an EU importer runs on the manufacturer's documents, and the contact details it adds, are set out in PPWR obligations of importers.

A producer under Art. 3(1)(15)(c) or (d), which supplies end users in another Member State directly, must appoint an authorised representative for EPR in each Member State where it first makes packaging available, other than its own, since 12 August 2026 (Art. 45(3) first sentence). Member States may also require other third-country producers to appoint one (second sentence).

This page covers the EU rule only; how sellers in the United Kingdom, the United States and other third countries meet it is explained in PPWR for non-EU exporters.

When Does the PPWR Apply? Key Dates from 2025 to 2040

The PPWR entered into force on 11 February 2025 and applies from 12 August 2026, while later obligations start between 2027 and 2040, several only after a Commission act. Where a date depends on a Commission act, the rule applies from the fixed date or a set period after the act, whichever is later, so a late act moves the start back. The table lists each key date, oldest first, with its article and its status as of 24 October 2026.

What applies since 12 August 2026?

Since 12 August 2026 the PPWR applies in all 27 Member States, including the PFAS limits for food-contact packaging, the operator obligations of Articles 15 to 22, producer registration and EPR, and the conformity documentation. The five groups of rules that apply since that date are listed below.

• PFAS limits: food-contact packaging only, under Art. 5(5), next to the heavy-metal limit of Art. 5(4) for all packaging.
• Operator obligations: manufacturers, suppliers, authorised representatives, importers, distributors and fulfilment service providers (Art. 15 to 22).
• Producer registration and EPR: a register in each Member State, an annual report by 1 June and, for producers under Art. 3(1)(15)(c) and (d), an EPR authorised representative (Art. 44 to 47).
• Conformity documentation: the Annex VII technical documentation and the EU declaration of conformity (Art. 38, 39).
• Reusable packaging criteria: the 9 cumulative criteria of Art. 11, enforceable since 12 August 2026 for reusable packaging placed on the market from 11 February 2025.

Packaging placed on the market before 12 August 2026 may stay on the market, according to Commission Notice C/2026/3084, section 5 (non-binding). The Notice also reads the PFAS limits as having no sell-off period: packaging placed on the market from 12 August 2026 must meet them. Reusable packaging placed on the market before 11 February 2025 needs no corrective action (Art. 15(9)). Each rule that applies from the general application date, and each that waits for a Commission act, is listed in PPWR since 12 August 2026.

What changes from 1 January 2030?

Four rules apply on the fixed date of 1 January 2030 (minimisation, the six Annex V restrictions, the refill-area endeavour and the re-use targets), while recyclability, recycled content and the empty space ratio apply from 1 January 2030 or later, whichever is the latest. Minimisation under Art. 10 takes over from the Directive's minimisation requirement, which stays until 31 December 2029. The six Annex V formats are restricted under Art. 25(1). Final distributors with more than 400 m2 of sales area endeavour to dedicate 10 % of it to refill stations (Art. 28(5)). The re-use targets of Art. 29 require at least 40 % for transport packaging, 10 % for grouped packaging in boxes other than cardboard, and 10 % for beverages offered by final distributors.

The three conditional rules carry their own triggers. Packaging below grade C cannot be placed on the market from 1 January 2030 or 24 months after the Art. 6(4) delegated acts, whichever is later. The 2030 recycled content targets of 30 % for contact-sensitive PET, 10 % for other contact-sensitive plastic, 30 % for single-use plastic beverage bottles and 35 % for other plastic packaging apply from 1 January 2030 or 3 years after the Art. 7(8) implementing act (Art. 7(1)). As arithmetic, an Art. 7(8) act entering into force after 1 January 2027 moves that start beyond 1 January 2030. The 50 % empty space ratio applies from 1 January 2030 or 3 years after the Art. 24(2) implementing acts (Art. 24(1)). Each 2030 rule and its trigger is worked through in PPWR 2030 deadlines.

What is still pending on 24 October 2026?

As of 24 October 2026 the only adopted PPWR delegated act is Delegated Decision (EU) 2026/429 on pallet wrappings and straps, and no implementing act exists, so the register format (Art. 44(14)) and the harmonised labels (Art. 12(6)) are overdue. The register-format implementing act was due 12 February 2026; a draft (Ares(2026)7688068) was published for feedback on the Commission's Have Your Say portal, and until an act applies each Member State keeps its own register format. The harmonised label acts were due 12 August 2026. The Art. 7(8) recycled content act is due 31 December 2026 and is not adopted as of 24 October 2026. Further deadlines follow: the Art. 11(2) delegated act on minimum rotations for reusable packaging by 12 February 2027, the Art. 30(3) re-use calculation act by 30 June 2027, the Art. 6(4) design-for-recycling delegated acts by 1 January 2028 and the Art. 24(2) empty space methodology by 12 February 2028.

Delegated Decision (EU) 2026/429 of 25 February 2026 (OJ L, 2026/429, 6.5.2026) is in force since 26 May 2026 and is based on Art. 29(18)(a). It exempts pallet wrappings and straps from the 100 % re-use rules of Art. 29(2) and (3), which cover transport packaging used within one group of companies or within one Member State; it does not exempt them from the 40 % target of Art. 29(1).

Two proposals would change the PPWR, and neither is law. COM(2025) 982 of 10 December 2025 (procedure 2025/0395(COD)) would suspend Art. 45(3) until 1 January 2035; the European Parliament adopted amendments on 20 October 2026 and referred the file back to its ENVI committee, so nothing is suspended and Art. 45(3) applies. COM(2026) 590 of 9 September 2026 (procedure 2026/0265(COD)) would delete Art. 63 on green public procurement. Every mandate, deadline and procedure stage is tracked in PPWR delegated acts, implementing acts and amending proposals.

What Does the PPWR Require? Requirements in the Order of the Regulation

The PPWR sets requirements for every packaging unit in Articles 5 to 12, 24 and 25, from substance limits to recyclability, recycled content, minimisation, labelling and banned formats, plus re-use, collection and recycling targets. The table follows the order of the Regulation and links the PPWR PFAS limits for food-contact packaging, PPWR Article 6 recyclability, the PPWR Article 7 recycled content targets, the PPWR empty space ratio, the PPWR labelling requirements, the PPWR banned packaging formats and deposit return systems under the PPWR.

The PFAS limits measure three different things. Limit (a) counts any single PFAS by targeted analysis, limit (b) the sum of targeted PFAS, and limit (c) total PFAS including polymeric PFAS; a separate total fluorine value of 50 mg/kg only triggers a duty for the chemical supplier to prove, on request, how much fluorine comes from PFAS. The heavy-metal limit of 100 mg/kg is a sum for four metals, not a value per metal, and it applies to every packaging material.

Recycled content figures are often confused. The 25 % recycled content figure for PET beverage bottles from 2025 is a target of the Single-Use Plastics Directive (Art. 6(5) of Directive (EU) 2019/904) as a Member State average, not a PPWR value. Under Art. 7(1) PPWR, recycled content is calculated as an average per manufacturing plant and year, per packaging type and format. Contact-sensitive packaging includes cosmetics packaging, so cosmetic primary plastic packaging falls under the 30 % or 10 % value for 2030, not 35 %.

The Annex V restrictions cover six formats from 1 January 2030, five of them plastic. Point 5, single-use packaging of toiletries for an individual booking in accommodation, covers any material. Member States may keep national restrictions on Annex V points 2 and 3 until 1 January 2030 (Art. 70(4)). Collection and recycling targets bind the Member States. At least 65 % of all packaging waste is recycled by 31 December 2025 and 70 % by 31 December 2030, with 2030 material targets of 55 % for plastic, 30 % for wood, 80 % for ferrous metals, 60 % for aluminium, 75 % for glass and 85 % for paper and cardboard (Art. 52(1)). Eurostat reports an EU recycling rate of 67.0 % in 2024 (env_waspacr), while packaging waste reached 180.99 kg per inhabitant in 2024 against 173.64 kg in the 2018 base year (env_waspac), which is above the base year of the Art. 43(1) prevention targets.

Packaging that meets Articles 5 to 12 may circulate freely: Art. 4(3) adds that national sustainability or information requirements may not conflict with the PPWR or block compliant packaging.

PPWR Obligations by Operator: Who Does What

The PPWR splits duties between six operators: the manufacturer proves conformity, the supplier provides information, the importer and distributor check, the fulfilment service provider keeps packaging compliant, and the producer registers and finances EPR (Art. 15 to 20, 44, 45). Two representatives and the Member States complete the picture.

The table lists each operator with its core duty and article; it links the PPWR EU declaration of conformity from the manufacturer row and the authorised representative for EPR under the PPWR from the EPR representative row.

The two representatives are different roles. The Art. 17 representative acts for the manufacturer on product compliance and is optional; the Art. 45(3) representative fulfils the producer's EPR obligations in a Member State and is mandatory in the two cases named. Manufacturers, Art. 17 representatives and importers hand documents to an authority within 10 days of a reasoned request (Art. 15(10), 17(2)(d), 18(8)), while Art. 19(6) sets no 10-day limit for distributors. Online platforms collect the producer's registration number in the consumer's Member State and a self-certification before they let it offer packaged goods (Art. 45(4)).

Does the PPWR require a certificate or CE marking?

No: PPWR conformity is shown by internal production control (Module A, Annex VII), with no notified body, no CE marking and no "PPWR certificate" (Art. 38, 39). The manufacturer draws up the technical documentation under Annex VII point 2 and an EU declaration of conformity that follows the Annex VIII model of 8 numbered points, one declaration per packaging type, kept up to date. Both are kept for 5 years for single-use packaging and 10 years for reusable packaging after placing on the market (Art. 15(3)). The conformity assessment may be carried out on the manufacturer's behalf (Art. 15(2)), but drawing up the technical documentation cannot be part of an authorised representative's mandate (Art. 17(2)). Analytical results that show the PFAS limits are met belong in the Annex VII technical documentation (Art. 5(6)), so a test report supports the declaration and does not replace it.

How Does the PPWR Apply in the 27 Member States?

The PPWR applies directly in all 27 Member States, but each keeps its own producer register, competent authority, EPR schemes and penalty rules, so a company selling in several states registers in each (Art. 44, 68 PPWR). The table shows PPWR in Germany with the LUCID packaging register, PPWR in France with the French AGEC law and Triman, and the common pattern in the other 25 Member States.

Penalties stay national. Member States lay down penalty rules and notify them by 12 February 2027, administrative fines are mandatory for breaches of Articles 24 to 29, and the Regulation itself sets no fine amount (Art. 68). In Germany, the fines of VerpackDG § 66(2) for breaches of PPWR duties apply from 12 February 2027 (§ 68(17)). Transition rules differ by state. In Germany, producers newly obliged under the VerpackDG had to register in LUCID by 12 September 2026, and existing registrants update their data by 12 November 2026 (VerpackDG § 68(2)). In France, producers not established in France designate a mandataire established in France by written mandate under Code de l'environnement Article L. 541-10-9-1, in force since 10 July 2026. A producer that is unsure which national rule applies to a product should check with the competent authority of the Member State concerned.

How Does the PPWR Relate to Other EU Rules?

The PPWR amends the Single-Use Plastics Directive (EU) 2019/904 and the Market Surveillance Regulation (EU) 2019/1020, and applies the EPR rules of the Waste Framework Directive to packaging. Within its own scope the Single-Use Plastics Directive prevails as the more specific rule, except that Art. 25(1) and (6) PPWR prevail over Art. 4 of that Directive for Annex V point 3 packaging. The changes of Art. 67(5) to Part B of the SUPD Annex, such as expanded polystyrene food and beverage containers and multipack plastic rings, apply from 12 February 2029. Art. 67(2) and (3) also delete the SUPD recycled content rules for beverage bottles from 1 January 2030 or 3 years after the Art. 7(8) implementing act, whichever is later. Art. 66 adds the PPWR as point 75 to Annex I of Regulation (EU) 2019/1020, and Art. 45(1) applies Articles 8 and 8a of Directive 2008/98/EC to packaging EPR.

Four neighbouring EU topics are outside this site's scope: food contact materials rules (covered on foodcontactmaterials.net), the REACH PFAS restriction proposal (pfasregulation.com), green claims and consumer empowerment rules (greenwashingdirective.com) and the Ecodesign for Sustainable Products Regulation with its digital product passport (esprguide.com).

What the Commission guidance and FAQ add

The Commission has published two non-binding documents, Commission Notice C/2026/3084 (OJ C, 10.6.2026) and the Commission's PPWR FAQ, and where either differs from the Regulation, the Regulation wins. The Notice has 33 sections and was presented on 30 March 2026; the FAQ is in its 2nd edition (August 2026). One example shows the gap: the Notice gives 1 January 2030 for the Art. 67(5) changes to the Single-Use Plastics Directive, while Art. 71 sets 12 February 2029. Both documents are compared section by section in PPWR guidance and FAQ.

PPWR questions answered

What counts as composite packaging under the PPWR?

Composite packaging is a unit of two or more different materials that cannot be separated manually (Art. 3(1)(24)). A material that makes up no more than 5 % of the total mass of the packaging unit does not make it composite. The same 5 % limit appears in the reporting rules, where an insignificant material of no more than 5 % of the unit mass may be reported under the main material (Art. 53(4)).

Does the PPWR set rules for plastic carrier bags?

Yes: Art. 34(1) requires Member States to keep annual consumption at or below 40 lightweight plastic carrier bags per person, or the weight equivalent, by 31 December 2025 and each 31 December after. Lightweight bags have a wall thickness below 50 microns and very lightweight bags below 15 microns (Art. 3(1)(56), (57)). Member States may restrict the marketing of bags by derogation from Art. 4 where this is proportionate and non-discriminatory (Art. 34(2)), and may exclude very lightweight bags used for hygiene reasons or for loose food from the 40-bag measure (Art. 34(4)). The Commission reports on the rule by 12 February 2032 (Art. 34(5)).

Is there a PPWR exemption for small businesses?

No general one: the PPWR has no size threshold, and micro-enterprises get only specific reliefs such as the supplier-as-manufacturer rule and the Art. 29(13) re-use exemption. A micro-enterprise has fewer than 10 persons and a turnover or balance sheet total not above EUR 2 million (Recommendation 2003/361/EC, as applicable on 11 February 2025). Where a micro-enterprise brand owner and its supplier are in the same Member State, the supplier is the manufacturer (Art. 3(1)(13)(b)).

The re-use exemption of Art. 29(13) needs both conditions: a micro-enterprise, and not more than 1,000 kg of packaging made available in a Member State per calendar year. Micro-enterprises are also exempt from the reusable offer of Art. 33 (Art. 33(4)), but not from the bring-your-own-container duty of Art. 32 that applies from 12 February 2027. There is no exemption from registration: producers under 10 tonnes per Member State and calendar year file only a lighter report (Art. 44(8)), and the reliefs are listed in PPWR rules for micro-enterprises.

What is the relationship between the PPWR and PFAS?

The PPWR limits PFAS in food-contact packaging to 25 ppb for any single PFAS, 250 ppb for the sum and 50 ppm for total PFAS since 12 August 2026 (Art. 5(5)). The Commission evaluates the limits by 12 August 2030, and the Annex VII technical documentation holds the proof that a food-contact packaging unit stays below all three values (Art. 5(6)). The REACH PFAS restriction proposal is a separate procedure, covered on pfasregulation.com.