PPWR vs the Packaging Directive 94/62/EC: What Changes and What Carries Over

Directive 94/62/EC on packaging and packaging waste, the EU Packaging Directive (PPWD) of 20 December 1994, was repealed with effect from 12 August 2026 by Article 70(1) of the PPWR (Regulation (EU) 2025/40), except four groups of provisions that continue until dates in 2028, 2029 or later. The four groups cover material identification under Art. 8(2), the minimisation essential requirement until 31 December 2029, the 2008 recycling targets with Art. 5(2) and (3) and Art. 6a until 31 December 2028, and Art. 12 reporting provisions until 31 December 2028, with data transmission until 31 December 2029.

The Directive's successor is the EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40 of 19 December 2024, which applies directly in every Member State and has been in force since 11 February 2025.

Several instruments from the Directive era outlast the repeal date. Commission Decision 97/129/EC on material codes is repealed with effect from 12 August 2028, two heavy-metal derogation decisions stay in force until delegated acts repeal them, and references to the Directive in other acts are read through the Annex XIII correlation table (Art. 70(5) PPWR). This page sets out what the Directive regulated, what the PPWR changes topic by topic, what carries over and until when, and what happens to packaging placed on the market before 12 August 2026.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources; every date on this page is checked against EUR-Lex, see our methodology and fact-checking.

The key facts of Directive 94/62/EC and its repeal are summarised in the table below.

What Is Directive 94/62/EC on Packaging and Packaging Waste?

Directive 94/62/EC is the European Parliament and Council Directive of 20 December 1994 on packaging and packaging waste, published in OJ L 365, 31.12.1994, p. 10, and in force since 31 December 1994. Its CELEX number on EUR-Lex is 31994L0062, and the last consolidated version, 01994L0062-20180704, carries every amendment up to Directive (EU) 2018/852.

The Directive regulated packaging through five sets of rules. The essential requirements of Art. 9 and Annex II governed manufacture and composition, reusability and recoverability. Art. 11 set the heavy-metal limit of 100 ppm from 30 June 2001, Art. 8(2) linked material identification to Decision 97/129/EC, Art. 6 set recycling targets, and Art. 12 governed data and its transmission to the Commission.

Which acts amended Directive 94/62/EC?

Seven acts amended Directive 94/62/EC between 2003 and 2018, from Regulation (EC) No 1882/2003 to Directive (EU) 2018/852. The seven amending acts, in date order, are listed below.

• Regulation (EC) No 1882/2003
• Directive 2004/12/EC
• Directive 2005/20/EC
• Regulation (EC) No 219/2009
• Directive 2013/2/EU
• Directive (EU) 2015/720 (OJ L 115, 6.5.2015, p. 11), on lightweight plastic carrier bags
• Directive (EU) 2018/852, which inserted the 2025 and 2030 recycling targets

The consolidated version 01994L0062-20180704 includes all seven amendments, from 2003 to 2018, in one text on EUR-Lex.

Is Directive 94/62/EC Still in Force?

No: Article 70(1) PPWR repealed Directive 94/62/EC with effect from 12 August 2026, the PPWR's general application date, except four groups of provisions that continue for set periods. The repeal did not take effect when the PPWR entered into force on 11 February 2025. Between those two dates the Directive and the Regulation stood side by side, and the Directive still governed packaging requirements.

The four exceptions are points (a) to (d) of Art. 70(1). Art. 8(2) on material identification continues until 30 months after the Art. 12(6) PPWR implementing act enters into force. Art. 9(1) and (2) continue for the minimisation essential requirement until 31 December 2029. Art. 5(2) and (3), Art. 6(1)(d) and (e) and Art. 6a continue until 31 December 2028. Art. 12(3a) to (3c) and (4) continue until 31 December 2028, with data transmission until 31 December 2029. The carry-over table below gives each point with its end date.

How Does a Directive Differ from the PPWR Regulation?

The Packaging Directive set results that each Member State had to write into national law by 30 June 1996, while the PPWR applies directly in all 27 Member States without national transposition. Art. 22(1) of the Directive fixed that deadline, and companies applied the Directive's rules through national packaging acts.

The PPWR is a regulation adopted on the legal basis of Article 114 TFEU, and Art. 71 makes it directly applicable, with no transposition step. Its obligations bind manufacturers, producers, importers and distributors in the text of the Regulation itself, mostly from 12 August 2026. For this pair, the Directive was mandatory for Member States as to the results it set, and the PPWR is mandatory for economic operators directly.

Art. 4 PPWR adds a free-movement rule. Under Art. 4(2), Member States may not prohibit, restrict or impede the placing on the market of packaging that complies with the sustainability, labelling and information requirements of Articles 5 to 12. Art. 4(3) allows national sustainability or additional information requirements only where they do not conflict with the PPWR and are not used to block compliant packaging.

What Changes from the Packaging Directive to the PPWR?

The PPWR replaces the Directive's essential requirements, marking rules and targets with directly applicable requirements, labels and targets, and keeps several values unchanged, such as the 100 mg/kg heavy-metal limit. Design rules move from Art. 9 and Annex II of the Directive to Arts 5 to 11 of the PPWR. Material codes give way to a harmonised material label under Art. 12(1). The recycling targets inserted by Directive (EU) 2018/852 move into Art. 52, and the carrier bag target into Art. 34(1). Each rule that replaced an essential requirement is explained under PPWR requirements for packaging.

The table below compares the Directive and the PPWR topic by topic.

Essential requirements become PPWR sustainability requirements

The Directive's essential requirements in Art. 9 and Annex II covered manufacture and composition, reusability and recoverability; the PPWR replaces them with the sustainability requirements of Arts 5 to 11. Annex II point 1, first indent, states the minimisation requirement: "Packaging shall be so manufactured that the packaging volume and weight be limited to the minimum adequate amount to maintain the necessary level of safety, hygiene and acceptance for the packed product and for the consumer."

The PPWR splits these duties into separate articles, from substances in Art. 5 to reusable packaging in Art. 11. Art. 10 on minimisation applies from 1 January 2030. Art. 11 sets 9 criteria for reusable packaging placed on the market from 11 February 2025, and Commission Notice C/2026/3084 (OJ C, 10.6.2026), point 12, reads them as substantially like the Directive's essential requirements and EN 13429:2004 (non-binding).

Annex II point 3(d) of the Directive defined biodegradable packaging as packaging that decomposes mostly into carbon dioxide, biomass and water, and excluded oxo-degradable plastic packaging. Art. 9(1) PPWR goes further for named formats: by 12 February 2028, permeable tea, coffee and beverage bags, soft single-serve units and sticky labels on fruit and vegetables must be compostable. Which formats must be compostable is covered under PPWR compostable packaging.

The heavy-metal limit carries over into Art. 5(4)

The limit of 100 mg/kg for the sum of lead, cadmium, mercury and hexavalent chromium comes from Article 11 of the Directive, which applied it from 30 June 2001, and Art. 5(4) PPWR keeps it for all packaging. The Directive expressed the value as 100 ppm; Art. 5(4) PPWR states it as 100 mg/kg for the four metals together, not per metal, and the limit is not a rule that starts in 2026. Two derogation decisions adopted under the Directive still apply, as set out in the carry-over section below.

Material codes and the PPWR harmonised label

Art. 8(2) of the Directive provides that packaging indicates the nature of the materials used on the basis of Commission Decision 97/129/EC, and the PPWR replaces this with a harmonised material label under Art. 12(1). Decision 97/129/EC of 28 January 1997 (OJ L 50, 20.2.1997, p. 28) establishes the identification system for packaging materials, with its numbers and abbreviations.

The Art. 12(1) label applies from 12 August 2028 or 24 months after the Art. 12(6) implementing act, whichever is the latest. The Art. 12(6) implementing act is not adopted as of 24 October 2026. The label applies from 12 August 2028 at the earliest; the PPWR labelling requirements page sets out every label.

Recycling targets and carrier bag targets

Art. 52 PPWR keeps the recycling targets that Directive (EU) 2018/852 inserted into the Directive: 65 % of all packaging waste by 31 December 2025 and 70 % by 31 December 2030. The material values sit in Art. 52(1). The postponement mechanism of Art. 6(1a) of the Directive is identical to Art. 52(2) PPWR: for the material targets, a Member State may postpone by up to 5 years, by at most 15 percentage points, with a floor of 30 % for any single target.

Carrier bags follow the same pattern. Art. 4(1a) of the Directive set 90 lightweight bags per person by 31 December 2019 and 40 by 31 December 2025, or no free bags by 31 December 2018. Art. 34(1) PPWR caps annual consumption at 40 lightweight plastic carrier bags per person (or the weight equivalent) by 31 December 2025 and each 31 December thereafter. The very lightweight bag also changed: Art. 3(1d) of the Directive included a hygiene or loose-food purpose, while Art. 3(1)(57) PPWR defines it by thickness only, below 15 microns. Thickness classes and national measures are explained under plastic carrier bags under the PPWR.

Harmonised standards and conformity assessment

Six packaging standards, EN 13427:2004 to EN 13431:2004 and EN 13432:2000, were referenced under the Directive, and as of 24 October 2026 no harmonised standard has been cited under the PPWR. The Commission listed the six in OJ C 44, 19.2.2005. No common specification exists under the PPWR either, and recital 58 PPWR states that EN 13432:2000 cannot be relied upon for a presumption of conformity.

Conformity assessment under the PPWR follows Art. 38 and Annex VII, Module A internal production control. No notified body takes part and the PPWR provides no CE marking. The manufacturer then signs the EU declaration of conformity under Art. 39; the EU declaration of conformity page shows its Annex VIII contents.

What Carries Over from Directive 94/62/EC after 12 August 2026?

Four groups of Directive provisions carry over after 12 August 2026 under Art. 70(1)(a) to (d) PPWR, and Art. 70(2) to (4) keep or end three further rules on separate dates. The four groups and the three further rules give seven end dates in total, one of which depends on an implementing act not yet adopted as of 24 October 2026.

The table below lists each Art. 70 point, the provision or act it concerns and its end date.

Art. 6(1)(d) and (e) of the Directive are the 2008 targets: 55 % to 80 % overall, glass 60 %, paper 60 %, metals 50 %, plastics 22.5 % and wood 15 %.

Minimisation essential requirement and EN 13428:2004 until 31 December 2029

Art. 9(1) and (2) of the Directive continue under Art. 70(1)(b) PPWR for the minimisation essential requirement of Annex II point 1, first indent, until 31 December 2029, together with the presumption of conformity from EN 13428:2004. Manufacturers therefore keep the minimisation wording of Annex II quoted above, and EN 13428:2004 remains the compliance standard for it until that date. Art. 10 PPWR applies from 1 January 2030, the day after the carry-over ends. What replaces the essential requirement is explained under PPWR packaging minimisation.

Material identification under Art. 8(2) and Decision 97/129/EC

Art. 8(2) of the Directive survives until 30 months after the Art. 12(6) PPWR implementing act enters into force, while Decision 97/129/EC is repealed with effect from 12 August 2028, so the two end on different dates. The Art. 12(6) act is not adopted as of 24 October 2026, so the end date of Art. 8(2) is not yet known. Decision 97/129/EC ends on its fixed date of 12 August 2028 in any case.

Commission Notice C/2026/3084, section 13, reads the codes as voluntary: where packaging carries them, they must be the codes of Decision 97/129/EC, and they are no longer allowed after 12 August 2028 (non-binding). How the codes relate to the harmonised pictograms is shown under EU harmonised sorting labels and symbols.

Recycling target, calculation and reporting rules until 2028 and 2029

Art. 70(1)(c) PPWR keeps Art. 5(2) and (3), Art. 6(1)(d) and (e) and Art. 6a of the Directive until 31 December 2028, and Art. 70(1)(d) keeps Art. 12(3a) to (3c) and (4) until the same date, with data transmission to the Commission until 31 December 2029. The data formats still come from Commission Decision 2005/270/EC (OJ L 86, 5.4.2005, p. 6), which the Art. 56(7) PPWR implementing acts are to replace; those acts are not adopted as of 24 October 2026.

The targets that apply to Member States after 12 August 2026 are the Art. 52 values. The current targets are listed under PPWR recycling targets by material.

Does Art. 70(1)(c) keep the 2025 and 2030 recycling targets of the Directive?

No: the text of Art. 70(1)(c) names points (d) and (e) of Art. 6(1), the 2008 targets, and not points (f) to (i), which set the 2025 and 2030 targets now found in Art. 52 PPWR. The English and German texts read the same way, and no corrigendum to the point has been found. The 2025 and 2030 targets therefore apply through Art. 52 PPWR, with the same values of 65 % and 70 %.

Heavy-metal derogations for glass and for plastic crates and pallets

Commission Decisions 2001/171/EC (glass packaging) and 2009/292/EC (plastic crates and pallets), adopted under the Directive, remain in force until repealed by delegated acts under Art. 5(8) PPWR (Art. 70(3)). Decision 2001/171/EC is published in OJ L 62, 2.3.2001, p. 20, and Decision 2009/292/EC in OJ L 79, 25.3.2009, p. 44. Both establish the conditions for a derogation for the packaging concerned in relation to the heavy-metal concentration levels. The derogation conditions are set out under PPWR substances of concern.

National restrictions on Annex V points 2 and 3 until 1 January 2030

Member States may keep national rules restricting the packaging formats and uses of Annex V points 2 and 3 until 1 January 2030 under Art. 70(4) PPWR, and Art. 4(3) does not apply to those rules until then. For that transition period, the Art. 4(3) test for national sustainability requirements does not reach these rules.

The national rules end on that date. From 1 January 2030 the six Annex V restrictions apply in every Member State under Art. 25(1) PPWR.

How Are References to Directive 94/62/EC Read under the PPWR?

References to Directive 94/62/EC in other EU or national acts are read as references to the PPWR in line with the correlation table in Annex XIII (Art. 70(5) PPWR). The rule covers every act that cites the Directive, so a reference to the Directive's articles leads to the corresponding PPWR provisions through Annex XIII.

The Single-Use Plastics Directive shows how the PPWR handles such references directly. Art. 67(1)(a) PPWR replaces Art. 2(2) of Directive (EU) 2019/904, which now states that the SUPD prevails over Directives 94/62/EC and 2008/98/EC "unless provided otherwise by Regulation (EU) 2025/40". The SUPD rule thus names the repealed Directive and the PPWR side by side.

What Happens to Packaging Placed on the Market under the Directive?

Packaging placed on the market before 12 August 2026 may stay on the market, according to the Commission's non-binding reading in Notice C/2026/3084 and its PPWR FAQ. The Commission's PPWR FAQ (non-binding), section X, and the Notice describe three cases, listed below.

• Packaging placed on the market before 12 August 2026 may remain on the market.
• Packaging produced but not yet placed on the market by that date need not be destroyed, but it must comply with the PPWR when it is placed on the market.
• Reusable packaging placed on the market before 11 February 2025 needs no bringing into conformity, withdrawal or recall (Art. 15(9) PPWR).

Labelling has its own sell-off rule. Art. 12(12) PPWR sets a sell-off period of 3 years from the date each labelling requirement applies. A question about one specific product or batch gets the rule above; check with the competent authority. What else applies from the general application date is covered under PPWR since 12 August 2026.

How Does the Directive's Repeal Fit into the PPWR Legal Text and Timeline?

Article 70 is the repeal and transitional provision of the PPWR in Chapter XIII, and it dates every step from the Directive to the Regulation. Art. 71 sets entry into force on 11 February 2025 and general application on 12 August 2026. Article 70 and Annex XIII can be read in context in the PPWR legal text.

The PPWR started as Commission proposal COM(2022) 677 of 30 November 2022, procedure 2022/0396(COD).

The carry-over dates run from 12 August 2028 for Decision 97/129/EC to 31 December 2028, 31 December 2029 and 1 January 2030. The carry-over dates sit next to every other date in the PPWR timeline.

Does the PPWR repeal the Single-Use Plastics Directive too?

No: the PPWR amends Directive (EU) 2019/904 through Art. 67 but does not repeal it, unlike Directive 94/62/EC. The SUPD stays in force and applies through national transposition. The overlap is explained under PPWR vs the Single-Use Plastics Directive.

Do national packaging laws based on the Directive still apply?

National packaging laws adopted under the Directive apply only as far as they are compatible with the PPWR, which since 12 August 2026 applies directly and bars national rules that block compliant packaging. Art. 4(2) and (3) PPWR set that limit. Germany shows the pattern: the VerpackDG applies from 12 August 2026 and replaced the Packaging Act (VerpackG).

This page covers EU Member States only. For a specific national rule, check with the competent authority. Registers, deposit systems and authorities are compared under national packaging laws in the 27 Member States.