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PPWR Requirements for Packaging: Substances, Recyclability, Recycled Content, Minimisation, Labelling and Bans, 2026 to 2040

PPWR packaging requirements by article: PFAS limits since 12 August 2026, recyclability grades, recycled content, empty space, labels and the 2030 bans.

Last updated 24 October 2026 · By the PackagingRegulation.org Editorial Team · How we fact-check · Print this page

The PPWR requirements for packaging are the product rules of Regulation (EU) 2025/40 on substances, recyclability, recycled content, bio-based and compostable packaging, minimisation, reusability, labelling and banned formats, applying in stages from 12 August 2026 to 1 January 2040. The first stage already applies: the PFAS limits for food-contact packaging, the 100 mg/kg heavy-metal limit and the reusability criteria are enforceable since 12 August 2026, while the recycled content targets of 1 January 2040 close the sequence.

These requirements are part of the PPWR, the EU Packaging and Packaging Waste Regulation, which also sets reuse, EPR and waste rules. The Regulation (CELEX 32025R0040, OJ L, 2025/40, 22.1.2025) entered into force on 11 February 2025 and applies generally from 12 August 2026 (Art. 71). Four of its main requirement dates still depend on Commission acts that are not adopted as of 24 October 2026.

This page lists every requirement with its article and date, then covers conformity, the dates that move with a Commission act, the exemptions by granting article and the Article 14 rules on environmental claims.

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 Are the PPWR Sustainability Requirements for Packaging?

The PPWR sustainability requirements are Articles 5 to 11 of Chapter II of Regulation (EU) 2025/40, which set rules on substances, recyclability, recycled content, bio-based feedstock, compostability, minimisation and reusability for all packaging placed on the EU market. Chapter II holds seven requirement articles, Art. 5 to 11, and Chapter III adds three more, Art. 12 to 14. Two further chapters complete the product rules, so the PPWR packaging requirements sit in three places, listed below.

  • Chapter II, sustainability requirements: Art. 5 substances in packaging, Art. 6 recyclable packaging, Art. 7 minimum recycled content in plastic packaging, Art. 8 biobased feedstock in plastic packaging, Art. 9 compostable packaging, Art. 10 packaging minimisation and Art. 11 reusable packaging.
  • Chapter III, labelling and claims: Art. 12 labelling of packaging, Art. 13 labelling of waste receptacles and Art. 14 environmental claims.
  • Chapter V, Articles 24 to 33: Art. 24 on excessive packaging, with the empty space ratio, and Art. 25 on the restricted formats listed in Annex V; carrier bags follow separately in Art. 34 of Chapter VI.

Who must meet these rules? They apply to packaging regardless of company size (Art. 2(1) PPWR), so a small firm placing packaging on the EU market meets the same limits and targets as a large one. Which packaging and which businesses fall under the Regulation is set out in PPWR scope.

Do the PPWR packaging requirements apply to packaging already on the market?

No: packaging placed on the market before 12 August 2026 may stay on the market, and there is no sell-off period for the PFAS limits that apply from that date. Commission Notice C/2026/3084, section 5, explains when packaging counts as placed: sales and grouped packaging when filled, transport and service packaging when empty, and imports at release for free circulation. Reusable packaging is treated differently: the Art. 11 criteria cover reusable packaging placed on the market from 11 February 2025, and reusable packaging placed before that date needs no corrective action (Art. 15(9) PPWR).

PPWR Packaging Requirements in the Order of the Regulation

The PPWR packaging requirements follow the order of the Regulation, from substances in Article 5 to the Annex V format restrictions of Article 25, and each one applies from its own date. The table covers PPWR Article 5 substances of concern, the PPWR PFAS limits for food-contact packaging, PPWR Article 6 recyclability, PPWR Article 7 recycled content targets, bio-based plastic packaging under the PPWR, PPWR compostable packaging, PPWR packaging minimisation, the PPWR empty space ratio, reusable packaging under the PPWR, the PPWR labelling requirements and the PPWR banned packaging formats.

Requirement Article What it requires Applies Detail page
Substances and heavy metals Art. 5(1) to (4) PPWR Minimise substances of concern (definition of Art. 2(27) Regulation (EU) 2024/1781, no numeric limit); sum of lead, cadmium, mercury and hexavalent chromium not above 100 mg/kg in all packaging, carried over from Art. 11 Directive 94/62/EC 12 August 2026 PPWR Article 5 substances of concern
PFAS Art. 5(5) PPWR Food-contact packaging only: 25 ppb any targeted PFAS, 250 ppb sum of targeted PFAS, 50 ppm total PFAS including polymeric PFAS 12 August 2026 PPWR PFAS limits for food-contact packaging
Recyclability Art. 6 PPWR Performance grade A (at least 95 %), B (at least 80 %) or C (at least 70 %) under Annex II Table 3 Grades A to C from 1 January 2030 or 24 months after the Art. 6(4) delegated acts, whichever is later; only A or B from 1 January 2038 PPWR Article 6 recyclability
Recycled content (plastic) Art. 7 PPWR 30 % contact-sensitive PET, 10 % contact-sensitive non-PET, 30 % single-use plastic beverage bottles, 35 % other plastic packaging From 1 January 2030 or 3 years after the Art. 7(8) implementing act, whichever is later; 50 %, 25 %, 65 % and 65 % from 1 January 2040 PPWR Article 7 recycled content targets
Bio-based feedstock Art. 8 PPWR No target and no operator obligation; bio-based plastic does not count towards Art. 7; Commission review Review by 12 February 2028; consultation 21 October 2026 to 13 January 2027 bio-based plastic packaging under the PPWR
Compostable Art. 9 PPWR Permeable tea, coffee and beverage bags, soft single-serve units and fruit and vegetable sticky labels compostable; machine capsules only where a Member State requires it, never metal capsules; other packaging designed for material recycling 12 February 2028 PPWR compostable packaging
Minimisation Art. 10 PPWR Weight and volume reduced to the minimum necessary; no double walls, false bottoms or unnecessary layers 1 January 2030; EN 13428:2004 remains the compliance standard until 31 December 2029 PPWR packaging minimisation
Empty space Art. 24 PPWR Empty space ratio of at most 50 % for grouped, transport and e-commerce packaging (Art. 24(1)); sales packaging empty space reduced to the minimum necessary, no numeric ratio (Art. 24(4)) 50 % ratio from 1 January 2030 or 3 years after the Art. 24(2) implementing acts, whichever is later; sales packaging by 12 February 2028 PPWR empty space ratio
Reusable Art. 11 PPWR 9 cumulative criteria, points (a) to (i), for packaging placed on the market from 11 February 2025 Enforceable from 12 August 2026 reusable packaging under the PPWR
Labelling Art. 12, 13 PPWR Harmonised material label (Art. 12(1)); reuse label (Art. 12(2)); waste receptacle labels, a Member State duty (Art. 13(1)) Material label 12 August 2028 at the earliest; reuse label from 12 February 2029 or 30 months after the Art. 12(6) act, whichever is the latest PPWR labelling requirements
Banned formats Art. 25, Annex V PPWR 6 restricted formats; points 1 to 4 and 6 cover plastic, point 5 covers accommodation toiletries in any material 1 January 2030 PPWR banned packaging formats

How Is Conformity with the PPWR Requirements Shown?

Conformity with the PPWR requirements of Articles 5 to 12 is shown by the manufacturer through internal production control under Annex VII Module A (Art. 38 PPWR), without a notified body and without CE marking. The route covers every requirement laid down in or pursuant to Articles 5 to 12, and no "PPWR certificate" exists. The assessment may be carried out on the manufacturer's behalf (Art. 15(2) PPWR), but the declaration stays the manufacturer's own.

The manufacturer draws up the Annex VII technical documentation and keeps it, with the declaration, for 5 years for single-use packaging and 10 years for reusable packaging (Art. 15(3) PPWR). Once the file is complete, the manufacturer signs the PPWR EU declaration of conformity under Art. 39 on the Annex VIII model.

What happens when a requirement is missed? Article 62(1) of the PPWR lists formal non-compliance: point (g) covers Art. 24 and 25, point (m) covers Art. 6 and point (n) covers Art. 7. Formal non-compliance under points (g) to (n) that persists leads to Art. 68 penalties.

Penalties stay national, and the PPWR itself sets no fine amount (Art. 68). Member States lay down and notify their rules by 12 February 2027, see PPWR penalties and market surveillance.

Which PPWR Requirement Dates Depend on Commission Acts?

Four of the main PPWR requirement dates move with a Commission act: the recyclability grades, the 2030 recycled content targets, the 50 % empty space ratio and the harmonised labels apply from a fixed date or a period after the act, whichever is later.

The recycled content targets show the mechanism most clearly: the 2030 percentages of Art. 7(1) apply from 1 January 2030 or 3 years after the Art. 7(8) implementing act, whose legal deadline is 31 December 2026. That second wave of requirements is explained in PPWR 2030 deadlines.

As of 24 October 2026, the only adopted PPWR delegated act is Delegated Decision (EU) 2026/429, and no PPWR implementing act has been adopted. Every trigger act in the table below is therefore still outstanding.

Each trigger act and its legal deadline is tracked in PPWR delegated acts and implementing acts.

Requirement Fixed date Trigger act and legal deadline Status on 24 October 2026 Rule
Recyclability grades A to C 1 January 2030 Art. 6(4) delegated acts, due 1 January 2028 Not adopted 24 months after the acts, whichever is later (Art. 6(2)(a))
Only grades A or B 1 January 2038 None Fixed in the Regulation Fixed date (Art. 6(3))
Recycled content 2030 1 January 2030 Art. 7(8) implementing act, due 31 December 2026 Not adopted 3 years after the act, whichever is later (Art. 7(1))
Empty space ratio 50 % 1 January 2030 Art. 24(2) implementing acts, due 12 February 2028 Not adopted 3 years after the acts, whichever is later (Art. 24(1))
Harmonised material label 12 August 2028 Art. 12(6) implementing act Not adopted 24 months after the act, whichever is the latest; 12 August 2028 at the earliest (Art. 12(1))
Reuse label 12 February 2029 Art. 12(6) implementing act Not adopted 30 months after the act, whichever is the latest (Art. 12(2))
Waste receptacle labels (Member States) 12 August 2028 Art. 13(2) acts Not adopted 30 months from adoption, whichever is the latest (Art. 13(1))
Minimum rotations for reusable packaging None Art. 11(2) delegated act, due 12 February 2027 Not adopted Sets the minimum number of rotations
Label sell-off None Linked to each labelling date Law 3 years from the date the relevant labelling requirement applies (Art. 12(12))

Every fixed and conditional date of the Regulation, from entry into force to 2040, sits in one table in the PPWR timeline.

Which Exemptions Apply to the PPWR Packaging Requirements?

PPWR exemptions are granted article by article, not for whole sectors or company sizes: each one lifts a specific requirement, such as recyclability under Art. 6(11) or recycled content under Art. 7(4) and 7(5). The table maps each exemption to its article and to the requirement it lifts.

Exemption Article Requirement lifted Condition
Dangerous goods Art. 2(2), 6(11)(f), 7(4)(f) PPWR Conflicting PPWR rules; recyclability; recycled content Directive 2008/68/EC prevails in a conflict; packaging for the transport of dangerous goods
Glass; plastic crates and pallets Art. 70(3) PPWR 100 mg/kg heavy-metal limit Decisions 2001/171/EC (glass) and 2009/292/EC (plastic crates and pallets) stay in force until repealed under Art. 5(8)
Innovative packaging Art. 6(10), 40(1) PPWR Recyclability From 1 January 2030, up to 5 years from the end of the calendar year of placing on the market, after notification to the competent authority
Medical, infant-food and listed-material sales packaging Art. 6(11)(a) to (g) PPWR Recyclability Medicinal, medical-device, IVD and infant-food packaging, dangerous goods, and sales packaging of lightweight wood, cork, textile, rubber, ceramic, porcelain or wax (fee modulation still applies to point (g)); review by 1 January 2035 (Art. 6(12))
Sector exceptions Art. 7(4)(a) to (h) PPWR Recycled content 8 points, including (e) compostable plastic packaging and (f) dangerous goods
Health risk; small plastic parts Art. 7(5) PPWR Recycled content Food-contact plastic where recycled content threatens health and compliance with Regulation (EC) No 1935/2004; plastic parts below 5 % of the total weight of the packaging unit
Protected designs; geographical indications Art. 10(2) PPWR Minimisation Designs or shape trademarks protected before 11 February 2025 where compliance would alter them; products with an EU geographical indication or quality scheme
E-commerce use; re-use systems Art. 24(5) PPWR 50 % empty space ratio Sales packaging used as e-commerce packaging; reusable packaging in a re-use system; both still subject to Art. 10
Medicinal and medical-device labels Art. 12(11) PPWR Art. 12 labelling Immediate and outer packaging where there is no space or labelling could jeopardise safe use
Micro-enterprises Art. 25(4) PPWR Annex V point 3 only Member State option

The PPWR has no general exemption for small companies. Where the brand owner is a micro-enterprise, defined in Recommendation 2003/361/EC as fewer than 10 persons and a turnover or balance sheet total not above EUR 2 million, the supplier becomes the manufacturer (Art. 3(1)(13)(b)). The supplier-as-manufacturer shift is explained in PPWR rules for micro-enterprises.

The only format derogation for micro-enterprises is the Member State option of Art. 25(4) for Annex V point 3, and it applies only where national law uses it. Whether a specific product falls under an exemption is a case-by-case question: check with the competent authority of the Member State concerned.

Medicinal products and medical devices are exempted under three articles: Art. 6(11), 7(4) and 12(11) PPWR. Sector detail is in PPWR for pharmaceuticals and medical devices.

What Does Article 14 PPWR Allow in Environmental Claims on Packaging?

Article 14 of the PPWR allows environmental claims on packaging properties only where they go beyond the minimum requirements of the Regulation and state whether they relate to the packaging unit, a part of it or all packaging the operator places on the market. The term "environmental claim" takes the meaning of Article 2, point (o), of Directive 2005/29/EC. The two conditions of Art. 14 PPWR are listed below.

  1. Claims concern only packaging properties that exceed the applicable minimum requirements of the Regulation.
  2. Claims specify whether they relate to the packaging unit, a part of it or all packaging placed on the market by the operator.

Compliance with both conditions is demonstrated in the Annex VII technical documentation, the file explained in PPWR technical documentation and conformity assessment. General claims law under Directive 2005/29/EC is covered on greenwashingdirective.com.

How Do the PPWR Requirements Connect to Reuse Targets, EPR and Waste Rules?

The PPWR requirements set how packaging is designed and labelled, while the reuse targets, EPR and the waste rules set who reuses, finances and collects it; recyclability grades, for example, will modulate EPR fees under Art. 6(8) PPWR. Fee modulation becomes mandatory 18 months after the entry into force of both the Art. 6(4) delegated acts and the Art. 6(5) implementing acts. The table links the PPWR legal text, PPWR vs the Packaging Directive 94/62/EC, the PPWR reuse targets, EU packaging EPR under the PPWR, EU packaging waste, PPWR compliance, PPWR in the 27 member states and PPWR by packaging material. This page covers the EU rule only.

Section Connection to the requirements Page
Legal text Articles 5 to 14, 24 and 25 and Annexes II, V, VII and VIII PPWR legal text
Packaging Directive Directive 94/62/EC repealed with effect from 12 August 2026; carry-overs in Art. 70(1)(a) to (d), including EN 13428:2004 for minimisation until 31 December 2029 PPWR vs the Packaging Directive 94/62/EC
Reuse targets Art. 11 criteria are the basis of the reuse targets PPWR reuse targets
EPR Fee modulation by recyclability grade under Art. 6(8) EU packaging EPR under the PPWR
Packaging waste Collection and recycling of the packaging the requirements shape EU packaging waste
Compliance Obligations of manufacturers, importers and distributors PPWR compliance
Member states National enforcement and penalty rules PPWR in the 27 member states
Materials Requirements per material, from plastic to glass PPWR by packaging material

What the Commission guidance says about the PPWR requirements

Commission Notice C/2026/3084 (OJ C, 10.6.2026) and the Commission's PPWR FAQ explain how the Commission reads the requirements, but both are non-binding and the Regulation prevails where they differ. The Notice confirms in section 5 that there is no stock-exhaustion period, and the FAQ, 2nd edition (August 2026), is equally non-binding. Both documents are compared in PPWR guidance and FAQ. Three neighbouring topics sit outside the PPWR: the REACH PFAS restriction (pfasregulation.com), food contact materials (foodcontactmaterials.net) and the ESPR, whose substance of concern definition Art. 5 applies (esprguide.com).

PPWR requirements questions answered

What are the 5 requirements of packaging under the PPWR?

The PPWR does not list five packaging requirements: Chapter II sets seven sustainability articles (Art. 5 to 11) and Chapter III sets three labelling and claims articles (Art. 12 to 14). Articles 24 and 25 add the empty space ratio and the Annex V format restrictions.

Which PPWR requirements apply since 12 August 2026?

Five requirements apply since 12 August 2026: the Art. 5(5) PFAS limits for food-contact packaging, the 100 mg/kg heavy-metal limit of Art. 5(4), the Art. 5(1) duty to minimise substances of concern, the Art. 11 reusability criteria and the Art. 14 claims conditions. What else applies from that date is listed in PPWR since 12 August 2026.

Do the PPWR requirements apply to every packaging material?

Yes: the requirements apply to all packaging regardless of material (Art. 2(1) PPWR), but recycled content (Art. 7) covers plastic packaging only, and Annex V point 5 restricts hotel toiletry packaging in any material. Annex V points 1 to 4 and 6 concern plastic packaging only.

Sources