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Regulation (EU) 2025/40 covers the entire life-cycle of packaging, design, substances of concern, recyclability, recycled content, reuse and waste management, in a single directly applicable Regulation that replaces three decades of fragmented national transpositions of Directive 94/62/EC.
What the PPWR is, why it exists, and how it is structured
The Packaging and Packaging Waste Regulation is the EU's first Regulation to cover the entire life-cycle of packaging, from design through to collection, sorting, recycling and reuse. It replaces Directive 94/62/EC, which had governed EU packaging policy for three decades, with a single directly applicable Regulation designed to end the fragmentation caused by 27 different national transpositions.
Packaging represents roughly 40% of the plastics and 50% of the paper used in the Union, and around 36% of municipal solid waste, so the Regulation treats packaging design, substances of concern, recyclability, recycled content, reuse and waste management as one connected policy problem rather than 27 separate national rulebooks.
The PPWR sits inside the European Green Deal and the Circular Economy Action Plan (CEAP), which committed to making all packaging reusable or recyclable in an economically viable way by 2030. The Commission's 2018 European Strategy for Plastics in a Circular Economy first flagged packaging design as a lever; the 2020 CEAP then committed to reinforcing packaging essential requirements, and the European Parliament's February 2021 resolution called for a full legislative revision rather than another update to the Directive.
The Commission responded with proposal COM(2022) 677 final on 30 November 2022. The European Parliament reached its position on 24 April 2024, the Council took its decision on 16 December 2024, and the Regulation was signed on 19 December 2024, published in the Official Journal on 22 January 2025, and entered into force on 11 February 2025. It becomes generally applicable on 12 August 2026.
The PPWR repeals Directive 94/62/EC from 12 August 2026, with several article-specific transitional carve-outs running to 31 December 2028 and 31 December 2029 while implementing acts catch up.
It amends Regulation (EU) 2019/1020 on market surveillance, adding packaging to its Annex I scope, and amends Directive (EU) 2019/904, the Single-Use Plastics Directive, clarifying that the SUP Directive prevails as lex specialis over the PPWR for the items it covers, while adding shrink wrap for luggage, protective plastic chips and multi-pack plastic rings to the single-use plastics restriction list.
The PPWR complements the Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781), which does not treat packaging as its own product category, and interacts closely with the Waste Framework Directive, the Single-Use Plastics Directive and the Market Surveillance Regulation. It combines binding EU-wide design and substance rules with waste-management targets on Member States and operational obligations directly on economic operators.
The five building blocks of Regulation (EU) 2025/40
The key figures from Regulation (EU) 2025/40
Subject matter, scope, the 71 definitions and free movement
Article 1 sets the subject matter: requirements for the entire life-cycle of packaging on environmental sustainability and labelling, plus extended producer responsibility, waste prevention, and the collection and treatment, including recycling, of packaging waste. Article 2 gives the Regulation the widest possible scope: it applies to all packaging regardless of the material used, whatever sector generates it, industry, retail, offices, services or households, and to all packaging waste. Directive 2008/68/EC on the transport of dangerous goods prevails in the event of a conflict.
Article 3 contains 71 numbered definitions, the backbone of the whole Regulation. Packaging is defined broadly enough to include service packaging, disposable dispensing items, and tea/coffee bags and single-serve system units, both explicitly brought inside the definition of packaging because of their disposal behaviour, even though they are consumed with the product. Sales packaging, grouped packaging and transport packaging replace the old primary/secondary/tertiary terminology.
The producer is defined around who first makes packaging or packaged products available on the territory of a given Member State: a company importing a packaged product from another Member State or a third country and supplying it locally becomes the producer for extended-producer-responsibility purposes. Composite packaging is two or more materials that cannot be separated manually, unless one material is an insignificant part, no more than 5% of total mass.
Member States cannot 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, and may not maintain additional national sustainability or information requirements that conflict with the Regulation.
Substances of concern, recyclability grades, recycled content, compostability, minimisation and reuse conditions
The sum of the concentrations of lead, cadmium, mercury and hexavalent chromium present in packaging or packaging components must not exceed 100 mg/kg, continuing the limit already established under Directive 94/62/EC, with the existing derogations for glass and for plastic crates and pallets kept in force until replaced by delegated acts.
By 31 December 2026 the Commission, assisted by ECHA, must report on substances of concern in packaging generally, and by 12 August 2030 it must evaluate whether the PFAS restriction needs amending or repealing to avoid overlap with REACH, the Food Contact Materials Regulation or the POPs Regulation.
From 12 August 2026, food-contact packaging may not be placed on the market if it contains per- and polyfluoroalkyl substances (PFAS) at or above:
All packaging placed on the market must be recyclable. Recyclability is expressed through recyclability performance grades A, B or C, combining a design-for-recycling assessment and a recycled-at-scale assessment. The design-for-recycling condition applies from 1 January 2030, or 24 months after the relevant delegated acts enter into force, whichever is later; the recycled-at-scale condition applies from 1 January 2035.
From 1 January 2030, packaging that does not reach at least Grade C cannot be placed on the market at all. From 1 January 2038, Grade C packaging is banned outright, only Grade A or B packaging may still be placed on the market. Innovative packaging can be placed on the market for up to five years without meeting the criteria, subject to notification. Exemptions apply to immediate/outer medicinal packaging, contact-sensitive medical-device packaging, dangerous-goods transport packaging, and certain lightweight-material sales packaging such as wood, cork, textile, rubber, ceramic, porcelain and wax.
By 1 January 2030, or three years after the relevant implementing act, the plastic part of packaging must contain a minimum percentage of post-consumer recycled content, calculated as an average per manufacturing plant and year:
By 1 January 2040, those targets rise to 50%, 25%, 65% and 65% respectively. Exemptions apply to immediate/outer medicinal and veterinary packaging, contact-sensitive medical-device packaging, compostable plastic packaging, dangerous-goods transport packaging, infant/young-children food packaging, and plastic parts under 5% of a packaging unit's total weight.
By 12 February 2028 the Commission must review the technological state of biobased plastic packaging and, where appropriate, propose sustainability requirements or targets. By the same date, permeable tea/coffee/beverage bags, non-permeable single-serve system units, and sticky labels affixed to fruit and vegetables must be compostable in industrially controlled conditions, and home-compostable where a Member State requires it. All other packaging, including packaging made of biodegradable plastic polymers, must instead be designed for material recycling by 12 February 2028.
By 1 January 2030, manufacturers and importers must ensure packaging weight and volume are reduced to the minimum necessary for functionality; packaging with features that only increase perceived volume, double walls, false bottoms, unnecessary layers, cannot be placed on the market, with narrow exceptions for protected trademarks and geographical indications.
Packaging placed on the market from 11 February 2025 is only reusable if it meets nine cumulative conditions covering multiple rotations, safety and hygiene, ability to be emptied and reloaded without damage, and reconditioning capability, and it must also independently satisfy the Article 6 recyclability requirements. By 12 February 2027 the Commission must adopt a delegated act establishing minimum rotation numbers for the most common reusable packaging formats.
Harmonised pictogram labels, digital marking and environmental claims
From 12 August 2028, or 24 months from the relevant implementing acts, whichever is later, packaging must carry a harmonised pictogram-based label showing material composition to help consumers sort waste correctly; compostable packaging must be labelled to make clear it is not suitable for home composting and must not be discarded in nature. Packaging containing substances of concern must be marked through a standardised, open digital-marking technology.
Reusable packaging placed on the market from 12 February 2029 must carry a label plus a QR code or equivalent digital data carrier giving information on the reuse system, collection points, and trip and rotation tracking. Recycled-content and biobased-content labelling remain voluntary, but must follow the harmonised format if used. The Commission must adopt the implementing acts establishing the harmonised label formats and digital-marking methodology by 12 August 2026.
By 12 August 2028, or 30 months from the relevant implementing acts, Member States must ensure harmonised labels enabling separate collection are affixed to waste receptacles, matching the packaging labels established under Article 12.
Voluntary environmental claims about packaging properties covered by this Regulation, recyclability, recycled content, reusability, may only be made where the packaging exceeds the applicable minimum legal requirement, and must specify whether the claim covers the whole packaging unit, part of it, or all packaging placed on the market by that operator.
Parallel due-diligence duties for every link in the supply chain
Manufacturers must run the Article 38 conformity assessment, draw up the technical documentation and EU declaration of conformity, and keep records for 5 years, single-use packaging, or 10 years, reusable packaging. Suppliers must give manufacturers everything needed to demonstrate conformity. Authorised representatives can be appointed by written mandate.
Importers must verify the manufacturer's conformity assessment before placing packaging on the market and must not do so if they suspect non-compliance. Distributors must verify producer registration and labelling before making packaging available. Fulfilment service providers must not let warehousing or dispatch conditions jeopardise compliance.
An importer or distributor that private-labels or modifies packaging assumes full manufacturer obligations (Art 21). Economic operators must identify their supply-chain counterparties on request, for 5 or 10 years depending on packaging type (Art 22). Packaging waste management operators must report annually to competent authorities and to producers or producer responsibility organisations (Art 23).
Empty space, restricted formats, reuse and refill targets, and the take-away sector
By 1 January 2030, or three years from the relevant implementing act, the maximum empty-space ratio for grouped, transport and e-commerce packaging is 50%. By 12 February 2028, sales packaging must also have its empty space minimised to what packaging functionality requires. E-commerce operators using sales packaging as e-commerce packaging, and reusable packaging within a reuse system, are exempt from the 50% ceiling.
From 1 January 2030, economic operators may not place on the market packaging in six formats and uses listed in Annex V:
A narrow micro-enterprise derogation applies where reuse infrastructure is not technically accessible. Explanatory guidelines, with a non-exhaustive exempted-produce list, are due by 12 February 2027.
Economic operators placing reusable packaging on a Member State's market for the first time must ensure a reuse system is in place there, and must participate in one or more reuse systems, reconditioning packaging before it is reused (Arts 26-27). Operators offering refill must inform end users of eligible container types and hygiene standards; from 1 January 2030, final distributors with a sales area over 400 square metres must endeavour to dedicate 10% of that area to refill stations for food and non-food products (Art 28).
From 1 January 2030, reuse targets apply: 40% of transport packaging, rising to a 70% endeavour-target by 2040; 10% of non-cardboard grouped packaging, rising to 25% by 2040; and 10% of alcoholic and non-alcoholic beverages in reusable sales packaging, rising to 40% by 2040 (Art 29). Micro-enterprises are exempt, and distributor pools are capped at 40% market share and 5 members. The calculation methodology is due 30 June 2027 (Art 30); annual reporting starts in 2030, alongside a new European observatory on reuse (Art 31).
By 12 February 2027, HORECA final distributors selling hot or cold beverages or ready-prepared food in take-away packaging must let consumers bring their own container, at no extra cost. By 12 February 2028, they must also offer a reusable-packaging option within a reuse system, again at no extra cost; micro-enterprises are exempt. From 2030, final distributors must endeavour to offer 10% of take-away products in reusable format.
A sustained reduction target, in force since the end of 2025
Member States must achieve a sustained reduction in lightweight plastic carrier bag consumption, defined as no more than 40 lightweight plastic carrier bags per capita per year by 31 December 2025, and every year thereafter. Member States may exclude very lightweight bags needed for hygiene or to prevent food wastage for loose products. By 12 February 2032, the Commission must report on whether other packaging materials are substituting for plastic bags with worse environmental impact, and propose reduction measures if so.
Manufacturer self-assessment on the New Legislative Framework pattern, without CE marking
Test, measurement and calculation methods must be reliable, accurate and reproducible (Art 35). Harmonised standards and Commission common specifications each give rise to a presumption of conformity (Arts 36-37). Conformity assessment (Art 38) uses the internal-production-control module, conformity assessment is the manufacturer's sole responsibility, mirroring the New Legislative Framework modules from Decision 768/2008/EC. The manufacturer draws up a single EU declaration of conformity (Art 39), which can bundle declarations required under other Union acts.
Notably, CE marking does not apply to PPWR compliance. CE marking on packaging, where it appears, only reflects compliance of the packaged product with other Union product law, to avoid consumer confusion between packaging conformity and product conformity.
EPR, fee modulation, deposit-and-return systems, and recycling targets by material
Each Member State must designate one or more competent authorities and notify the Commission by 12 July 2025 (Art 40). Each Member State must reduce packaging waste generated per capita, against a 2018 baseline, by at least 5% by 2030, 10% by 2035 and 15% by 2040 (Art 43).
Each Member State must establish a national producer register within 18 months of the first relevant implementing act, due by 12 February 2026; producers must register in every Member State where they first make packaging available, with a simplified reporting track for producers placing under 10 tonnes per year. Registration must be granted within 12 weeks (Art 44).
Producers bear extended producer responsibility under Articles 8/8a of Directive 2008/98/EC; the EPR fee must also cover labelling waste receptacles and compositional waste surveys, a form of fee modulation rewarding better design (Art 45). Distance-selling producers must appoint an authorised representative for EPR. Producers may discharge EPR collectively through a producer responsibility organisation, authorised within 18 weeks, which must post a financial guarantee against non-compliance or insolvency (Arts 46-47).
Member States must ensure systems for the return and separate collection of all packaging waste; packaging meeting the design-for-recycling criteria must be collected for recycling, and incineration or landfill of such packaging is prohibited, subject to a narrow exception. Mandatory collection objectives must be set by 1 January 2029.
By 1 January 2029, Member States must ensure at least 90% by weight annual separate collection of single-use plastic beverage bottles and single-use metal beverage containers up to 3 litres, achieved through deposit-and-return systems with a deposit charged at the point of sale. Wine and aromatised-wine products, spirit drinks, and milk and milk products are excluded from the mandatory scope.
A Member State may be exempted from establishing a DRS if it already achieves an 80% separate collection rate by 2026 and, by 1 January 2028, notifies the Commission with a credible implementation plan showing how it will still reach 90%. If separate collection then falls and stays below 90% for three consecutive years, the exemption lapses and a DRS must be established within roughly two years.
Member States must achieve, across their whole territory:
A Member State may postpone the 2030 material-specific deadlines by up to five years under strict conditions, capped at a 15 percentage-point derogation, with floors the recycling rate must never drop below regardless of postponement. Member States must report recycling, plastic-carrier-bag consumption and DRS separate-collection data annually (Art 56), and establish harmonised, publicly accessible, machine-readable packaging databases (Art 57).
Market surveillance escalation and border data interconnection
Market surveillance authorities that suspect packaging presents a risk to the environment or human health must evaluate it and require corrective action; unresolved objections escalate to a Union safeguard procedure with an implementing act determining whether the national measure was justified. Article 60 covers compliant packaging that nonetheless presents a risk. Article 61 sets up an automated data interconnection between the EU's product market-surveillance information system and customs risk-management systems for packaging entering the Union at the border. Article 62 lists formal non-compliance triggers, missing or incorrect EU declaration of conformity, non-functional QR codes, incomplete technical documentation, breaches of the empty-space, restricted-format, reuse, refill or recycled-content rules, and the resulting withdrawal, recall or penalty consequences.
Minimum mandatory criteria where packaging drives a significant share of contract value
By 12 February 2030, the Commission must adopt implementing acts setting minimum mandatory green public procurement requirements for public contracts under Directives 2014/24/EU and 2014/25/EU where packaging or packaged products represent more than 30% of the estimated contract value. The requirements apply to procurement procedures launched 12 months or more after the implementing act enters into force, and may take the form of technical specifications, selection criteria or contract performance conditions. Contracting authorities may derogate on public-security, public-health or unresolvable-technical-difficulty grounds.
A ten-year delegation covering the technical detail behind the headline targets
The power to adopt delegated acts, covering, among others, the Article 5 heavy-metal and PFAS thresholds, Article 6 design-for-recycling criteria, Article 7 recycled-content adjustments, Article 11 minimum rotations, and several Article 29 reuse-target exemptions, is conferred on the Commission for 10 years from 11 February 2025, tacitly renewable unless the European Parliament or Council objects. Implementing acts follow the examination procedure via the committee established under Article 39 of Directive 2008/98/EC.
Bringing packaging under market surveillance, and adding to the single-use plastics ban list
Article 66 amends Regulation (EU) 2019/1020 on market surveillance by adding both Directive (EU) 2019/904 and the PPWR itself to its Annex I scope, formally bringing packaging under the EU's horizontal market-surveillance and customs-control framework.
Article 67 amends Directive (EU) 2019/904, the Single-Use Plastics Directive: it clarifies that the SUP Directive is lex specialis over the PPWR except where Article 25(1) and (6) PPWR, restrictions on single-use plastic packaging formats in Annex V point 3, prevail; it deletes the SUP Directive's own recycled-content rules for plastic beverage bottles from 2030, since PPWR Article 7 now governs this exclusively; and it expands the SUP Directive's restricted-products list to add shrink wrap used at airports or train stations to protect luggage, polystyrene or other plastic protective chips, and multi-pack plastic rings used as grouped packaging, all now banned as single-use plastics. This last addition, under Article 67(5), applies from 12 February 2029 rather than the Regulation's general application date.
Penalties, evaluation, repeal and the staggered entry-into-application timetable
Member States must lay down effective, proportionate and dissuasive penalties by 12 February 2027; penalties for breaches of Articles 24 to 29, empty space, restricted formats, reuse and refill obligations, must specifically include administrative fines (Art 68). The Commission must evaluate the Regulation's contribution to the internal market and to environmental sustainability by 12 August 2034, with a dedicated section on the impact on the agri-food system and on food waste (Art 69).
Directive 94/62/EC is repealed from 12 August 2026, but several of its provisions stay alive on transitional timetables running to 31 December 2028 and 31 December 2029 while implementing acts catch up. Commission Decision 97/129/EC, the old packaging-material identification system, is repealed from 12 August 2028.
The Regulation entered into force on 11 February 2025, 20 days after its 22 January 2025 publication in the Official Journal, and applies from 12 August 2026, except for Article 67(5), the new single-use-plastics restrictions, which applies from 12 February 2029.
Where the PPWR sets a hard number, and where it does not
| Sector | 2030 target | 2040 target | Exemptions / notes |
|---|---|---|---|
| Transport packaging (pallets, crates, IBCs, drums) | 40% | 70% (endeavour) | 100% for own-site or linked-enterprise transfers and same-Member-State transfers; cardboard boxes and dangerous-goods packaging exempt (Art 29(1)-(4)) |
| Large white goods (large-scale machinery packaging) | No numeric target | No numeric target | Recital 527 named this sector as assessed for reuse potential, but Art 29(4)(b) exempts packaging custom-designed for large-scale machinery and equipment from the transport-packaging target |
| Pallet wraps, straps and slings | 40% (within transport packaging) | 70% (endeavour) | Flexible formats covered by Art 29(1) alongside rigid transport packaging; exempt if in direct contact with food (Art 29(4)(c)) |
| Take-away cold and hot beverages and food | 10% (endeavour) | No further figure set | Own-container option mandatory from 12 Feb 2027; reusable-packaging option mandatory from 12 Feb 2028; micro-enterprises exempt (Arts 32-33) |
| HORECA on-site consumption | Single-use plastic packaging banned outright | Not applicable, already banned | Restriction, not a reuse percentage; venues without drinking-water access exempted (Art 25, Annex V point 3) |
| Alcoholic and non-alcoholic beverages (sales packaging) | 10% | 40% (endeavour) | Wine, aromatised wine products, spirits and milk/milk products exempt; final distributors under 100 sqm sales area may be exempt (Art 29(6)-(7)) |
Regulation (EU) 2025/40 versus the Directive 94/62/EC it repeals
| Feature | PPWR (Reg (EU) 2025/40) | Directive 94/62/EC |
|---|---|---|
| Instrument type | Regulation, directly applicable in all Member States, no national transposition required | Directive, required transposition into 27 separate national legal orders |
| Scope | Entire life-cycle of packaging: design, substances, recyclability, recycled content, reuse and waste management, in one instrument | Essential requirements and general waste-management principles, with detailed rules left to national implementation |
| Binding on | Economic operators directly, manufacturers, importers, distributors and final distributors, as well as Member States | Primarily Member States, who then set the binding rules for operators through national transposition |
| Enforcement | Harmonised EU-wide conformity assessment and a single EU declaration of conformity; packaging brought under the Market Surveillance Regulation; a common penalties framework due by 12 February 2027 | Enforcement varied by Member State transposition, with no EU-wide conformity assessment module or single declaration of conformity requirement |
Directive 94/62/EC governed EU packaging policy for three decades but left the operative detail to national transposition, producing 27 different rulebooks. The PPWR replaces that fragmentation with a single directly applicable Regulation, while several of the Directive's provisions stay alive on transitional timetables until the corresponding PPWR delegated and implementing acts are adopted.
From the first EU packaging Directive to the Grade C ban in 2038
Article 3 contains 71 numbered definitions. The load-bearing concepts that drive the rest of the Regulation:
Load-bearing terms as used in Regulation (EU) 2025/40
Primary sources for Regulation (EU) 2025/40
Full text of Regulation (EU) 2025/40 of 19 December 2024 (13 chapters, 71 articles, 189 recitals, 13 annexes):
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040
CELEX number: 32025R0040 | OJ reference: OJ L, 2025/40, 22.1.2025
The machine-readable ELI for the PPWR, resolving directly to the official act:
The full amendment and procedural history of the PPWR on EUR-Lex, tracing every consolidated version back to the original text:
https://eur-lex.europa.eu/legal-content/EN/HIS/?uri=CELEX:32025R0040
EP procedural reference: PE/73/2024/REV/1. Commission proposal: COM(2022) 677 final, 30 November 2022.
The European Commission's Directorate-General for Environment maintains the policy landing page for packaging and packaging waste, including implementation guidance as it is published:
https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
Six tools to analyse, track, and work with the PPWR and EU circular-economy legislation