A Practical Guide to Regulation (EU) 2025/40 on Packaging and Packaging Waste. For businesses placing packaged goods on the EU market, the rules changed in February 2025. From 12 August 2026, compliance is no longer optional-it is the law.

TL;DR

Regulation (EU) 2025/40 on packaging and packaging waste (the Packaging and Packaging Waste Regulation, or PPWR) entered into force on 11 February 2025 and generally applies from 12 August 2026. The application date has been widely referred to as “Eclipse Day” in the industry.
It replaces the former Packaging Waste Directive (94/62/EC) with a directly applicable regulation that creates uniform rules across all EU Member States.
From 12 August 2026, businesses face immediate obligations: a ban on PFAS in food‑contact packaging, heavy metal limits, mandatory unique identification on each packaging unit, conformity assessments, technical documentation, and an EU Declaration of Conformity.
The European Commission published the second edition of its PPWR FAQs in August 2026, clarifying that enforcement will not be automatic-Member States must first give economic operators an opportunity to take corrective action before imposing further measures.
By 2030, all packaging placed on the EU market must be recyclable (at least Grade C), meet minimum recycled content targets for plastics, and comply with packaging minimisation rules (weight and volume reduced to the minimum necessary, empty space ratio not exceeding 50%).
Extended Producer Responsibility (EPR) obligations apply, and non‑EU exporters must comply when selling packaged goods into the EU.

What Is the PPWR?

The Packaging and Packaging Waste Regulation (PPWR) – formally Regulation (EU) 2025/40 – is a new EU law that replaces the Packaging and Packaging Waste Directive (94/62/EC). It was adopted on 19 December 2024, entered into force on 11 February 2025, and generally applies from 12 August 2026.

Unlike a directive, which requires national transposition, a regulation is directly applicable in all EU Member States without the need for national implementing legislation. This creates a level playing field across the EU internal market and harmonises packaging rules for the first time.

Why Was It Introduced?

Packaging consumption has grown rapidly in recent years due to increased online purchases, home deliveries, and global trade. In 2023, each European citizen generated over 178 kg of packaging waste-around half a kilo of packaging every day. Without action, this is projected to increase by 19% by 2030.

The PPWR is the EU’s response to this challenge. It aims to:

Reduce packaging waste and unnecessary packaging
Promote reuse, refill systems, and recycling
Increase the use of recycled materials
Harmonise labelling and reporting requirements
Reduce dependence on imported fossil fuels from which plastic packaging is almost entirely made

The regulation is a key pillar of the EU Circular Economy Action Plan and introduces far-reaching requirements across the full packaging life cycle-from design and manufacturing through to end‑of‑life waste management.

Scope: Who and What Is Covered?

Which Packaging Is Covered?

The PPWR applies to all packaging and packaging waste, regardless of material or origin. This includes:

Primary packaging (sales packaging)
Secondary packaging (grouped packaging)
Tertiary packaging (transport packaging)

The scope covers packaging manufactured within the EU and packaging imported from third countries.

Which Businesses Are Affected?

The regulation applies to all businesses placing packaging on the EU market, including:

Manufacturers – carry the most extensive obligations, including conformity assessment, technical documentation, and the EU Declaration of Conformity
Importers – must verify supplier documentation and retain it for market surveillance
Distributors and retailers – have verification and due diligence obligations
Producers – responsible for Extended Producer Responsibility (EPR) obligations on a market‑by‑market basis

Brand owners beware: If your brand is on the packaging, you are likely the manufacturer for PPWR purposes, regardless of who physically produces the packaging.

Micro‑enterprises (as defined in Recommendation 2003/361/EC) are subject to lighter rules but still required to meet core obligations.

Key Requirements and Deadlines

The PPWR introduces a rolling series of deadlines stretching from August 2026 to 2040. Below is a breakdown of the key requirements.

Substance Restrictions (From 12 August 2026)

Heavy Metals:

The combined concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg.

PFAS in Food‑Contact Packaging:

Per- and polyfluorinated alkyl substances (PFAS) are banned in food‑contact packaging from 12 August 2026. Strict thresholds apply:

Parameter	Limit
Any individual PFAS substance	25 ppb
Sum of PFAS (targeted analysis)	250 ppb
Total fluorine	50 ppm

Food‑contact packaging placed on the market after 12 August 2026 must not exceed these limits.

Important: There is no transitional period for the exhaustion of stocks regarding packaging produced before 12 August 2026 that contains PFAS. However, packaging placed on the market before 12 August 2026 may remain on the market and does not need to be withdrawn.

Packaging Minimisation (From 1 January 2030)

From 1 January 2030, packaging weight and volume must be reduced to the minimum necessary. Marketing and consumer acceptance are no longer valid justifications for excess packaging.

Empty Space Ratio: For grouped, transport, and e‑commerce packaging used to supply products to final distributors or end users, the empty space ratio must not exceed 50%.

Recyclability Requirements

All packaging placed on the market must be designed for recycling from 12 August 2026.

Recyclability Performance Grades:

From 1 January 2030, only packaging with recyclability grade A (at least 95% recyclable), B (at least 85%), or C (at least 70%) will be permitted. Packaging below Grade C will be prohibited.

From 1 January 2038, only grade A or B will be acceptable.

Minimum Recycled Content for Plastics (From 1 January 2030)

Plastic packaging must contain minimum recycled content, calculated as an average per manufacturing plant and year.

Key targets include:

Single‑use plastic beverage bottles: at least 30% recycled content by 2030, rising to 65% by 2040
Targets vary by packaging type and contact sensitivity (food/pharma have lower initial targets)

Labelling and Information Requirements

Harmonised Labels (From 12 August 2028) :

Packaging must bear harmonised pictogram labels indicating recyclability and sorting instructions. These labels must be accessible to all users, including people with disabilities.

Digital Product Passport (DPP) :

Certain packaging categories must feature machine‑readable data carriers (e.g., QR codes) linking to a decentralised database containing material composition, environmental footprint, recyclability grades, and end‑of‑life disposal instructions.

Identification Markings (From 12 August 2026) :

Packaging must include:

Manufacturer/importer identification: Company name, trademark, and contact details
Packaging identification: A type, batch, or serial number (or similar identifier)

If the size or nature of the packaging does not allow for this to be included on‑pack, the information can be provided in a document accompanying the packaging. It is not necessary for every single component of a packaging unit to be individually marked-it is sufficient for the required information to be displayed on only one component of the sales packaging.

EU Declaration of Conformity (From 12 August 2026)

Every piece of packaging on the EU market must have its own Declaration of Conformity (DoC) and supporting technical documentation.

What the DoC Requires (Annex VIII):

A unique identification number for tracking
The manufacturer’s name and address
A sole responsibility statement
Packaging identification (type, material, and batch or serial number)
Conformity statement referencing Articles 5 through 12
Signature with place and date

Key requirements:

The DoC applies per packaging type-each format, each material, each configuration needs its own declaration
The DoC must be kept up to date and made available in the language that can be easily understood by end users in the Member State where the packaging is placed on the market
Retention limits: 5 years for single‑use packaging, 10 years for reusable
The person who signs is personally liable

Manufacturer vs. Producer:

Understanding the distinction is critical:

Manufacturer – responsible for conformity assessment, technical documentation, and the DoC. This is the entity that places packaging on the EU market under its own name or trademark.
Producer – responsible for Extended Producer Responsibility (EPR) registration, fees, and volume reporting. This is determined on a market‑by‑market basis.

Reuse and Refill Targets

Transport Packaging:

By 2030: 40% of transport packaging must be reusable within a re‑use system

Take‑away Beverages (HORECA Sector) :

From 12 February 2027, final distributors offering hot or cold beverages in take‑away packaging must allow consumers to bring their own container to be filled, without charging more or offering less favourable conditions.

By 12 February 2028, they must also offer consumers the option of obtaining products in reusable packaging within a re‑use system.

Reuse Targets for Beverage Containers:

By 2030: at least 20% of cold and hot beverages sold in take‑away containers must be in reusable packaging or part of a refill system
By 2040: this target increases to 80%

Micro‑enterprises are exempted from these HORECA obligations.

Packaging Waste Reduction Targets

Member States must reduce packaging waste generated per capita relative to 2018 levels:

5% by 2030
10% by 2035
15% by 2040

Deposit and Return Systems (DRS)

By 1 January 2029, all Member States must implement deposit and return systems for:

Single‑use plastic beverage bottles
Metal beverage containers up to three litres (excluding certain products such as wine and spirits)

Bans on Specific Packaging Formats

By 31 December 2027, certain single‑use packaging formats are banned, including:

Single‑use plastic shrink wrap for suitcases and bags at airports
Grouped packaging for cosmetics (except perfumes), hygiene, and toiletry products

Single‑Use Packaging Prohibitions

From 1 January 2030, single‑use packaging for cosmetics, hygiene, and toiletry products intended for use in the accommodation sector is prohibited.

Plastic Bag Consumption Limits

By the end of 2025, annual per capita consumption of lightweight plastic carrier bags must be limited to 40 bags (with exceptions for very lightweight bags used for hygiene or food preservation).

Timeline: Key Dates at a Glance

Date	Requirement
11 February 2025	PPWR entered into force
30 March 2026	European Commission published first PPWR guidance document
10 June 2026	Commission Notice Guidance (C/2026/3084) published
12 August 2026	General application begins; PFAS ban in food‑contact packaging; heavy metal limits; mandatory unique identification; conformity assessment and EU Declaration of Conformity required
12 February 2027	HORECA: consumers must be allowed to bring own containers for take‑away beverages
31 December 2027	Bans on specific single‑use packaging formats
12 February 2028	HORECA: reusable packaging option for take‑away beverages
12 August 2028	Harmonised recyclability and sorting labels required
1 January 2029	Mandatory deposit and return systems for beverage containers
1 January 2030	Recyclability grades (A, B, C) apply; packaging minimisation rules; minimum recycled content targets; single‑use packaging ban in accommodation sector
1 January 2035	Recyclability grades A and B only apply
1 January 2038	Recyclability grades A and B only apply
By 2040	Increased recycled content targets (65% for beverage bottles)

Extended Producer Responsibility (EPR)

The PPWR introduces specific rules on Extended Producer Responsibility (EPR) for packaging and packaging waste. Producers are financially and operationally responsible for the waste management of the packaging they place on the market.

For non‑EU exporters, this involves:

Registering with the national authority in each EU country of sale
Providing data on packaging type, weight, recyclability, and recycled content
Paying EPR fees

Distinction Between Manufacturer and Producer:

The PPWR makes a clear distinction:

Manufacturer: Responsible for design, conformity assessment, and labelling (EU‑wide)
Producer: Responsible for Extended Producer Responsibility (EPR) obligations (market‑by‑market)
There is only one manufacturer in a supply chain within the meaning of the PPWR throughout the EU. Importers without separate legal personality cannot act as importers; an authorised representative may be required.

What Non‑EU Businesses Need to Know

UK exporters (and other non‑EU businesses) must comply with PPWR when selling any packaged goods to the EU. Non‑compliance could result in goods being rejected at EU borders.

Key actions for non‑EU businesses:

Understand your obligations: Research EPR scheme requirements in your target EU market
Assess your packaging: Evaluate against PPWR criteria and national EPR guidelines
Register with relevant EPR schemes: Register and report packaging data; consider appointing an authorised representative to manage EPR obligations locally
Collect and report data: Ensure all relevant data is collected and records are kept

Enforcement and Practical Guidance

What the European Commission Has Clarified

The European Commission published the second edition of its PPWR FAQs in August 2026, providing crucial clarifications:

Enforcement will not be automatic:

Packaging will not automatically be prohibited, withdrawn, or recalled where PPWR non‑compliance is identified on day one
Member States must first give the relevant economic operator an opportunity to take corrective action
Only where non‑compliance persists may further measures-such as prohibiting, recalling, or withdrawing non‑compliant packaging-be imposed
Market surveillance authorities are encouraged to adopt a support‑oriented approach through awareness‑raising, requests for information, and reasonable timeframes for corrective action

This is a meaningful reassurance, but not a licence for inaction. Documented good‑faith efforts will be central to any discussion with an authority.

The PPWR and food law are complementary frameworks

The FIC Regulation (Regulation (EU) 1169/2011) and the PPWR pursue different objectives and operate as complementary, parallel frameworks
Compliance with the FIC Regulation alone is not sufficient to fulfil the manufacturer identification requirement of Article 15(6) PPWR
A food or beverage business cannot simply point to its existing FIC name‑and‑address labelling as satisfying the PPWR manufacturer identification requirement

Expanded clarifications for economic operators:

The updated FAQ explains the distinction between sales, grouped, and transport packaging; identifies who is considered the manufacturer of transport packaging and branded packaging; clarifies responsibility where different companies own the product name and trademark; and provides examples for determining the producer in different supply chain scenarios.

Unresolved issues

There is still no harmonised EU verification methodology for compliance with the Article 5(5) PFAS limits. The short period between the publication of the revised FAQ and the start of the PPWR’s applicability gives affected companies limited time to review the guidance.

How to Prepare Your Business

Immediate Steps (Before 12 August 2026)

Determine your PPWR role: Do you place packaging on the EU market under your name or trademark? If yes, you are likely the manufacturer
Map your packaging portfolio: The declaration is per packaging type, so list every format, material, and supplier
Test for substance compliance: PFAS limits, heavy metals, and restricted substances have defined thresholds now. This is the immediate priority
Audit your packaging – identify excessive packaging or non‑recyclable materials
Implement conformity assessment: Prepare technical documentation with substance test results first
Assign unique identification: Each packaging unit must have a unique identifier
Prepare EU Declaration of Conformity for every packaging type
Start building your technical documentation and data structure

Medium‑Term Planning (2027–2029)

Design for recyclability – ensure packaging meets future grade requirements
Plan for recycled content – source recycled plastics for packaging
Implement labelling – prepare for harmonised labels by August 2028
Set up EPR registration – in all relevant EU Member States
Prepare for deposit and return systems – by January 2029

Long‑Term Strategy (2030 and beyond)

Achieve full recyclability – Grade C minimum by 2030, Grade B by 2038
Reduce packaging weight and volume – meet minimisation requirements
Increase recycled content – meet 2030 and 2040 targets
Support reuse and refill systems – align business models with circular economy

Sources of Further Guidance

The European Commission has published several key interpretative tools to support PPWR implementation:

Commission Notice Guidance (C/2026/3084) – published 10 June 2026
First edition FAQs – published 30 March 2026
Second edition FAQs – published August 2026

Both are available on the European Commission’s website.

Industry resources:

EUROPEN has launched a PPWR Conformity Assessment Toolkit
Legal and consulting firms have published detailed readiness guides

Disclaimer

This article provides general information about Regulation (EU) 2025/40 and does not constitute legal advice. The requirements are complex and subject to interpretation. Businesses should seek independent legal advice based on their specific operational circumstances.

Key Takeaways

The PPWR applies from 12 August 2026 – the first obligations are now in effect.
The European Commission’s updated FAQs (August 2026) clarify that enforcement will be pragmatic: Member States must first give operators an opportunity to take corrective action.
A Declaration of Conformity is required for every packaging type from 12 August 2026. The DoC must include a unique identification number, manufacturer details, and signature.
PFAS in food‑contact packaging is banned from 12 August 2026 with strict limits: 25 ppb per substance, 250 ppb sum, 50 ppm total fluorine.
If your brand is on the packaging, you are likely the manufacturer for PPWR purposes and carry the conformity assessment, DoC, and technical file obligations.
By 2030, all packaging must be recyclable (Grade C minimum), meet recycled content targets, and comply with minimisation rules.
Non‑EU exporters must comply when selling packaged goods into the EU.