Regulation on Packaging and Packaging Waste (PPWR)

The PPWR replaces the current Packaging and Packaging Waste Directive. As an EU regulation, the PPWR is directly applicable—it sets out the rights and obligations of entities, who can invoke it directly before courts or authorities (and must comply with it). It becomes part of the Member States’ national laws without the need for any domestic implementing legislation.

The overarching goals of the PPWR are clear:

• to decouple economic growth from packaging waste,
• to ensure packaging is fit for a circular economy,
• to improve transparency across the (packaging) value chains.

The PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026. Certain requirements (e.g., regarding recyclability, targets for recycled content, or reuse targets by 2030) will be phased in at later dates. At various stages, the European Commission will also adopt numerous delegated and implementing acts to specify or supplement specific areas covered by the PPWR.

Given the phased implementation starting in 2026 and the numerous targets set for the period up to 2030 and beyond, ensuring compliance with the PPWR is not a one-time effort aimed at ensuring regulatory compliance, but rather a structural change that requires long-term operational readiness, especially for companies with an extensive and complex range of packaged products. Companies must be aware that non-compliance with the PPWR is not only a regulatory risk but also a threat to business continuity.

The PPWR introduces new requirements concerning, among other things:

• substances in packaging (including potentially hazardous substances and PFAS concentrations in packaging intended for food contact),
• recycled content in plastic packaging,
• packaging minimization,
• labeling,
• recyclability,
• environmental claims regarding packaging properties. 

Compliance of the packaging of a product with the PPWR requirements must be demonstrated by the EU declaration of conformity (DoC), preceded by the conformity assessment procedure.

The PPWR establishes numerous obligations for economic operators, depending on their role in the supply chain (e.g., as a manufacturer, importer, or distributor). A separate category under the PPWR is the producer, who, depending on the circumstances, may refer to the manufacturer, importer, or distributor. Proper identification of each economic operator’s role in the supply chain is therefore crucial for determining the obligations that the PPWR imposes on that entity.