Table of Contents
Introduction: PPWR
The EU Packaging and Packaging Waste Regulation (PPWR) came into force on February 12, 2025. It will apply from August 12, 2026 to all companies that place packaging on the EU market – from small businesses to multinational corporations.
The aim of the regulation is to strengthen the circular economy: From 2030, all packaging must be recyclable, while specific reuse targets apply to certain types of packaging. In addition, the member states must reduce their per capita packaging volume – by 5% by 2030, 10% by 2035 and 15% by 2040, in each case compared to the base year 2018.
The PPWR defines binding requirements for design, recycling, documentation and labeling as well as specific deadlines that companies must now be aware of and implement.
Key innovations and obligations
Reusability (reusable quotas & refill)
By 2030, 40% of transport packaging within the EU must be reused; by 2040, this proportion is to rise to 70%. Within a member state and between locations of the same company, a 100% reuse obligation will already apply from 2030.
Reuse targets will also come into force for collection and sales packaging from 2030. These relate in particular to beverage packaging and other defined types of packaging, with exceptions for products such as milk and dairy products, wine and spirits.
In the HORECA sector (hotel, restaurant and catering) and in the refill sector, final distributors with a sales area of more than 400 m² are obliged to offer reusable alternatives. They must also make it possible for customers to fill their own containers. A target of 10% reusable containers has been set, and retailers should also aim to set aside 10% of their sales area for refill stations.
Additional packaging bans will apply from 2030. This includes single-use plastic collection packaging such as shrink wrap, single-use packaging in the HORECA sector such as cups, plates or portion packs for sugar, milk and spices (with exceptions for hygiene and safety purposes), single-use plastic packaging for fruit and vegetables under 1.5 kg and single-use packaging in the accommodation sector such as small shampoo bottles or bars of soap. Very light plastic bags may only be used for loose foodstuffs or for hygienic reasons.
Recyclability (design for recycling)
From 2030, all packaging must be recyclable. To this end, it will be classified in Recyclability Performance Grades A-C. The criteria and methodology for the assessment will be defined by January 1, 2028 (delegated acts) and January 1, 2030 (implementing acts) at the latest. From 2038, only level A or B packaging will be permitted; level C packaging will then be prohibited. Exceptions apply for a limited period for innovative packaging as well as for certain food packaging, pharmaceutical packaging and hazardous goods.
Minimum use of recyclate
From 2030, quotas will apply for the use of post-consumer recyclate (PCR) in packaging. The minimum proportion for PET food packaging is 30%, rising to 50% by 2040. For other contact-sensitive plastics, a proportion of 10 to 25% applies, rising to a maximum of 25% by 2040. Single-use plastic drinks bottles must contain 30% recyclate from 2030, rising to 65% by 2040. For other plastic packaging, a quota of 35% applies, rising to 65% by 2040.
These quotas apply to each plastic part that makes up more than 5% of the total weight of a packaging. Compostable packaging is excluded from the recyclate quotas.
Packaging minimization and substance bans
From 2030, the weight, volume and layers of packaging must be reduced to the extent necessary for its functionality. A maximum permitted void ratio of 50% applies to transport and e-commerce packaging. Packaging with double walls, double bottoms or unnecessary layers will be prohibited. In addition, substance restrictions apply, for example for heavy metals (cumulative limit values) and PFAS in food contact materials.
Labeling obligations
The PPWR provides for harmonized symbols and pictograms throughout the EU. New mandatory information will come into force in stages from 2028 and 2029. This includes information on material composition, recycled content, reusability and membership of EPR or deposit systems. From 2030, information on substances of concern must be provided digitally.
Some of the information must be communicated via digital technologies such as QR codes, including the recycled content, reusability, waste streams and manufacturer information. Sustainability claims are only permitted if the minimum legal standards are exceeded. In addition, uniform labeling of waste collection containers will be introduced.
Documentation and verification obligations (EPR)
A manufacturer register will be set up in each Member State, in which companies must register as soon as they place packaging on the market. The date depends on the national implementation, but after 2026 at the latest. In any case, registration must take place before the packaging is placed on the market for the first time.
Companies are also obliged to submit annual volume reports. The EPR fees are eco-modulated so that environmentally friendly packaging is more favorable. For companies not based in a Member State, there is an obligation to appoint authorized representatives: EU-wide voluntary for design conformity and nationally mandatory for compliance with the EPR requirements.
Deposit return systems (DRS)
By January 1, 2029, Member States must introduce deposit systems for single-use plastic beverage bottles and single-use metal containers with a capacity of up to three liters. The aim is to collect at least 90% of this packaging separately by weight. Member States that already achieve a rate of more than 80% in 2026 and present a strategy to achieve 90% by the beginning of 2028 can apply for an exemption from this obligation.
Practical guide: Step-by-step preparation
Companies should prepare for the new requirements in good time. The following roadmap shows how implementation can be approached systematically:
- Carry out an internal packaging analysis: All packaging used must be recorded – including material, quantity, recyclability (according to grades A-C) and recycled content. The void ratio should also be checked.
- Involve suppliers: Suppliers should be obliged to provide PPWR-compliant materials and evidence at an early stage.
- Check and document recyclability: With the help of recognized standards and tools such as RecyClass, recyclability can be assessed. Weak points should be rectified and the results documented, also with regard to modulated EPR fees.
- Optimize the use of recyclate: Companies should align their packaging with the new quotas, carry out material tests and set up a monitoring system for the proportion of recycled material.
- Implement labeling requirements: Packaging designs must be adapted to the new requirements, QR codes and digital product information must be integrated. It is also important to inform employees and customers about the new symbols and processes in good time.
- Adapt EPR processes: This includes registration in all relevant member states, setting up systems for volume reporting and calculating and optimizing licensing costs.
- Prepare deposit systems: Companies that fall under the deposit obligation must ensure that they participate in the systems in good time and fulfill their documentation obligations.
Recommendation for action
Companies should start implementation at an early stage. Many deadlines seem far away at first glance, but require lengthy adjustments in procurement, design and logistics.
Compliance with the regulations is crucial, as violations could lead to sales bans from 2030. At the same time, implementing the PPWR requirements offers the opportunity to use sustainability as a competitive advantage, reduce costs and strengthen the brand image.
Finally, it is advisable to actively seek cooperation with partners in reusable systems and take-back logistics and to help shape these in order to benefit from synergy effects and cost advantages right from the start.
