An overview of PPWR: The new EU packaging waste regulation

First published: September 2026

Regulation (EU) 2025/40, widely referred to as EU Packaging and Packaging Waste Regulation or PPWR, is a major reset of how packaging is designed, documented, labelled, used, recovered and placed on the European market. For brands, importers, manufacturers, and distributors, packaging is more than a sourcing or sustainability task. It is now a core compliance issue with direct implications for market access, product development and supply chain governance.

PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026. Unlike the previous Packaging Directive, PPWR is a directly applicable EU regulation, which means businesses are moving into a far more harmonised and prescriptive compliance environment. For companies selling into the EU, packaging must be demonstrably more circular, more transparent and easier to recover at scale. 

Contact us directly for PPWR support.

A brief description of PPWR

PPWR is the EU’s new legal framework for packaging and packaging waste. It applies to all packaging placed on the EU market, whether used in B2B or B2C channels, and covers the full packaging life cycle from design and manufacture through to use, collection, sorting and recycling.

Regarding the scope, PPWR is not limited to plastic packaging, nor does it apply only to primary retail packs. It also affects food contact packaging, grouped packaging, transport packaging, e-commerce packaging and industrial formats. For many businesses, this means packaging will need to be managed with the same rigour as other regulated product components.

Background of PPWR

The regulation is designed to tackle a persistent EU-wide problem: too much packaging waste and too little reuse or high-quality recycling. In practical terms, PPWR moves packaging regulation away from broad policy ambition and into measurable design, material and documentation requirements. 

In practice, PPWR does four things at once:

• It tightens design rules. 
• It introduces stronger evidence and documentation obligations. 
• It links market access more directly to recyclability and material performance. 
• It pushes economic operators towards packaging systems that are easier to reuse, sort and recycle at scale.
• It regulates certain substances used in packaging, including heavy metals and PFAS.

For businesses, this means that packaging decisions made today will increasingly affect future market access, commercial resilience and customer confidence. A packaging format that appears viable under current internal specifications may become non-compliant if it cannot demonstrate recyclability, minimisation, compliance with substances of concern, or proper technical documentation.

Who needs to comply with PPWR?

Any company placing packaging or packaged products on the EU market should assume PPWR is relevant. This includes packaging manufacturers, brand owners, importers, distributors and, where required, authorised representatives. 

This is particularly important for global supply chains. A non-EU supplier may produce the packaging, but the EU importer or brand owner will still need confidence that the packaging complies. In other words, businesses cannot pass down legal responsibility simply by outsourcing packaging production.

Contact us now to ensure PPWR compliance.

The key PPWR requirements businesses should understand 

Recyclability by design

One of the most important changes under PPWR is the move to design-for-recyclability. Packaging will need to be recyclable, and from 2030 packaging placed on the EU market must meet recyclability performance criteria and achieve a minimum recyclability grade. Over time, the rules tighten further, meaning lower-performing packaging formats will face increasing pressure.

Businesses using complex laminates, difficult-to-separate components or unnecessary material combinations should expect redesign pressure well before the main deadlines arrive.

Packaging minimisation

Under Article 10 of the EU Packaging and Packaging Waste Regulation (PPWR), manufacturers and importers must ensure that by 1 January 2030, all packaging placed on the EU market is reduced in weight and volume to the minimum necessary to ensure its functionality.

The new rules strictly ban design features intended solely to inflate perceived product volume (such as double walls, false bottoms, or unnecessary layers) and remove marketing and consumer acceptance as valid standalone justifications for additional weight or volume.

Economic operators must document how they evaluated design limits against performance criteria covering factors like product protection, logistics, safety, and reusability. 

For grouped, transport, and e-commerce packaging, the PPWR is especially relevant because empty-space limits will apply. That has direct implications for online retail, fulfilment operations, secondary packaging and logistics efficiency.

Recycled content in plastic packaging

Another major development is the introduction of minimum recycled content requirements for certain plastic packaging applications. These targets are phased and vary by polymer type and use case, but the message is clear: businesses using plastic packaging need stronger control over material sourcing, supplier evidence, and claim substantiation.

The compliance challenge is not just securing recycled material. It is also about proving, documenting, and maintaining conformity as packaging specifications evolve.

Reuse and refill requirements

PPWR introduces reuse and refill obligations and targets for certain packaging categories, including some transport, industrial, e-commerce and beverage applications.

For many operators, this shifts the packaging discussion from single-format optimisation to system design. Beyond considering whether a pack can be recycled, businesses should now focus on whether a reusable model is required or commercially viable within the relevant application.

Substances in packaging: PFAS and heavy metals

PPWR addresses substances in packaging. In particular, it restricts PFAS in food-contact packaging where they exceed the relevant thresholds, and it maintains limits for the combined concentration of certain heavy metals in packaging and packaging components.

This means businesses need clearer supplier controls, specifications, substantiated and reliable evidence and technical documentation for coatings, inks, barriers and other material inputs where these substances may be relevant.

Traceability and technical documentation

PPWR increases the importance of traceability and supporting documentation. Compliance is not just about meeting the packaging requirements, but also about being able to show, through declarations, technical files and product-identification information, that packaging can be traced and assessed against PPWR requirements.

In practice, this means businesses will need stronger control over supplier data, packaging specifications and compliance records. This will require closer coordination across packaging development, procurement, regulatory, quality, and commercial teams so compliance with PPWR applicable requirements such as recyclability, recycled content, or substance compliance can be properly evidenced.

Harmonised labelling and consumer information

PPWR also moves towards harmonised labelling to support sorting, material identification and reuse information. Over time, packaging artwork and on-pack communication will need to align with regulatory requirements and implementing acts.

This means packaging compliance will increasingly involve not only regulatory and technical teams, but also packaging development, artwork management and marketing functions.

Declaration of Conformity and Technical Documentation

One of the most important aspects of PPWR is the stronger focus on Declaration of Conformity and Technical Documentation. 

From 12 August 2026, packaging placed on the EU market will need an EU Declaration of Conformity for the applicable packaging type. That declaration is the formal statement that the packaging complies with PPWR. However, the legal strength of the declaration depends entirely on the quality of the supporting technical file. 

In practice, Technical Documentation shall include packaging descriptions, design drawings, material specifications, applied standards, supplier declarations, recyclability assessments, minimisation assessments, reusability evaluations, relevant test reports, and other applicable requirements under PPWR that may become applicable over time. Businesses therefore need more than a signed document. They need a structured evidence base that can withstand customer scrutiny, regulatory review and internal change management.

For many organisations, this will be one of the biggest operational gaps. Packaging data often sits across procurement, packaging engineering, suppliers, testing laboratories and regulatory teams. PPWR makes that fragmentation risky.

Why are testing and compliance services becoming essential?

Testing and compliance services can play a critical role in making PPWR manageable. The regulation depends heavily on verifiable evidence, and many businesses will need external support to build that evidence base efficiently. 

A reliable Testing, Inspection, and Certification partner like Eurofins Sustainability Services can help mitigate both legal exposure and operational friction.

What does PPWR mean for packaging design and sourcing teams?

For packaging designers and specifiers, PPWR changes the design brief itself. Historically, packaging design often balanced brand presentation, cost, transport protection and shelf impact. Those factors still matter, but under PPWR they now need to be balanced against recyclability, minimisation, material transparency and future compliance risk.

For sourcing teams, supplier management becomes more demanding. Businesses will need better visibility into material composition, additives, recycled content and technical evidence. Generic supplier declarations will often be insufficient if they cannot support a full conformity assessment. 

For e-commerce in particular, PPWR is likely to push a sharper reassessment of oversized boxes, void fill and secondary packaging logic. Businesses that have built packaging around fulfilment convenience rather than minimisation may find that their legacy formats require significant redesign before 2030.

What should businesses do now for PPWR compliance?

Audit packaging by packaging type

Start with a packaging inventory built around packaging types, not only finished product SKUs. This is essential because conformity evidence and declarations need to map to packaging specifications.

Identify high-risk formats

Prioritise packaging that is most likely to face future redesign or evidence gaps, especially plastic packaging, multi-material formats, e-commerce packs, transport packaging and formats that may fall within reuse requirements.

Review existing documentation

Many businesses already hold some relevant information, but it is often spread across supplier files, specifications and historic test reports. PPWR readiness depends on bringing that information into a controlled and current compliance structure.

Strengthen supplier data collection

Supplier engagement should move beyond broad sustainability statements. Businesses need clear, current and traceable evidence on composition, recycled content, additives and pack configuration.

Build a technical evidence workflow

Treat Technical Documentation as an ongoing process rather than a last-minute paperwork exercise. The companies that start building internal governance now will be far better placed than those waiting until deadlines are close.

How can Eurofins Sustainability Services help you ensure PPWR compliance?

At Eurofins Sustainability Services, we help organisations turn PPWR requirements into practical compliance actions. Our support combines testing, compliance expertise and traceability services so you can better understand your obligations, substantiate packaging claims and place compliant packaging on the EU market with greater confidence. 

Contact us now!

Frequently asked questions