On February 11, 2025, EU Regulation 2025/40 on Packaging and Packaging Waste (PPWR) officially entered into force. This regulation replaces the Packaging and Packaging Waste Directive (94/62/EC). Most provisions of the new regulation will be implemented from August 12, 2026. The regulation aims to significantly reduce packaging waste generation, promote reusability or recyclability of all packaging, and facilitate the EU's transition to a circular economy. It covers the entire life cycle of packaging from design, production, market placement to end-of-life collection and recycling.
The EU PPWR applies to all packaging (regardless of material used) and all packaging waste, whether such packaging is used for industry, other manufacturing, retail or distribution, offices, services or households, or whether such packaging waste originates from these premises. Manufacturers, packaging or packaging material suppliers, authorized representatives designated by manufacturers, importers, distributors, fulfillment service providers, packaging waste management operators, and others must fulfill their respective obligations in accordance with the regulatory requirements.
Sustainability Requirements for Packaging
1. Strict Limitations on Hazardous Substances
- The combined concentration of lead, cadmium, mercury, and hexavalent chromium resulting from substances present in packaging or packaging components shall not exceed 100 mg/kg.
- From August 12, 2026, food contact packaging containing per- and polyfluoroalkyl substances (PFAS) at or above specified threshold concentrations shall not be placed on the market.
2. Use of Recyclable Packaging
All packaging placed on the market shall be recyclable. Manufacturers shall assess the recyclability of packaging in accordance with the regulation and indicate the recyclability performance grade using Grade A, B, or C (see table below). When the recyclability performance grade of a packaging unit is below 70%, it shall be technically considered non-recyclable, and its market placement shall be restricted.
3. Minimum Recycled Content Requirements for Plastic Packaging
Any plastic packaging component placed on the market shall contain a minimum percentage of post-consumer plastic waste recyclate (calculated as an annual average per manufacturing plant).
|
Packaging Type |
2030 |
2040 |
|
Contact-sensitive packaging with PET as main component (excluding single-use plastic beverage bottles) |
30% |
50% |
|
Non-PET contact-sensitive plastic packaging (excluding single-use plastic beverage bottles) |
10% |
25% |
|
Single-use plastic beverage bottles |
30% |
65% |
|
Other plastic packaging |
35% |
65% |
Note: Packaging for certain medical devices, medicinal products, compostable materials, dangerous goods, products intended exclusively for infants, veterinary medicinal products, and packaging products that pose a threat to human health are exempt.
4. Packaging Minimization
By January 1, 2030, manufacturers or importers shall ensure that packaging placed on the market is reduced to the minimum weight and volume necessary to ensure its functionality, taking into account the shape and material of the packaging. Packaging designed to increase the perceived product volume (including double walls, false bottoms, and unnecessary layers) shall not be placed on the market.
5. Reusable Packaging
For example, from January 1, 2030, economic operators using transport packaging or sales packaging (including e-commerce distribution) within the EU shall ensure that 40% is reusable packaging if using packaging that meets specific requirements. From January 1, 2040, this proportion shall reach at least 70%.
Labeling, Marking and Information Requirements
- From August 12, 2028, packaging placed on the market shall bear a harmonized label containing information on the composition of packaging materials to facilitate consumer sorting. The label shall use pictograms that are easy to understand, including for persons with disabilities.
- Reusable packaging placed on the market shall bear a label informing users that the packaging is reusable. Information on reuse systems and collection points shall be provided in digital form, such as through QR codes.
- Ensure that harmonized labels are affixed, printed or engraved on waste containers in a clearly visible, legible and indelible manner.
Extended Producer Responsibility (EPR)
This is an important environmental policy framework in the EU. It requires any natural or legal person professionally engaged in the development, manufacture, processing, handling, sale or import of products (product producers) to assume extended producer responsibility. Such measures may include accepting returned products and residual waste generated after their use, as well as subsequent waste management and assuming financial responsibility for such activities.
The PPWR requires that each Member State's registration authority provide links to other countries' producer registration authority websites, enabling all Member States to register producers or authorized representatives to fulfill extended producer responsibility. Producers shall submit a registration application to the competent authority responsible for registration in the Member State when placing their packaging or packaged products on the market in that Member State for the first time, or when opening packaged products in cases where the final user is not involved.
Reference
- DIRECTIVE 2008/98/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 19 November 2008 on waste and repealing certain Directives
- REGULATION (EU) 2025/40 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC
