What is the Packaging and Packaging Waste Regulation (PPWR)?
The Packaging and Packaging Waste Regulation (PPWR) is a flagship EU sustainability regulation designed to transform how packaging is designed, used, and managed across its lifecycle. It replaces the Packaging and Packaging Waste Directive (PPWD) and introduces harmonised, enforceable requirements to reduce packaging waste, improve recyclability, and lower resource use across the EU.
The PPWR provides clarity on who is obligated for specific packaging requirements and when compliance is due, helping to reduce regulatory fragmentation across Member States. Implementation will be supported through secondary legislation and guidance, creating a consistent EU wide framework for sustainable packaging.
Who does the PPWR apply to?
The PPWR applies to all packaging placed on the EU market, regardless of material or format, including:
- Primary (sales) packaging
- Secondary (grouped) packaging
- Tertiary (transport) packaging
It covers the full lifecycle of packaging, from design and production through to end-of-life management.
Obligations apply to a wide range of stakeholders, including:
- Suppliers and manufacturers
- Brands and retailers
- Importers and distributors
Requirements vary by role but include the completion of the Declaration of Conformity (DoC), ensuring packaging meets the PPWR’s requirements on time, and reporting to market surveillance authorities upon request.
What are the timelines and deadlines of the PPWR’s key requirements?
The regulation introduces a range of requirements through a phased rollout that increases with ambition over time:
2026
- Requirements begin for substances of concern, green claims, reusable packaging, and the Declaration of Conformity (DoC)
2028
- Empty space reduction requirements for sales packaging (implementation details are evolving)
2030 (major milestone)
- Packaging bans and restrictions take effect for certain formats and materials
- Minimisation requirements to reduce packaging weight and volume
- Recycled content targets introduced for plastics
- Recyclability thresholds enforced packaging must meet design-for-recycling (DfR) criteria
2035–2040
- Stricter recyclability thresholds
- Higher recycled content targets
The PPWR also introduces packaging labelling requirements, including harmonised consumer facing and waste sorting information, which will be phased in over the next few years as the relevant implementing acts enter into force.
What are the risks of non-compliance?
Failure to comply with PPWR presents significant financial, legal, and commercial risks. Businesses may face administrative penalties, costly redesigns, product recalls and reduced customer trust.
Regulatory enforcement can also restrict or prohibit non-compliant packaging from being placed on the EU market, directly impacting revenue and supply chains. Alongside this, complex packaging that is difficult to recycle can increase eco-modulated Extended Producer Responsibility (EPR) fees.
What are the business opportunities?
PPWR compliance is also a strategic opportunity to unlock cost savings and efficiency gains. Optimising packaging for recyclability, reuse, and material reduction can lower input costs, streamline operations, and reduce EPR fees.
Organisations that move early can strengthen their brand reputation and improve access to capital, as investors are increasingly prioritising strong ESG performance and regulatory readiness.
How should organisations prepare?
To prepare for the PPWR, organisations placing packaging on the EU market should ensure that packaging:
- Meets DfR criteria
- Is minimised in weight and volume, with minimal empty space
- Contains the required levels of recycled content
- Avoids banned materials and formats
- Has the correct labelling
A critical first step is conducting a PPWR compliance and risk assessment across packaging portfolios to identify non-compliant formats. Given the cost and lead time associated with packaging redesign and tooling changes, early action is essential to meet the 2028 and 2030 requirements.