What Businesses Need to Know About PPWR, the EU’s New Packaging Waste Law

Article Highlights:

• At its core, the PPWR is a circular economy instrument. It’s designed to reduce the amount of packaging placed on the market, eliminate packaging that cannot be effectively recycled, and drive systemic changes in how packaging materials are designed, collected, sorted, and reused. 
• The scope of the PPWR is intentionally broad, applying to all economic operators that place packaging or packaged products on the EU market, regardless of where the packaging is manufactured. This includes EU-based manufacturers, non-EU importers, distributors, retailers, and online marketplaces that facilitate sales into the EU.
• One of the most transformative elements of the PPWR is the requirement that all packaging placed on the EU market must be recyclable according to defined performance criteria. Recyclability is no longer a general concept, but rather a measurable standard assessed against EU-wide design-for-recycling criteria.
• The PPWR entered into force in February 2025, but its obligations did not apply immediately. The general application date is August 2026, giving businesses a limited transition period to align packaging portfolios and compliance systems.

The European Union has formally adopted a new Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, commonly referred to as the PPWR. This regulation represents one of the most consequential shifts in EU product and packaging compliance in over two decades. Unlike the former Packaging and Packaging Waste Directive, which allowed member states significant discretion in implementation, the PPWR applies directly and uniformly across all EU markets.

For businesses that place packaged goods on the EU market, whether as manufacturers, importers, distributors, or online sellers, the PPWR fundamentally changes how packaging must be designed, documented, labeled, and managed at end of life. The regulation is not limited to traditional packaging producers, either; it affects any company whose products rely on packaging to reach EU customers.

The urgency of the PPWR regulation is driven by environmental realities. Packaging accounts for a significant and growing share of EU waste, with packaging volumes increasing faster than recycling rates across the continent. The regulation is intended to:

• Reduce waste generation at the source
• Improve material circularity
• Ensure packaging placed on the EU market aligns with long-term climate and resource-efficiency objectives.

What the PPWR Aims to Achieve

The PPWR marks a deliberate transition away from the previous Packaging Directive, which relied on national transposition and resulted in fragmented rules, inconsistent enforcement, and uneven environmental outcomes. The new regulation establishes harmonized requirements that apply uniformly across all member states, reducing regulatory ambiguity while raising the compliance bar for businesses.

At its core, the PPWR is a circular economy instrument. It’s designed to reduce the amount of packaging placed on the market, eliminate packaging that cannot be effectively recycled, and drive systemic changes in how packaging materials are designed, collected, sorted, and reused. The regulation prioritizes waste prevention first, followed by reuse and refill systems, and finally high-quality recycling where reuse is not feasible.

By setting binding performance criteria rather than aspirational targets, the PPWR shifts responsibility upstream. Packaging design decisions made today will determine whether products can legally remain on the EU market tomorrow.

What’s the Scope of PPWR? 

The scope of the PPWR is intentionally broad. It applies to all economic operators that place packaging or packaged products on the EU market, regardless of where the packaging is manufactured. This includes EU-based manufacturers, non-EU importers, distributors, retailers, and online marketplaces that facilitate sales into the EU.

Non-EU companies are explicitly within scope if they sell packaged goods directly to EU customers, including through e-commerce channels. In such cases, the non-EU business is treated as the producer for compliance purposes unless an authorized representative or importer assumes those obligations.

In addition, the PPWR regulation applies to all types of packaging, including primary, secondary, and tertiary forms, across all materials and sectors. There are a few highly limited exemptions, but these are narrowly defined and should not be assumed without a detailed legal assessment.

PPWR’s Key Requirements and Compliance Obligations

Recyclability and Eco-Design

One of the most transformative elements of the PPWR is the requirement that all packaging placed on the EU market must be recyclable according to defined performance criteria. Recyclability is no longer a general concept, but rather a measurable standard assessed against EU-wide design-for-recycling criteria.

Packaging must meet minimum recyclability performance grades, and only packaging that can be recycled at scale within existing or planned EU infrastructure will be permitted. Materials, additives, inks, labels, and multi-material constructions are all evaluated in determining whether packaging meets these criteria.

This requirement forces businesses to reconsider packaging formats that have historically been tolerated but are functionally non-recyclable, such as complex laminates or hard-to-separate composite materials.

This requirement forces businesses to reconsider packaging formats that have historically been tolerated but are functionally non-recyclable, such as complex laminates or hard-to-separate composite materials.

Minimum Recycled Content

For plastic packaging, the PPWR introduces binding minimum recycled content thresholds that increase over time, beginning in 2030. These requirements vary by packaging type and application, reflecting differences in material availability and technical feasibility.

Compliance with recycled content targets requires verifiable material traceability. Companies must be able to substantiate recycled content claims through documented supply chain evidence, not merely marketing assertions. This introduces new data management and supplier engagement obligations, particularly for businesses sourcing packaging globally.

Packaging Reduction and Reuse Mandates

The PPWR establishes explicit waste prevention measures aimed at reducing the volume of packaging placed on the market. Packaging that serves no functional purpose, including excessive unused space, is restricted. E-commerce packaging is a particular focus, with limits on empty space ratios and expectations for right-sized packaging.

In parallel, the regulation introduces reuse and refill targets for specific sectors, including food service and transport packaging. While not all businesses will be subject to reuse mandates, many will need to assess whether reusable systems are required, permitted, or strategically advantageous under the new framework.

Labelling, Digital Information, and Conformity Documentation

The PPWR will be introducing new, standardized labeling requirements in order to improve consumer sorting behavior and waste management outcomes. Labels must clearly indicate material composition and disposal pathways, using harmonized EU formats.

The regulation also introduces digital information requirements, often referred to as digital product or packaging passports. These systems are intended to make detailed packaging information accessible to authorities and waste operators, while simultaneously reducing physical labeling complexity.

Every in-scope packaging format must be supported by technical documentation and an EU Declaration of Conformity. This documentation must demonstrate compliance with applicable PPWR requirements and be maintained for market surveillance purposes.

Extended Producer Responsibility and Fees

Extended Producer Responsibility remains a cornerstone of EU packaging policy, but the PPWR significantly strengthens and harmonizes EPR obligations. Producers are financially responsible for the collection, sorting, and treatment of packaging waste generated from their products.

Eco-modulation of fees will be expanded, too, meaning that packaging design directly affects EPR costs. Packaging that is difficult to recycle or disrupts recycling streams will attract higher fees, while compliant and high-performing designs benefit from lower financial burdens.

Timelines and Milestones

The PPWR entered into force in February 2025, but its obligations did not apply immediately. The general application date is August 2026, giving businesses a limited transition period to align packaging portfolios and compliance systems.

However, not all requirements apply simultaneously. Recyclability design criteria, labeling standards, and documentation obligations apply earlier than recycled content thresholds and reuse targets. Businesses must therefore plan for phased compliance, rather than a single implementation event.

Delaying preparation until August 2026 significantly increases a business’s compliance risk, particularly for companies with complex packaging supply chains or long product development cycles.

PPWR Impact by Sector and Business Model

The PPWR affects sectors differently, depending on the difficulty and complexity of their packaging and their overall business model. E-commerce companies face heightened scrutiny due to packaging volume, void space requirements, and expectations around reusable transport packaging.

E-commerce companies face heightened scrutiny due to packaging volume, void space requirements, and expectations around reusable transport packaging.

Manufacturers and importers must reassess packaging specifications, supplier contracts, and material sourcing strategies. In many cases, compliance will require redesign rather than incremental adjustments.

Small and medium-sized enterprises benefit from some transitional flexibility, but they are not exempt. Larger organizations face broader reporting obligations and increased enforcement visibility, while SMEs often face resource constraints that make early planning essential.

Noncompliance Risks and Enforcement

Enforcement of the PPWR is carried out by member state authorities, within a harmonized legal framework. Penalties for non-compliance may include fines, product withdrawals, sales bans, and reputational damage.

While enforcement approaches may vary nationally, the underlying compliance obligations do not. Businesses should not assume that operating in multiple EU markets allows for selective compliance or regulatory arbitrage.

Market surveillance authorities are expected to increasingly rely on documentation audits and digital data access, making poor recordkeeping a primary enforcement risk.

Practical Steps to Prepare for PPWR

Preparation for PPWR compliance should begin well before August 2026. Companies should start by identifying all packaging placed on the EU market and mapping applicable regulatory requirements by material and use case.

For in-scope businesses, supply chain engagement is critical. Packaging suppliers must be able to provide recyclability assessments, recycled content verification, and supporting technical documentation. Internal processes for conformity assessment, record retention, and regulatory monitoring must also be established or updated.

Early action allows businesses to integrate PPWR requirements into broader sustainability, ESG, and product compliance strategies, rather than treating them as a last-minute regulatory burden.

Frequently Asked Questions

What Counts as Packaging? 

Packaging under the PPWR includes any material used to contain, protect, handle, deliver, or present goods, regardless of the material or intended disposal route. This includes packaging used in transport, retail, and e-commerce contexts

Does the PPWR Apply to Packaging Not Manufactured in the EU? 

The regulation applies even if packaging is manufactured outside the EU, provided the packaged product is placed on the EU market. Responsibility rests with the economic operator placing the product on the market.

How Do Digital Labels Work? 

Digital labels function as a complement to physical labeling, providing structured compliance and material information through standardized digital systems accessible to regulators and waste operators.

Stay Ahead of Regulatory Compliance With Top Compliance Software

The EU’s Packaging and Packaging Waste Regulation is not a minor regulatory update. Rather, it represents a critical structural shift in how packaging is regulated, designed, and financed across the EU market.

For businesses, strategic, proactive compliance is not only about avoiding penalties. It’s about securing long-term market access, managing compliance costs, and positioning products within an increasingly sustainability-driven regulatory environment. Companies that act early will be better equipped to adapt, innovate, and compete as the PPWR reshapes the European packaging landscape. 

Businesses determined to remain compliant—and competitive—within a shifting EU marketplace can obtain significant value from compliance software Z2Data. The tool helps companies achieve compliance with over 180 major global regulations, including REACH, RoHS, EUDR, California Prop 65, the EU Battery Regulation, and many more. Z2Data’s expert compliance team carries out due diligence for customer supply chains, and then executes comprehensive risk analysis, helping businesses develop a meticulous understanding of their compliance risk exposure. 

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