Industries All industries
PPWR timeline: the packaging obligations landing between now and 2030
Regulation (EU) 2025/40 applies from August 12, 2026, and stacks most of its requirements on January 1, 2030. The timeline, and who carries each duty.
On this page
On August 12, 2026, Regulation (EU) 2025/40 on packaging and packaging waste, the PPWR (Packaging and Packaging Waste Regulation), becomes applicable in all 27 member states. It is a regulation, not a directive: it applies as written, without transposition, on the same day and in the same terms from Lisbon to Helsinki.
Adopted on December 19, 2024, published in the Official Journal on January 22, 2025, and in force since February 11, 2025, the text replaces Directive 94/62/EC, which dated from 1994. Its mechanics are easy to describe and demanding to live with. The text sets a general application date in 2026 and labeling milestones in 2028 and 2029, then stacks recyclability, recycled content, empty space limits, format bans, and the first reuse targets on January 1, 2030.
From August 12, 2026, every packaging type must prove its conformity
The application date is not a warm-up. From that day, a manufacturer may only place packaging on the EU market after checking it against the design requirements of Articles 5 to 12, drawing up the technical documentation of Annex VII, and issuing an EU declaration of conformity under Article 39.
Article 5 also bites immediately on substances. The combined concentration of lead, cadmium, mercury, and hexavalent chromium stays capped at 100 mg/kg, and food-contact packaging may no longer be placed on the market with PFAS (per- and polyfluoroalkyl substances) above the thresholds set in the article.
2028 and 2029 bring harmonized labels and deposit systems
The middle of the timeline belongs to information and collection:
| Deadline | What becomes mandatory | Article |
|---|---|---|
| Aug 12, 2026 | General application: declaration of conformity, technical file, PFAS and heavy-metal caps | Art. 5, 15, 39 |
| Feb 12, 2028 | Industrial compostability for the designated formats | Art. 9 |
| Aug 12, 2028 | Harmonized label on material composition | Art. 12 |
| Jan 1, 2029 | Separate collection of 90% of single-use plastic bottles and metal beverage containers | Art. 50 |
| Feb 12, 2029 | Label identifying reusable packaging | Art. 12 |
| Jan 1, 2030 | Recyclability grades and empty-space cap (at the earliest, see below), recycled content, format bans, reuse targets | Art. 6, 7, 10, 24, 25, 29 |
| Jan 1, 2035 | Packaging must also be recycled "at scale" | Art. 6 |
| Jan 1, 2038 | Grade C banned: grade A or B only | Art. 6 |
Two of these deserve a closer look. The material-composition label of Article 12 applies from August 12, 2028, or 24 months after the implementing act that defines it, whichever comes later; the reusability label follows on February 12, 2029. And by January 1, 2029, member states must collect separately 90% of single-use plastic bottles and metal beverage containers up to three liters, in practice through a deposit return system. A member state that already collected more than 80% of those containers in 2026 can be exempted, if it files a plan for reaching 90%.
January 1, 2030 carries most of the regulation
Five requirement families land on the same day.
Recyclability. Under Article 6, all packaging must be designed for recycling and graded A, B, or C. The grading applies from January 1, 2030, or 24 months after the delegated acts setting the criteria enter into force, whichever is later. Grade C remains acceptable until January 1, 2038, after which only A and B survive. From 2035 a second test is added: the packaging must actually be recycled at scale, not just be recyclable on paper.
Recycled content. Article 7 sets minimums for the plastic part of packaging: 30% for contact-sensitive packaging made mainly of PET (polyethylene terephthalate), 10% for contact-sensitive packaging in other plastics, 30% for single-use plastic beverage bottles, and 35% for other plastic packaging. The bottle target climbs to 65% in 2040.
Good to know: recycled content is assessed as an average per manufacturing plant and calendar year, not unit by unit. One batch below the threshold does not doom a product line; a site average below it does.
Minimization and empty space. Article 10 requires packaging to be reduced to the minimum weight and volume needed for its function. Article 24 puts a number on the most visible symptom: grouped, transport, and e-commerce packaging may not exceed a 50% empty space ratio, from January 1, 2030 or three years after the entry into force of the implementing acts setting the calculation method, whichever is later.
Banned formats. Article 25 and its Annex V remove several single-use plastic formats from the market: packaging for fresh fruit and vegetables under 1.5 kg, miniature toiletries under 50 ml or 100 g in hotels, single portions of condiments, sauces, sugar, or creamer served in cafés and restaurants, and collation films that bundle multipacks for convenience. Member states can carve out narrow exemptions, for hygiene or to prevent food spoilage.
Reuse. Article 29 sets the first binding targets: 40% of transport packaging used in reusable systems, and 10% of beverages made available in reusable packaging, rising to 40% in 2040.
Manufacturer, importer, distributor, producer: who carries what
The PPWR names four roles, and mid-sized companies often hold several at once.
The manufacturer (Article 15) carries the design obligations: conformity with Articles 5 to 12, the technical file, the declaration of conformity. The importer (Article 18) may not place non-conforming packaging on the market and must verify that a non-EU manufacturer has done the conformity work, keeping the documentation available for authorities. The distributor checks, before offering a product, that the producer is registered and the required markings are present.
The producer is the extended producer responsibility (EPR, REP in French) role, and it is not necessarily the factory. It is the operator that first makes the packaging available in a given member state, which for a brand selling across borders is usually the brand, not its supplier. The producer registers in the national producer register of Article 44 and pays fees modulated by, among other things, the packaging's recyclability grade. A brand that exports to five member states owns five registrations.
Most dates are fixed; part of the technical detail is not
As of February 2026, several pieces of secondary legislation are still expected: the delegated acts detailing the recyclability grades, the methodology for calculating recycled content, and the implementing acts defining the harmonized labels. Most of the deadlines above sit in the regulation itself and do not move. A few carry later-of backstops tied to those acts, the recyclability grading and the empty-space cap among them, so their January 1, 2030 date is the earliest one, not a guaranteed delay. Planning for 2030 remains the only safe reading.
Start from the portfolio, not the text: list your packaging types, assign each one its 2030 requirements, and identify per country which entity in your chain is the producer. The formats on shelves on January 1, 2030 are being designed now, and the registrations of August 2026 come first. These deadlines were verified in February 2026 against the text published in the Official Journal on January 22, 2025.
FAQ
Does the PPWR need to be transposed into national law?
No. Regulation (EU) 2025/40 is directly applicable in all 27 EU member states from August 12, 2026, with no national transposition. Member states only retain choices on limited points, such as how they organize deposit return systems and certain exemptions.
What happens to packaging graded C for recyclability?
Grade C packaging remains compliant from January 1, 2030 to December 31, 2037. From January 1, 2038, only packaging graded A or B may be placed on the EU market. From 2035, packaging must additionally be recycled at scale in practice.
Who is the producer under the PPWR?
The producer is the operator that first makes packaging or a packaged product available in a given member state, and it carries the extended producer responsibility obligations: registration in that state's producer register and payment of modulated fees. For a brand selling in several member states, the brand is usually the producer in each of them.
Which packaging formats are banned from January 1, 2030?
Annex V of the PPWR bans, among others, single-use plastic packaging for fresh fruit and vegetables under 1.5 kg, miniature toiletries under 50 ml or 100 g in hotels, single-use portions of condiments, sauces, sugar, and creamer in cafés and restaurants, and plastic collation films used to bundle multipacks. Member states may grant narrow exemptions for hygiene or food-safety reasons.
