Frequently asked questions

The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, is a European Union regulation aimed at reducing packaging waste and increasing recycling and re-use across all Member States. It replaces the Packaging and Packaging Waste Directive (PPWD), Directive 94/62/EC, which was repealed with effect from 12 August 2026, and introduces uniform rules and targets for packaging reduction, recycling, and re-use.

The PPWR is a regulation, meaning it is directly applicable and enforceable in all EU Member States without transposition into national law. In contrast, the Packaging and Packaging Waste Directive (PPWD) set objectives that each Member State transposed into national legislation, which resulted in differing requirements across the EU.

No, the PPWR does not fully harmonise all requirements. The PPWR sets uniform rules across the EU on packaging sustainability requirements, including recyclability, recycled content, minimisation, substance restrictions and labelling. However, Extended Producer Responsibility (EPR) schemes, producer registration and Deposit Return Systems (DRS) continue to be organised at Member State level, within common minimum requirements set by the PPWR.

National EPR fee structures, including the bonus and penalty schemes applied in countries such as the Netherlands and Spain, remain set at Member State level, including fee categorisation and pricing. Under the PPWR, EPR fee modulation is to be based on the recyclability performance grades once the relevant criteria apply.

The PPWR requires Member States to reduce packaging waste generated per capita by 5% by 2030, 10% by 2035, and 15% by 2040, compared with 2018. Recycling targets for all packaging waste are set at 65% by weight by the end of 2025 and 70% by the end of 2030, with material-specific targets. From 1 January 2030, or three years after the adoption of the implementing act on the calculation methodology, whichever is later, the plastic part of packaging must contain minimum recycled content: 30% for contact-sensitive packaging made from PET, 10% for contact-sensitive packaging made from other plastics, 30% for single-use plastic beverage bottles and 35% for other plastic packaging. These thresholds rise to 50%, 25%, 65% and 65% respectively from 1 January 2040. Re-use targets for transport, grouped and beverage packaging apply from 1 January 2030.

An overview of key targets will soon be published for our Recycling Intelligence Platform subscribers, split by the 19 packaging formats we currently cover.

The PPWR entered into force on 11 February 2025 and has applied since 12 August 2026, with targets and requirements phased in through to 2040. Key dates include 12 August 2026 (restrictions on PFAS in food-contact packaging), 12 August 2028 (harmonised material composition labelling, subject to the adoption of the relevant implementing act), 1 January 2029 (mandatory DRS), 1 January 2030 (recyclability, recycled content, minimisation and re-use requirements, and restrictions on certain packaging formats), 1 January 2035 (recycled-at-scale requirement) and 1 January 2040 (higher recycled content and re-use targets).

Several application dates depend on the adoption of implementing and delegated acts by the European Commission. As of October 2026, the implementing acts on the format for producer registers (Article 44) and on harmonised labels (Articles 12 and 13) had not been adopted. This section will be updated upon their adoption.

Almost all provisions of the PPWR are aimed at the reduction of packaging waste and the improved management of materials placed on the market.

The PPWR introduces harmonised Design for Recycling (D4R) criteria, to be set out in delegated acts due by 1 January 2028, which assign packaging a recyclability performance grade (A, B or C). From 1 January 2030, packaging must achieve at least grade C, and from 1 January 2038 at least grade B. It also introduces the recycled-at-scale requirement, applicable from 1 January 2035, under which packaging must be collected, sorted and recycled in sufficient quantities through existing infrastructure. The PPWR additionally establishes minimum recycled content thresholds for plastic packaging, EPR fee modulation based on recyclability, and mandatory DRS by 1 January 2029 for single-use plastic beverage bottles and single-use metal beverage containers of up to three litres, with exemptions available to Member States meeting specified separate collection rates.

Businesses must comply with requirements on packaging design, including recyclability, recycled content, minimisation, re-use and labelling. Obligations already applicable since 12 August 2026 include restrictions on PFAS in food-contact packaging, conformity assessment, technical documentation and the EU declaration of conformity, and the appointment of an authorised representative for EPR in Member States where a producer is not established (Article 45(3)). The European Commission has proposed suspending the Article 45(3) requirement until 1 January 2035 (COM(2025) 982); as of October 2026, this proposal had not been adopted.

Member States are required to lay down rules on penalties for infringements by 12 February 2027. Packaging that does not comply with the PPWR may not be placed on the EU market.

The PPWR sets requirements that all packaging must meet from 1 January 2030, including a minimum recyclability performance grade of C (at least 70% recyclability), rising to grade B (at least 80%) from 1 January 2038, and, from 1 January 2035, the recycled-at-scale requirement. Packaging not meeting these minimum thresholds may not be placed on the EU market.

The Design for Recycling criteria are to be adopted through delegated acts by 1 January 2028, and the recycled-at-scale methodology through implementing acts by 1 January 2030. CIRCPACK provides forecasts of packaging performance against the requirements applicable in 2030, 2035, and beyond.

This is based on Veolia’s recycling operations, collaboration with industry groups such as RecyClass, and CIRCPACK’s freely available Design for Recycling (D4R) guidelines, providing insights to support preparation for upcoming standards.

CIRCPACK certification experts can be contacted via email, or on the CIRCPACK website, for a free consultation.

Certain types of packaging are exempt from specific PPWR requirements. The recyclability requirements do not apply to immediate packaging of medicinal products for human and veterinary use, contact-sensitive plastic packaging of medical devices and in vitro diagnostic medical devices, contact-sensitive plastic packaging of infant formula and food for special medical purposes, transport packaging for dangerous goods, and sales packaging made of lightweight wood, cork, textile, rubber, ceramic or porcelain. Comparable exemptions apply to the recycled content requirements. These exemptions are limited to the requirements specified, and exempted packaging remains subject to all other applicable obligations.

For example, packaging exempted from the recyclability requirements remains subject to EPR obligations, including the payment of EPR fees.

The PPWR introduces a harmonised label indicating the material composition of packaging, applicable from 12 August 2028 or 24 months after the adoption of the relevant implementing act, whichever is later, to support correct waste sorting. This applies alongside Directive (EU) 2024/825 on empowering consumers for the green transition, which applies from 27 September 2026 and restricts generic environmental claims and unverified sustainability labels.

The regulation also establishes re-use and refill obligations. From 12 February 2027, final distributors in the hotel, restaurant and catering (HORECA) sector must allow consumers to bring their own containers for takeaway food and beverages, and from 12 February 2028 they must offer takeaway food and beverages in re-usable packaging.

The PPWR forms part of the EU’s strategy for the transition to a circular economy, aimed at reducing reliance on virgin materials, minimising waste, and increasing re-use and recycling across the packaging value chain.

The full text of the regulation is available on EUR-Lex. The European Commission adopted a non-binding guidance notice on the interpretation of the PPWR on 5 June 2026 (C(2026) 3702).

CIRCPACK experts can be contacted for questions relating to the PPWR and its implications or requirements. Answers are provided from both an operational and a regulatory perspective, including on requirements still subject to implementing and delegated acts.