What’s so different?
The PPWR now applies: what’s different?
Key takeaways
Broader Applicability and Uniform Requirements
The PPWR applies to all packaging placed on the EU market, irrespective of material or origin, including packaging of imported products. As a regulation, it applies directly in all Member States, with requirements applying from set dates.
Supply Chain Adaptation
Recyclability and recycled content requirements apply from 2030. Meeting them requires changes to packaging design, materials and supplier arrangements ahead of the application dates.
Scrutiny of Environmental Claims
Directive (EU) 2024/825, applicable from 27 September 2026, prohibits generic environmental claims and sustainability labels not based on a certification scheme or established by public authorities. Environmental claims relating to packaging must be specific and verifiable.
Early Compliance
Packaging that does not meet the PPWR requirements by the applicable dates may not be placed on the EU market. Assessing packaging against the requirements before those dates reduces the risk of market exclusion.
The scope and application of the PPWR explained
The PPWR changes the regulatory framework for packaging in the EU through:
- its applicability to all packaging placed on the EU market, irrespective of material or origin, including packaging of imported products,
- the prohibition on placing non-compliant packaging on the EU market from specified dates,
- and the establishment of harmonised definitions and methodologies, including the recycled-at-scale requirement and harmonised Design for Recycling criteria.
As these requirements apply, the PPWR contributes to the EU’s circular economy objectives. CIRCPACK provides support with compliance throughout this process.
The PPWR and the repealed PPWD
The Packaging and Packaging Waste Directive (PPWD), Directive 94/62/EC, was the EU framework for packaging and packaging waste from 1994 until its repeal with effect from 12 August 2026. The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, entered into force on 11 February 2025 and has applied since 12 August 2026. The PPWR builds on the PPWD and sets more detailed requirements and targets for reducing packaging waste and improving the recyclability of packaging.
The PPWR also differs from the PPWD in its legal nature and scope. While the PPWD set foundational goals for packaging waste management, allowing Member States flexibility in implementation, the PPWR introduces a uniform and binding framework across the EU, with targets for recycling, packaging reduction, and re-use. The PPWR applies these rules directly in all Member States, addressing differences in national implementation of the PPWD.
Direct Applicability: A regulation is a binding legislative act that is directly applicable in all EU Member States from the date of application set out in it. It does not require transposition into national law; once a regulation applies, it is law across the EU.
Uniformity: Regulations apply the same rules in all Member States. This instrument is used where consistent legislation across the EU is required.
Example: The General Data Protection Regulation (GDPR) is a regulation, meaning the same data protection rules apply across all Member States without individual national legislation.
Require Transposition: A directive sets out objectives that all EU Member States must achieve, but allows each Member State to determine how to implement them in national law. Directives require transposition into national legislation by a specified deadline.
Variety in Implementation: Because Member States determine how directives are implemented, the means by which each Member State meets a directive’s objectives can differ.
Example: The Working Time Directive sets minimum standards for working hours across the EU, and each Member State implements it within its national labour law.
Key Topic One: Bans from the Market and Recyclability Claims
Production: Recyclability Requirements
From 1 January 2030, or 24 months after the entry into force of the design-for-recycling delegated acts, whichever is later, all packaging placed on the EU market must achieve at least recyclability performance grade C. From 1 January 2038, the minimum is grade B. These requirements affect the entire supply chain, from material suppliers to packaging manufacturers and fillers. The delegated acts are due to be adopted by 1 January 2028; the PPWR provides 24 months between their entry into force and the application of the recyclability requirements.
Strategic Implications
- Innovation in Materials: Meeting the recyclability thresholds may require new materials and technologies, including research and development of packaging solutions that are compliant and cost-effective.
- Supply Chain Adjustment: Incorporating new materials and processes into the supply chain requires coordination with suppliers, manufacturers, and recycling facilities.
- Regulatory Compliance: Compliance with the PPWR involves monitoring the adoption of implementing and delegated acts and adapting accordingly. Compliance frameworks reduce the risk of market exclusion.
Marketing: Environmental Claims Legislation
In parallel, Directive (EU) 2024/825 on empowering consumers for the green transition, which amends the Unfair Commercial Practices Directive (2005/29/EC), applies from 27 September 2026. It prohibits generic environmental claims that cannot be substantiated and sustainability labels not based on a certification scheme or established by public authorities. The proposed Green Claims Directive has not been adopted; in June 2025, the European Commission announced its intention to withdraw the proposal. This legislation restricts unsubstantiated statements about the recyclability and sustainability of products.
Strategic Implications
- Transparency and Accountability: Environmental claims about packaging must be clear, specific and substantiated.
- Consumer Protection: Misleading environmental claims constitute unfair commercial practices and may lead to penalties under national law.
- Substantiation of Claims: Recyclability claims supported by independent assessment or certification meet the substantiation requirements more readily than unverified statements.
Compliance and Certification
Under the PPWR, packaging recyclability is assessed against design-for-recycling criteria, with the recycled-at-scale requirement applying from 1 January 2035. CIRCPACK certification assesses the recyclability of packaging ahead of the adoption of the design-for-recycling delegated acts.
The certification process assesses packaging against current design-for-recycling standards, supporting the evaluation of the risk of market exclusion from 2030.
CIRCPACK certification combines laboratory testing with testing in Veolia facilities processing thousands of tonnes of waste on a daily basis, in order to assess packaging performance under real-world conditions.
Key Topic Two: Lead Times
The PPWR requirements apply in phases from 12 August 2026 to 2040. Repositioning packaging strategies, implementing new processes and ensuring compliance involve lead times that must be accounted for before each application date.
Comparable implementation timelines applied to the packaging Extended Producer Responsibility (EPR) data reporting obligations introduced in the United Kingdom from 2023.
Production lead times:
Adapting production lines to meet the PPWR recyclability requirements involves reconfiguring manufacturing processes to incorporate recyclable materials. This includes updating equipment, training personnel, and establishing new supply chains. These changes require investment and planning in advance of the 2030 and 2038 application dates.
Marketing and Communication requirements:
Changes to packaging also require updates to branding and marketing materials, including packaging artwork and consumer information. The harmonised material composition label applies from 12 August 2028, or 24 months after the adoption of the relevant implementing act, whichever is later, and requires changes to packaging labelling. Communication about the sustainability characteristics of packaging must comply with Directive (EU) 2024/825.
Key Topic Three: Uncertainty
While the PPWR sets baseline requirements, several details depend on implementing and delegated acts not yet adopted as of October 2026. These include the design-for-recycling criteria (delegated acts due by 1 January 2028), the recycled-at-scale methodology (due by 1 January 2030), the recycled content calculation methodology (due by 31 December 2026), the harmonised label specifications (due by 12 August 2026) and the format for producer registers (due by 12 February 2026). Several application dates are linked to the adoption of these acts.
Internal Processes: Preparing for Pending Requirements
Internally, companies must prepare for compliance while secondary legislation is pending. This involves planning packaging changes against the 2030, 2035 and 2038 application dates, securing contracts with recycled material suppliers, and establishing internal processes that can be adapted as the remaining acts are adopted.
- Timeline Management: Planning should be aligned with the application dates for recyclability (2030 and 2038), recycled content (2030 and 2040) and the recycled-at-scale requirement (2035).
- Supplier Contracts: Securing sources of recycled materials supports consistent supply and compliance with the recycled content requirements.
- Process Flexibility: Adaptable internal processes allow adjustment as the remaining implementing and delegated acts are adopted.
External Factors: Market Signalling and Early Compliance
Externally, companies can communicate their compliance status to the market, within the limits set by Directive (EU) 2024/825. Certification of packaging recyclability by providers such as CIRCPACK provides independent substantiation of recyclability for consumers and stakeholders.
- Market Signalling: Substantiated communication on compliance supports a company’s market position.
- Early Certification: Certification ahead of the application dates provides an assessment of packaging against future requirements.
Conclusion: Long-Term Strategic Benefits
Compliance with the PPWR requires planning against application dates, some of which depend on secondary legislation still pending. Investment in compliance ahead of these dates reduces the risk of penalties and market exclusion.
Sustainable Growth: Packaging designed to meet the 2030 and 2038 recyclability thresholds remains eligible for the EU market beyond those dates.
Risk Mitigation: Compliance ahead of the application dates reduces the risk of regulatory penalties and market exclusion.
Enhanced Reputation: Verified recyclability supports environmental claims that meet the substantiation requirements applicable from 27 September 2026.
