Cooley’s Productwise Bitesize brings you a short introduction to the EU Packaging and Packaging Waste Regulation (PPWR), which starts to apply to all packaging and packaged products placed on the EU market from August 2026.
- Full name: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste
- Applies from: 12 August 2026, with longer transition periods for some requirements
- Where can I find it: Full text
What is it about?
The PPWR replaces the existing Packaging and Packaging Waste Directive (PPWD) and is intended to reduce divergence between the rules currently applicable in different EU Member States.
The PPWR introduces requirements applicable throughout the life cycle of packaging, including new rules on labelling, chemical content, claims, recyclability, reuse and reduction of packaging. It also further harmonises the rules on extended producer responsibility (EPR).
Who and what will it apply to?
The PPWR applies to:
- All packaging placed on the EU market and all packaging waste, regardless of the type of packaging or the material used. This includes sales packaging, packaging used in stores and transport packaging, irrespective of whether the packaging or packaged products are destined for businesses or consumers.
- Businesses involved in placing packaged products on the EU market, including EU and non-EU manufacturers, importers and distributors, all of whom will have compliance obligations under the new regime. The “manufacturer” does not need to be the company physically producing the packaging, so it is possible that your business is captured even if you are working with a third-party packaging supplier.
- Online platforms allowing traders to sell packaging or packaged products to EU consumers.
Overview of requirements
Key obligations in the PPWR include:
From 12 August 2026:
- Conformity assessment: Conduct a conformity assessment, draw up technical documentation, and retain it for five or 10 years depending on the type of packaging.
- Labelling: Label packaging with traceability information (manufacturer details, importer details, and type, batch, serial number or other element allowing identification). Additional labelling requirements will apply once the relevant implementing acts have been adopted.
- Substances of concern: Minimise the presence of substances of concern and comply with restrictions on heavy metal concentrations (lead, cadmium, mercury and hexavalent chromium) and, for food-contact packaging, with restrictions on the concentration of PFAS.
- EPR: Comply with EPR obligations, e.g. by engaging a producer responsibility organisation (PRO) and/or registering in the national producer register established by each Member State (insofar as established by 12 August 2026, with some EPR obligations, including reporting, applying later).
- Claims: Avoid misleading claims and comply with green claims requirements.
- Corrective action: Take corrective action in respect of noncompliant packaging and notify authorities of any noncompliance.
After 12 August 2026, at dates which vary depending on the specific obligations:
- Recyclability: Design packaging for recyclability. Recyclability criteria and performance grades are anticipated through forthcoming delegated acts.
- Recycled content: Ensure packaging meets minimum recycled content requirements. Implementing acts are expected to set out the methodology for the calculation and verification of the percentage of recycled content recovered from post-consumer plastic waste recycled and collected within the EU.
- Labelling: Label packaging with a harmonised label containing information on material composition and with standardised open digital-marking technologies providing information on substances of concern. Details are to be specified in implementing acts which will be adopted by the European Commission.
- Packaging minimisation: Minimise the weight and volume of packaging. Further details to be specified in implementing acts which will be adopted by the European Commission.
- Packaging formats: Phase out certain packaging formats (e.g. shrink wrap, single-use packaging for cosmetics, hygiene and toiletry products used in the accommodation sector, etc.).
- Reuse: Ensure at least 40% by 2030 and 70% by 2040 of transport packaging and/or sales packaging used for transportation is reusable packaging. Delegated acts are anticipated covering criteria for reusable packaging.
- EPR: Report to the national authorities or ensure the PRO does.
Why does it matter?
The PPWR introduces significant new obligations for businesses making packaging or packaged products available on the EU market, touching on sustainability, compliance, labelling and EPR. Noncompliance may limit the ability to sell packaged products in the EU and could expose businesses to regulatory risk across multiple EU Member States.
With the first requirements applying from August 2026, businesses should already have reviewed their packaging portfolios to identify compliance gaps, particularly in relation to substance restrictions, labelling requirements and EPR obligations.
In parallel, businesses should continue to monitor the development of secondary legislation, since many of the obligations will start to apply once implementing and delegated acts have been adopted, and integrate PPWR compliance considerations into ongoing packaging design and supplier engagement.
Is there any guidance?
Guidance and an FAQ to accompany the PPWR were published by the European Commission in March 2026. Further guidance is also anticipated, including guidelines on marks or labels likely to mislead or confuse consumers or end-users.
