PPWR means that companies will have to treat packaging as a product subject to specific requirements concerning composition, design, recycling, labelling and documentation. However, the new obligations will not all apply at the same time. The Regulation applies from 12 August 2026, while some requirements will be introduced gradually by 2030, 2035 and 2040.
PPWR, meaning Regulation (EU) 2025/40 on packaging and packaging waste, applies to all packaging placed on the European Union market, regardless of material, product type or industry. It replaces the previous Directive 94/62/EC and is directly applicable in all Member States.
Do you not know which PPWR requirements apply to the packaging used in your company? Start by collecting information about its materials, design, intended use and suppliers. This will allow you to assess the scope of obligations and plan the necessary changes before ordering the next batch.
1. Why is PPWR important for businesses?
PPWR does not apply only to manufacturers of empty boxes, bottles or films. The obligations may also apply to companies that order packaging under their own brand, import products in packaging, sell them or make them available for the first time on the market of a given country.
One company may fulfil several roles at the same time. In practice, it is necessary to determine whether the company acts as:
- manufacturer,
- importer,
- distributor,
- producer within the meaning of extended producer responsibility,
- an entity using or filling packaging.
This is important because responsibility for packaging compliance may rest with a different entity than the obligation to register, report and finance packaging waste management. The European Commission explains that the manufacturer is responsible for the compliance of packaging with sustainability and labelling requirements, while the producer within the meaning of PPWR is primarily responsible for obligations related to packaging waste in a given country.
2. What requirements does PPWR introduce?
The new regulations cover the entire life cycle of packaging, from design and material selection to reuse or waste management.
| Area | What will change for companies? |
|---|---|
| Packaging composition | It will be necessary to control potentially hazardous substances, including heavy metals and PFAS |
| Recycling | Packaging will be assessed in terms of design for recycling and recyclability at scale |
| Recycled content | Some plastic packaging will have to contain a specified amount of recycled material |
| Minimisation | Packaging should have the lowest possible weight and volume, while still protecting the product |
| Labelling | Harmonised labels will be introduced, including information on material composition |
| Documentation | Packaging compliance will have to be demonstrated in technical documentation and an EU declaration of conformity |
3. PFAS substances and heavy metals
PPWR maintains the restriction on the total concentration of lead, cadmium, mercury and hexavalent chromium. As a rule, it must not exceed 100 mg/kg of the packaging or its components.
From 12 August 2026, restrictions will also apply to PFAS in packaging intended to come into contact with food. For companies, this may mean the need to obtain detailed information from suppliers about material composition and, in some cases, to carry out appropriate testing.
A supplier’s assurance that a material is “safe” or “eco-friendly” may not be sufficient. The document should clearly indicate the material, product, scope of assessment carried out and the results obtained.
4. Packaging must be designed with recycling in mind
From 2030, the recyclability of packaging will be assessed according to classes A, B or C. Packaging that does not meet class C requirements will not be allowed to be placed on the market, taking into account the exceptions and deadlines provided for, depending on the adoption of detailed implementing acts. From 2035, it will also be important whether a given type of packaging is actually recycled at scale.
Already at the design stage, it is worth checking:
- the number of materials used,
- whether individual elements can be separated,
- the type of labels, prints and adhesives,
- the colour and properties of the material,
- the availability of sorting and recycling technologies.
Packaging made from a material considered recyclable will not always be compliant. The problem may lie in the overall construction, material combinations or an element that makes sorting more difficult.
5. Less material and less empty space
PPWR requires the weight and volume of packaging to be limited to the level necessary to maintain its function, protect the product and meet legal requirements.
From 2030, the empty space ratio in grouped, transport and e-commerce packaging must not exceed 50%. Filling materials such as bubble wrap, air cushions or polystyrene are also considered empty space.
This does not mean that product protection should be abandoned. However, the company should be able to justify why a specific amount of material and free space is necessary.
6. New labels on packaging
PPWR provides for the introduction of harmonised labels informing about the material composition of packaging and how to handle the waste. The obligation is to apply from 12 August 2028 or 24 months after the entry into force of the relevant implementing act, if that date falls later.
It is therefore not worth creating markings now that are intended to imitate the future EU system. It is better to prepare space for the label, organise material data and monitor the publication of templates and detailed rules.
7. Technical documentation and EU declaration of conformity
PPWR introduces the obligation to carry out a conformity assessment of packaging. The manufacturer should prepare technical documentation and then draw up an EU declaration of conformity confirming compliance with the applicable requirements.
The documentation may include, among other things:
- description of the packaging and its intended use,
- drawings and material specifications,
- information from suppliers,
- results of analyses and tests,
- method of assessing recyclability,
- labelling,
- list of applicable requirements.
Before placing packaging on the market, the importer should check whether the assessment has been carried out, the documentation is available and the packaging has the required markings. The distributor should not make packaging available if they have reason to believe that it is non-compliant.
8. How to prepare your company for PPWR?
It is worth starting preparations with a simple audit:
- Prepare a list of the packaging used and its variants.
- Determine the company’s role for each packaging type and sales market.
- Collect material specifications and documents from suppliers.
- Check the composition, weight, volume and structure of the packaging.
- Assess which solutions may hinder recycling.
- Determine who will be responsible for documentation and the declaration of conformity.
- Plan changes before printing packaging and ordering a large batch.
Some detailed PPWR rules will still be specified in implementing acts, delegated acts and Commission guidelines. Therefore, compliance should not be treated as a one-time task.
How can RCC help?
RCC helps companies organise requirements related to products, materials and documentation. Analysis of the packaging, its application and the available information makes it possible to determine which PPWR requirements may apply and which actions should be planned first.
Do you use packaging but do not know whether your existing documentation will be sufficient? Send its description, photos and available materials to rcc@rcc.com.pl. We will help determine the next steps and prepare your company for the new obligations.