PPWR: what does the new European Packaging Regulation mean for you?

What is the PPWR?

PPWR stands for Packaging and Packaging Waste Regulation, also known as the European Packaging Regulation. Its official name is Regulation (EU) 2025/40. The rules apply from 12 August 2026.

The PPWR replaces the old packaging directive (the PPWD) from 1994. That difference matters:

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  A directive first had to be transposed into national law by each country. That is why the rules in Germany were slightly different from those in France.

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  A regulation applies directly and is the same everywhere.

Do you supply to several European countries? Then that is good news. Fewer differences per country and more certainty up front.

Which packaging does the PPWR apply to?

To all packaging on the European market. Whatever the material, and wherever it comes from.

So not only the bag or the tray the consumer sees. Your outer case, your crate and your pallet hood are covered too.

What changes under the PPWR, and when?

From 12 August

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  Safer materials. Substances of concern must be reduced further. The focus is mainly on PFAS in food packaging and on heavy metals.

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  Proof on paper. Every packaging needs a technical file and an EU declaration of conformity. With those you show that the packaging complies.

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  Different roles in the chain. Manufacturer, importer, distributor and producer each have their own obligations. This also determines who pays for Extended Producer Responsibility (EPR). In the Netherlands this runs through Verpact.

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  Recyclability and minimisation. Packaging must meet the basic requirements for recyclability and minimisation. This was already set out in the PPWD. From 2030 the new, stricter requirements apply.

From 2028

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  One European sorting symbol. The same symbol on the packaging and on the waste bin.

From 2030

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  Only recyclable packaging may be placed on the market. From 2038 the requirements become stricter.

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  Mandatory recycled content in plastic packaging. Recyclate is recycled material. The minimum percentages rise further from 2040.

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  Less material, less waste. Minimisation: all packaging must be reduced to a minimum in weight and volume. Each country is also given strict targets to reduce packaging waste.

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  Banned applications. Some packaging is no longer allowed. The emphasis is on packaging in hospitality and accommodation.

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  Reuse targets. These apply to transport packaging, e-commerce, hospitality and take-away, among others.

On top of that, all countries must recycle more and better.

So 12 August 2026 is the starting point, not the finish line. The biggest changes to your packaging design arrive in 2030.

That seems far away. It is closer than you think. Switching materials often takes more time than expected. Think of processability tests, shelf life tests and sometimes adjustments to your packaging machines.

What is still unclear in the PPWR?

On 3 August 2026 the European Commission published an update of its frequently asked questions (FAQ). That helps, but on many points it remains unclear.

For some parts, the details will only follow in the years ahead. For example: when exactly is packaging recyclable? And how do you calculate the share of recycled content or reuse?

Good to know: the Commission is opting for a soft landing.

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  Do you not meet the rules? First comes a warning and the opportunity to put things right. Only after that will a member state take further measures.

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  Stock produced before 12 August but not yet placed on the market does not have to be destroyed.

Two open issues in the PPWR: PFAS and definitions

1. The PFAS protocol is not finished
   The limit values are fixed. The measurement method is not. There is no harmonised European test method yet.
   
   Our advice: use a risk analysis and assessment to show that the materials supplied comply. Think of:

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  Purchasing PFAS-free base material, or material guaranteed to stay below the limit;

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  working on clean machines and under clean conditions;

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  using food-safe lubricants

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  independent auditing of the quality system, for example through BRC, FSSC or ISO 9000;

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  validation through analyses on specific products.
2. The definitions are not yet precise
   When is something transport packaging, sales packaging or grouped packaging? That looks like a detail. Yet it determines:

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  who is subject to EPR;

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  who draws up the declaration of conformity;

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  Which rules apply.

In the FAQ of 3 August 2026 (second edition) the Commission explains that the manufacturer is the party with decisive control over design and specification. 

The EUNR (European National Registers) also published a statement. The EUNR is the network of sixteen national packaging registers. In short:

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  Packaging that only takes its final form during filling, and that is the case for much flexible film, comes into being at that moment;

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  Packaging that already exists empty in its final form (usually rigid formats) comes into being earlier in the chain.

These questions determine who registers, who reports and who pays.

The problem: other articles of the PPWR and the FAQ allow a different reading. Not helpful. Officially this change already takes effect on 12 August, including the possible shift of responsibilities. 

Several EPR organisations, including Verpact, have already announced that they are pressing pause on this. What that means is still unclear for all parties in the chain.

We are following this closely. We share what we learn, even when the answer is still “not yet known”.

How to prepare for the PPWR

1. Ask your supplier for the supporting technical documentation of the packaging components. As OPACKGROUP we are happy to support our customers with this.
2. Start on the declaration of conformity and complete the technical file. This is the responsibility of the manufacturer: the brand owner or the party that fills the packaging.
3. Agree together who has which role: manufacturer, supplier, importer or distributor. That also determines who pays the EPR fee.
4. Start now with the packaging that has to change by 2030. Count on a long lead time.
5. Take a critical look at weight, volume and empty space in your packaging

Continue the conversation at our seminar – 3 September

On 3 September and 26 November OPACKGROUP is hosting the seminar Sustainable Packaging. We take you through the PPWR obligations that already apply, look ahead to 2030 and discuss what this means in practice for your packaging. There is plenty of room for questions, including the difficult ones.

You can register via Register for the Sustainable Packaging seminar – 3 September The session on 3 September is fully booked, so you can put your name on the waiting list. You are very welcome on 26 November.

This article is a general explanation and not legal advice.