PPWR: obligations and deadlines

Summary

Regulation (EU) 2025/40 on packaging and packaging waste, usually called the PPWR, applies from 12 August 2026 (Article 71). It covers all packaging, whatever the material, and all packaging waste, whether it comes from industry, other manufacturing, retail, offices, services or households (Article 2(1)). Directive 94/62/EC was repealed from the same date, with a short list of provisions that stay in force for a transition, for example parts of Article 12 of the Directive until 31 December 2028 (Article 70(1)).

Not every obligation starts on that date. The limit of 100 mg/kg for the combined concentration of lead, cadmium, mercury and hexavalent chromium (Article 5(4)), the PFAS limits for food-contact packaging (Article 5(5)) and the duties of manufacturers, importers and distributors (Articles 15, 18 and 19) apply from the general application date. Requirements that change how packaging is designed, labelled, filled and reused arrive in steps between 2028 and 2040.

Many of those later steps are not fixed calendar dates. Packaging must be recyclable within grades A, B or C from 1 January 2030, or 24 months after the delegated acts on design-for-recycling criteria enter into force, whichever is later. The minimum recycled content in plastic packaging applies from 1 January 2030, or three years after the implementing act on the calculation method enters into force, whichever is later. The harmonised label applies from 12 August 2028, or 24 months after the implementing acts enter into force, whichever is later. In practice, each of these dates can move with the acts it depends on.

Penalties are set nationally. Member States must lay down penalty rules and notify the Commission by 12 February 2027, and breaches of Articles 24 to 29 must carry administrative fines (Article 68). The Regulation itself contains no fixed fine amount, so the exposure of a business depends on the Member State where the packaging is made available.

This page is built from the text of the Regulation as published in the Official Journal on 22 January 2025. It does not cover later corrigenda or amendments, which you should check in the consolidated version on EUR-Lex. Where a date depends on an act that we have not verified as adopted, the table says so.

Who and what is covered

The Regulation uses precise roles. Which obligations reach you depends on which of these you are, and one business can be several at once.

Packaging

An item, irrespective of material, that an economic operator intends to use for the containment, protection, handling, delivery or presentation of products to another economic operator or an end user. The definition includes service packaging and disposable items filled at the point of sale, as well as tea, coffee and other beverage bags and single-serve units that are disposed of with the product (Article 3(1), point 1).

Placing on the market

The first making available of packaging, empty or with a product, on the Union market. This matters because most conformity duties attach to the moment of placing on the market, not to every later sale.

Manufacturer

Anyone who manufactures packaging or a packaged product, and also anyone who has packaging or a packaged product designed or manufactured under its own name or trademark. A brand owner that outsources production is therefore a manufacturer. If that brand owner is a micro-enterprise and its supplier is established in the Union, the supplier is treated as the manufacturer.

Importer and distributor

An importer is established in the Union and places packaging from a third country on the market. A distributor is anyone else in the supply chain, other than the manufacturer or importer, that makes packaging available on the market. An importer or distributor that sells under its own name or trademark, or modifies packaging in a way that could affect conformity, is treated as a manufacturer (Article 21).

Producer (extended producer responsibility)

A different concept from the manufacturer. A producer is a manufacturer, importer or distributor that, in the situations listed in Article 3(1) point 15, first makes packaging or packaged products available in a Member State, or unpacks packaged products without being an end user. Producers have extended producer responsibility and must register (Articles 44 and 45).

Packaging formats

Sales packaging forms a sales unit with the product for the end user. Grouped packaging groups several sales units at the point of sale. Transport packaging eases handling and transport of one or more sales units, excluding road, rail, ship and air containers. E-commerce packaging is transport packaging used to deliver products sold online or by other distance sales. The empty-space limit and the re-use targets apply differently to these formats.

Relationship to other law

The Regulation applies without prejudice to the waste rules for hazardous waste, to Union requirements on the safety, quality, health and hygiene of packed products, and to transport rules. Where it conflicts with Directive 2008/68/EC on the transport of dangerous goods, that Directive prevails.

Obligations by article

Timeline of dates written into the Regulation

Dates are listed as the Regulation states them. The status of each date is calculated when you open the page.

11 February 2025

Entry into force

• Regulation enters into force. Packaging placed on the market from this date is considered reusable only if it meets the nine conditions of Article 11(1). (Article 71, 11)

12 August 2026

General application date

• Regulation applies; Directive 94/62/EC is repealed with transitional exceptions. (Article 71, 70(1))
• PFAS limits for food-contact packaging apply. (Article 5(5))
• Duties of manufacturers, importers and distributors apply. (Article 15 to 19)

31 December 2026

Commission deadline

• Commission to prepare a report on substances of concern in packaging. This is a Commission task, not a business obligation. (Article 5(2))
• Commission to adopt the implementing and delegated acts on recycled-content calculation, plastic recycling technology criteria and third-country equivalence. (Article 7(8) to 7(10))

12 February 2027

Deadlines

• Member States lay down penalty rules and notify the Commission. (Article 68)
• Packaging in an EPR scheme may be identified by a symbol in a QR code or other open digital marking. (Article 12(9))
• Commission delegated act on minimum rotations for reusable packaging. (Article 11(2))
• Commission guidelines explaining Annex V. (Article 25(6))

1 January 2028

Commission deadline

• Delegated acts on design-for-recycling criteria and recyclability grades are due. (Article 6(4))

12 February 2028

Deadlines

• Compostable packaging requirements and design for recycling of other packaging. (Article 9)
• Operators filling sales packaging reduce empty space to the minimum necessary; empty-space methodology act due. (Article 24(2), 24(4))

12 August 2028

Or 24 months after the implementing acts, whichever is later

• Harmonised sorting label with material composition applies. (Article 12(1))

1 January 2029

Or 24 months after the implementing act, whichever is later

• Recycled content must be calculated and verified under the Article 7(8) methodology. (Article 7(11))
• Member States ensure 90% separate collection of single-use plastic beverage bottles and metal beverage containers up to 3 litres through deposit and return systems. This is a Member State obligation. (Article 50)

12 February 2029

Or 30 months after the Article 12(6) act, whichever is later

• Reusable packaging carries a reusability label and a QR code or other open digital data carrier. (Article 12(2))

1 January 2030

Several, some tied to acts

• Recyclability grades A to C; recycled content minimums; packaging minimisation; 50% empty space limit; banned formats in Annex V; re-use targets. (Article 6, 7, 10, 24, 25, 29)
• Digital-marking methodology for substances of concern due; innovative-packaging derogation becomes available. (Article 12(7), 6(10))

1 January 2035

Or 5 years after the Article 6(5) acts, whichever is later

• Recycled-at-scale condition of the recyclability definition applies. (Article 6(2)(b))

1 January 2038

Fixed

• Packaging must be recyclable within grades A or B. (Article 6(3))

1 January 2040

Fixed

• Second-stage recycled content minimums for plastic packaging; endeavour targets for re-use of transport and grouped packaging and beverages. (Article 7(2), 29)

Exemptions that come up most often

Exemptions are written article by article. An exemption from Article 6 does not automatically remove you from Article 12, so check each article separately.

• Medicinal and veterinary medicinal products and medical devices: immediate packaging, contact-sensitive device packaging, and outer packaging of medicines where needed to preserve quality are excluded from several articles, including 6, 7 and 12.
• Contact-sensitive packaging for infant formula, processed cereal-based food, baby food and food for special medical purposes is excluded from the recyclability and recycled-content articles.
• Packaging used for the transport of dangerous goods is excluded from the recyclability, recycled-content and re-use articles.
• Sales packaging made from lightweight wood, cork, textile, rubber, ceramic, porcelain or wax is excluded from the recyclability requirement, though fee modulation under Article 6(8) still applies.
• Plastic parts under 5% of the weight of the packaging unit are excluded from the recycled-content minimums.
• Compostable plastic packaging is excluded from the recycled-content minimums.
• Packaging whose design is legally protected, or that holds a protected geographical indication or quality scheme product, can be excepted from the Article 10 rule against volume-increasing features.
• Micro-enterprises are not exempt as such. The Regulation shifts manufacturer duties to the EU supplier in defined cases and lets Member States allow some on-premises plastic formats where re-use infrastructure is not feasible.
• Final distributors with a sales area of 100 m2 or less are exempt from the beverage re-use target.
• Sales packaging used as e-commerce packaging is exempt from the 50% empty-space limit but must still meet Article 10.
• Producers placing less than 10 tonnes of packaging a year in a Member State may benefit from a reporting derogation under Article 44(8); the exact scope should be confirmed in the full text.

Acts that decide several dates

These Commission acts determine when parts of the Regulation take practical effect. We have not verified the adoption status of any of them.

• Implementing act on the methodology to calculate and verify recycled content (Article 7(8)). Due by 31 December 2026.
• Delegated act with sustainability criteria for plastic recycling technologies (Article 7(9)). Due by 31 December 2026.
• Implementing acts on the harmonised label and its specifications (Article 12(6)). Due by 12 August 2026.
• Implementing acts on digital marking of material composition (Article 12(7)). Due by 12 August 2026; the method for substances of concern is due by 1 January 2030.
• Delegated act on the minimum number of rotations for reusable packaging (Article 11(2)). Due by 12 February 2027.
• Commission guidelines explaining Annex V (Article 25(6)). Due by 12 February 2027.
• Delegated acts on design-for-recycling criteria and recyclability grades (Article 6(4)). Due by 1 January 2028.
• Implementing act on the empty space ratio methodology (Article 24(2)). Due by 12 February 2028.
• Implementing acts on the recycled-at-scale methodology and chain of custody (Article 6(5)). Due by 1 January 2030.
• Implementing act or acts on the register of producers (Article 44(14)). No due date was identified.

Where to start

This list is a practical suggestion, not wording taken from the Regulation.

1. Work out which of the roles above you hold for each product line: manufacturer, importer, distributor, producer, final distributor.
2. List your packaging by format (sales, grouped, transport, e-commerce) and by material, and mark everything that touches food.
3. For food-contact packaging, ask suppliers for PFAS evidence, because the limits apply from 12 August 2026.
4. Check whether you hold Annex VII technical documentation and an EU declaration of conformity for each packaging type, and how long you keep them.
5. Check producer registration and EPR duties in every Member State where you first make packaging or packaged products available.
6. Put the acts in the list above on a watch list and re-check the dates that depend on them.

PPWR Readiness Check

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Frequently asked questions

When does the PPWR apply?

Regulation (EU) 2025/40 applies from 12 August 2026 (Art 71). Many specific obligations start later (2028-2040) or depend on acts the Commission still has to adopt.

Who is affected by the PPWR?

Manufacturers, importers, distributors, brand owners, retailers, HORECA, e-commerce sellers and fulfilment providers, each with different duties.

Has the PPWR been postponed?

The text of the Regulation sets application from 12 August 2026. Claims of postponement or amendment must be checked against EUR-Lex before relying on them.

Sources

• Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, OJ L, 22.1.2025

Facts last checked against the Official Journal text on 6 November 2026.