PPWR FAQ

PPWR stands for the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40). It creates a harmonised legal framework for packaging and packaging waste across the EU and replaces the previous Packaging and Packaging Waste Directive.

The regulation covers areas including recyclability, recycled content, packaging minimisation, substances of concern, labelling, reuse and extended producer responsibility.

PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026.

However, not all requirements apply from that date. Several important requirements are introduced progressively towards 2030 and beyond.

No. Some requirements apply from 12 August 2026, while others have later application dates or depend on further delegated or implementing acts.

For example, detailed Design for Recycling criteria, recycled-content requirements for plastic packaging and packaging minimisation are introduced later.

PPWR applies broadly to all packaging placed on the EU market, whether empty or filled and regardless of the material used.

This includes sales packaging, grouped packaging and transport packaging as well as packaging components. It applies both to packaging produced in the EU and packaging imported from outside the EU.

PPWR requires packaging to meet recyclability requirements, with limited exemptions.

Detailed Design for Recycling criteria are still being developed. The binding recyclability performance criteria will apply from 1 January 2030 or 24 months after the relevant delegated act enters into force, whichever is later. Further requirements concerning whether packaging is actually recycled at scale follow later.

No. PPWR does not generally require all packaging to be mono-material or all plastic packaging to be clear.

However, the complete packaging unit and its components will be considered when recyclability is assessed. Material combinations, colours, coatings and other design choices may therefore affect future recyclability performance.

The right solution still depends on the specific food, packaging application and required performance.

The requirements depend on whether the packaging is contact-sensitive and which polymer it is made from.

For contact-sensitive plastic packaging, the 2030 targets are 30% post-consumer recycled content for PET and 10% for plastics other than PET. For contact-sensitive PET, the target increases to 50% by 2040.

The first targets apply from 1 January 2030 or three years after the relevant implementing act enters into force, whichever is later.

From 1 January 2030, packaging must be designed so that its weight and volume are reduced to the minimum necessary to maintain its functionality.

This does not simply mean making packaging as light or small as possible. Product protection, food safety, filling and production requirements, logistics and other necessary functions must still be maintained.

PPWR does not introduce a blanket PFAS ban. Instead, it introduces maximum concentration limits for PFAS in food-contact packaging from 12 August 2026.

The limits apply to the packaging unit as a whole, including associated inks, varnishes, glues and adhesives, and apply to both intentionally added and unintentionally present PFAS.

No. PPWR does not introduce a general ban on single-use food packaging.

It does, however, restrict certain specific single-use packaging formats from 2030, including selected applications in retail and HoReCa. Further EU guidance is being developed on the exact formats covered and relevant exemptions.

Yes, for certain packaging types and sectors.

PPWR introduces reuse and refill requirements and targets, several of which apply from 2030. They do not apply equally to all food packaging, so the relevance needs to be assessed according to the packaging type, application and business model.

Yes. PPWR introduces harmonised labelling requirements intended to make packaging materials easier to identify and sort.

Detailed formats and implementation rules are being developed through implementing acts. Businesses should therefore follow the development of these rules when preparing future packaging designs.

Manufacturers have obligations relating to conformity assessment, technical documentation and the EU Declaration of Conformity for applicable PPWR requirements.

Suppliers must provide manufacturers with the information and documentation necessary to demonstrate conformity, while the manufacturer remains responsible for ensuring that the packaging it places on the market complies with the applicable requirements.

Plus Pack currently supports customers with relevant product information through our Supplier Information Statement, Technical Data Sheet and food-contact Declaration of Compliance. These documents are separate from the PPWR EU Declaration of Conformity.

Food producers need to understand their own role under PPWR as well as the requirements applying to the packaging they use.

Depending on how packaging is branded, specified and placed on the market, a food producer may itself be considered the manufacturer under PPWR. For example, a company that has packaging or a packaged product designed or manufactured under its own name or trademark may take on manufacturer responsibilities.

This makes access to reliable packaging data and supplier documentation particularly important.

Packaging distributors also have responsibilities under PPWR and need to understand their position in the supply chain.

Relevant product and compliance information must be available to support customers further down the value chain. Distributors may also have specific obligations if they become aware that packaging made available on the market is not compliant, and their role in relation to EPR may depend on how and where packaging is supplied.

Buying packaging from a supplier does not automatically mean that all PPWR responsibility sits with the supplier.

Responsibilities depend on the role of each economic operator. Suppliers must provide relevant technical information, while the manufacturer is responsible for ensuring conformity of the packaging it places on the market.

The exact allocation of responsibilities should therefore be assessed for the individual supply chain.

Yes.

PPWR harmonises certain EPR requirements and introduces a common framework for eco-modulation based on recyclability performance. However, it does not establish one common EPR fee across Europe, and Member States retain flexibility in how their national EPR systems operate.

Packaging design, recyclability, recycled content and other factors may therefore have a commercial impact, but a particular packaging change cannot automatically be assumed to deliver a specific EPR saving.

Not in every respect.

Several important requirements for 2030 still depend on delegated acts, implementing acts and detailed methodologies that are not yet finalised.

Packaging can be assessed against requirements already known today and developed with future requirements in mind, but certain aspects will need to be reassessed as the remaining rules are adopted.

Plus Pack helps customers turn PPWR requirements into practical packaging decisions.

We can support you with relevant product documentation, review existing packaging, discuss material and design options, explore recycled-content solutions and consider potential implications for future recyclability and EPR.

Whether you are a food producer, distributor or packaging buyer, the objective is to help you understand what matters for your packaging today, what to prepare for next and which options are relevant to your specific application.