EU Packaging Regulation (PPWR): What Buyers and Suppliers Need to Know
The PPWR has applied since 12 August 2026. What changed on that date, which milestones follow up to 2040, what is still under negotiation and what buyers should ask suppliers.
5 min czytania
The PPWR, the EU Packaging and Packaging Waste Regulation (EU) 2025/40, replaces the old packaging directive with one set of rules that applies directly in every member state. It entered into force on 11 February 2025 and has applied generally since 12 August 2026, with stricter requirements phased in up to 2040.
This overview explains what the PPWR means in practice for companies that buy or supply packaging. It is general information, not legal advice, so check the details for your own products with your supplier or an adviser.
What is the PPWR?
The regulation was published in the Official Journal on 22 January 2025. Because it is a regulation rather than a directive, the core rules do not have to be written into national law first. National authorities still run parts of the system, such as producer registers and extended producer responsibility (EPR) schemes.
The PPWR deals with packaging placed on the EU market, and some rules, such as the empty space limit, name grouped, transport and e-commerce packaging specifically. That makes it relevant for anyone who buys printed boxes, mailers, bags or display packaging, not only for large brands.
What has applied since 12 August 2026
Several obligations took effect on the general application date. According to compliance summaries of the text, these include:
- Substances in packaging: limits on PFAS in food contact packaging and on substances of concern, including the heavy metal limits.
- Conformity assessment: the rules on conformity assessment and the EU declaration of conformity in Articles 38 and 39 apply from 12 August 2026.
- Old directive repealed: Directive 94/62/EC is repealed from the same date, with a few transitional exceptions.
Is the PPWR delayed?
No. As of autumn 2026 the general application date stands. Some implementing acts, such as the formats for the harmonised labels, have run late, and the Commission has published interpretative guidance, but neither changes the legal date. A delegated decision in 2026 also exempted pallet packaging and straps from certain re-use requirements.
The authorised representative rule under negotiation
One change is still being negotiated, namely Article 45(3), which requires producers selling packaging directly to end users in another member state to appoint an authorised representative for EPR there. In December 2025 the Commission proposed suspending the rules on appointing an authorised representative for batteries and packaging. On 21 October 2026 the Council agreed its negotiating position, which would exempt producers placing less than 1 tonne of packaging a year on another member state's market. Until a final text is adopted, the existing rule applies.
PPWR timeline: the milestones up to 2040
Many requirements apply later, and some depend on detailed rules the Commission still has to adopt. The dates below are the earliest dates set in the regulation.
| Date | What applies |
|---|---|
| 12 August 2026 | General application, substance limits, declaration of conformity |
| 12 February 2028 | Rules for certain compostable packaging formats |
| 12 August 2028 | Harmonised labelling of packaging, at the earliest |
| 12 February 2029 | Labelling obligations for reusable packaging |
| 1 January 2030 | Minimisation, recyclability by design, minimum recycled content for plastic packaging |
| 1 January 2035 | Packaging must be recyclable at scale |
| 2038 to 2040 | Stricter recyclability grades, higher reuse and recycled content targets |
The dates follow the EUROPEN guide to the PPWR milestones and the European Circular Economy Stakeholder Platform.
Recyclability grades
From 2030, packaging is graded for recyclability, and packaging below grade C may not be placed on the market from 1 January 2030, or 24 months after the detailed criteria are adopted, whichever is later. The recitals of the regulation state that from 1 January 2038, packaging should be at least grade B.
Minimisation and empty space
Packaging minimisation requirements apply from 1 January 2030. For grouped, transport and e-commerce packaging, a maximum empty space ratio of 50 percent applies from 1 January 2030, or three years after the implementing rules, whichever is later.
What the PPWR means for packaging buyers
Buyers are increasingly asked by their own customers and authorities how their packaging complies. The easiest way to prepare is to ask the right questions in every request for quotation.
- Can you provide the EU declaration of conformity and technical documentation for this packaging?
- What recyclability grade do you expect for this design, and what would move it up a grade?
- Is there a lighter or smaller design with the same protection?
- For plastic: what recycled content can you offer today, and with what documentation?
- Can you deliver FSC or PEFC certified board where relevant?
For more questions to raise with your supplier, see sustainable packaging: what to ask your supplier. If you specify corrugated boxes, our guide to FEFCO codes helps you describe the box precisely.
Practical steps for buyers
Most of the heavy requirements land in 2030, but packaging changes take time to design, test and approve. A simple plan helps, for example along these lines:
- List the packaging you buy: item, material, supplier, yearly volume and the countries where it is sold.
- Ask each supplier for the declaration of conformity and the material composition of every item.
- Mark items that combine materials, use plastic or carry a lot of empty space, as these are the most likely to need changes.
- Plan redesigns with your suppliers well before 2030, so new formats can be tested and approved in good time.
- Keep the answers together, so you can show customers and authorities what you buy and why.
What the PPWR means for packaging suppliers
Suppliers who can answer these questions clearly are easier to choose. Prepare a short compliance pack for your main products: declaration of conformity, material composition, any certificates and your view on recyclability under the coming criteria.
If you sell packaging directly to end users in other member states, keep an eye on the authorised representative negotiations, because the outcome will decide whether you need a representative in each country.
PPWR questions in your Flobid request
On Flobid, buyers can set certificate requirements in a request for packaging, and only checked certificates are shown on supplier profiles. Read more about how Flobid approaches sustainability in sourcing.
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste, Official Journal of the European Union, EUR-Lex (2025)
- PPWR Text: Regulation (EU) 2025/40, 71 Articles, 13 Annexes, packagingregulation.org
- PPWR starts applying from 12 August 2026: a quick guide to what businesses need to know, EUROPEN (2026)
- The EU Packaging and Packaging Waste Regulation: when will it come into effect and what does it cover?, European Circular Economy Stakeholder Platform (2026)
- PPWR delayed? The verified answer, ppwr-packaging.com (2026)
- Proposal for a Regulation suspending the application of the rules on the appointment of an authorised representative, COM(2025) 982, EUR-Lex (2025)
- Council wants to exempt small packaging producers from the representative requirement, Lovguiden (2026)
Często zadawane pytania
When does the PPWR apply?
Regulation (EU) 2025/40 entered into force on 11 February 2025 and has applied generally since 12 August 2026, with further requirements phased in up to 2040.
Has the PPWR been postponed?
No. The general application date of 12 August 2026 stands. A separate proposal to suspend the rule on appointing an authorised representative for extended producer responsibility is still being negotiated.
Does the PPWR apply in every EU country?
Yes, as a regulation it applies directly in all member states, although extended producer responsibility schemes are still run nationally.