What you need to know about Regulation (EU) 2025/40 (PPWR): A summary of obligations

To promote sustainability in packaging and waste reduction across the EU, the European Commission introduced a draft of the Packaging and Packaging Waste Regulation (PPWR) back in 2022. It is intended to harmonize regulations across the EU, offering clearer guidance for businesses and creating a consistent framework for packaging design, manufacturing, and waste management within the EU market.  

The final version—Regulation (EU) 2025/40—was officially published on January 22, 2025. The regulation came into effect on February 11, 2025, with its main provisions becoming applicable from August 12, 2026. However, the PPWR will be implemented in stages, with certain requirements taking effect gradually between 2026 and 2040.

The initial draft of the PPWR featured ambitious reuse and recyclability targets, many of which were scaled back following industry pushback. In its adopted form, the regulation shifts focus more strongly on recyclability and minimizing superfluous packaging, although certain reuse objectives are still retained. The main high-level objectives of PPWR can be separated into several areas:

1. Reduction of packaging waste  
2. Promotion of recycling  
3. Improvement of environmental compatibility  
4. Increase in transparency

Implementation stages of PPWR

The PPWR adopts a gradual implementation approach, allowing businesses sufficient time to adjust to the new set of requirements.

02/2025

• Entry into effect

08/2026  

• Regulation becomes applicable: Food-contact packaging with PFAS content above specific limits cannot be introduced on the market (Article 5).

2027

• Refill possibility for takeaway: Food service providers must give customers the choice to have beverages and ready-to-eat meals served in containers they bring themselves (Article 32).

2028

• Empty space in packaging must be reduced to a minimum whilst still maintaining product safety and usability (Article 24).

• Harmonized labeling will be introduced, stating material composition incl. percentage of recycled content or biobased plastic content (Article 12).

• Sticky labels must be compatible with the harmonized compostability standard in case of compostable packaging (Article 9).

2030

• All packaging should be recyclable or reusable in an economically feasible way. Packaging with a recyclability rate below 70% will no longer be considered recyclable and may not be placed on the market (Article 6&11).

• Minimum recycled content is introduced: 10-30% for contact sensitive packaging; 30% for single-use plastic beverage bottles; 35% for other plastic packaging (Article 7).

• Reuse targets for different transport packaging are implemented (Article 29).

2035

• Packaging must be recyclable on a large scale to promote a circular economy (Article 6).

2038

• Packaging should be at least grade B (recyclability rate of above 80%) to be eligible for the market (Article 6).  

2040

• Stricter norms on recycled content will be imposed, ranging from 25 to 65% based on the type of packaging and its intended use (Article 7). Reusability targets for different transport packaging will be higher – 70% reusability within the reuse system (Article 29).

What are the requirements to expect from PPWR?

The PPWR mainly targets producers as central stakeholders. According to the regulation’s definition of a producer, any entity placing packaged products on the market will be subject to its obligations.

Minimum recyclability  

A new recyclability grading system is being implemented, categorizing packaging into performance classes A, B, and C where:

• Grade A: ≥ 95% recyclable
• Grade B: ≥ 80% recyclable
• Grade C: ≥ 70% recyclable (per unit based on weight).

Starting in 2030, packaging that achieves less than 70% recyclability will be deemed non-recyclable and prohibited from being placed on the market. From 2038 onward, this restriction will expand to include class C packaging, defined as having a recyclability rate below 80%.

Minimum recycled content in plastic packaging

Starting from January 1, 2030, plastic packaging will be required to include a minimum amount of recycled material. This recycled content must come from post-consumer plastic waste (PCR) that has been collected and processed within the EU under the environmental and emissions standards of Directive 2010/75/EU, or in non-EU countries that uphold equivalent regulatory requirements. The thresholds of recycled content are as follows:

• Single-use plastic beverage bottles: recycled content 30% by 2030, increasing to 65% by 2040
• ‍Other contact-sensitive packaging primarily made of PET: recycled content 30% by 2030 and 50% by 2040
• ‍Contact-sensitive packaging made from plastics other than PET: recycled content 10% by 2030 and 25% by 2040
• ‍All other types of plastic packaging: recycled content 35% by 2030 and 65% by 2040.

Minimization of packaging

Packaging must be downsized to the minimum necessary dimensions to avoid material waste. This includes prohibiting features such as double walls, false bottoms, excess layers, and misleading designs. Article 24 of the PPWR also sets limits on empty space within packaging: secondary, transport, and shipping packaging must not contain more than 50% void space (including air and filler materials). Despite these restrictions, packaging must continue to fulfill essential criteria for product protection, logistics, functionality, hygiene, and safety.

Increased share of reusable packaging

From 2030, the following mandatory reuse rates will be established for certain packaging types (subject to certain exceptions):

• Beverage packaging: 10% (40% in 2040)
• Transport, sales, and e-commerce packaging: 40% (70% in 2040)
• Outer packaging: 10% (25% in 2040)

The exact method for calculating the reuse rates will be established by the European Commission by June 30, 2027.  

Food service providers will be obligated to allow customers to refill hot or cold drinks and ready-to-eat meals using their own containers. Responsibility for managing potential food safety liabilities will be delegated to individual EU member states, meaning that implementation details are still to be determined.

From February 12, 2028, takeaway food and beverages must also be made available in reusable packaging as part of an established reuse system. This reusable option must be offered under equal pricing and conditions, without penalizing the consumer.

Limiting hazardous substances in packaging

In terms of other substances of high concern, the PPWR upholds existing limitations on heavy metals as defined in Directive 94/62/EC. The total concentration of lead, cadmium, mercury, and hexavalent chromium must remain below 100 mg/kg.

Under the PPWR, new chemical safety standards for packaging - particularly for food contact materials - have been introduced. A key development is the prohibition of per- and polyfluoroalkyl substances (PFAS) in food-related packaging, effective from August 12, 2026. To meet compliance, packaging must not exceed the following PFAS thresholds:

• 25 parts per billion (ppb) for any single PFAS identified through targeted analysis
• 250 ppb as the combined limit for all PFAS identified through targeted analysis
• 50 parts per million (ppm) for total organic fluorine, serving as a marker for overall PFAS content.

With the PPWR’s final provisions approaching 2030, companies are under growing pressure to adapt. While the main requirements will begin to apply after an 18-month transition period in August 2026, unless delayed by specific clauses, building compliant, economically sustainable closed-loop systems may take years. This timeframe provides packaging producers with some flexibility, but early action is key to maintaining a competitive edge and benefiting from the changes ahead. Proactively aligning packaging design and production processes with the PPWR now can help businesses avoid disruptive last-minute adjustments and ensure long-term readiness.