Since 12 August 2026, the new Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied throughout the EU. It is the most comprehensive reform of European packaging law in decades. What does it mean for companies, and what needs to be done now? An overview.
Note: this article provides a general overview and is not legal advice. The text of the regulation and the supplementary legal acts of the European Commission are authoritative.
What is the PPWR?
The PPWR entered into force on 11 February 2025 and has applied directly in all member states since 12 August 2026. Unlike the previous EU Packaging Directive, it is a regulation. It therefore does not need to be transposed into national law first. National rules such as the German Packaging Act are being adapted to it. Its goal: less packaging waste, more recycling and more reuse.
What has applied since August 2026
- Declaration of conformity and technical documentation: manufacturers must be able to prove that their packaging meets the requirements of the regulation.
- Manufacturer identification: packaging must carry information that identifies the manufacturer and the packaging.
- Substance restrictions: limits apply to heavy metals in packaging. For food-contact packaging, limits for PFAS also apply.
- Producer responsibility: registration and participation in a compliance system remain mandatory. In Germany, this still runs via the LUCID packaging register. More in our article Packaging Act and LUCID.
Member states must set penalties for infringements by February 2027.
What follows in the coming years
- 2028: introduction of EU-wide harmonised labelling of material composition. It is intended to make correct disposal easier for consumers.
- 2030: packaging must in principle be recyclable and meet certain recyclability grades. Minimum recycled content applies to plastic packaging. Packaging must be minimised to the functionally necessary weight and volume. For transport, grouped and e-commerce packaging, the permitted empty space will be limited. In addition, there are reuse targets for certain types of packaging, such as transport packaging.
- From 2035 onwards: recycling requirements will be tightened further.
Many details will be specified in further legal acts by the European Commission. Keep an eye on these developments.
What does this mean for cardboard packaging?
For paper and board packaging, the PPWR is more of an opportunity. Mono-material cardboard packaging is well placed to meet the recycling requirements. Paper and board are not subject to recycled content quotas as plastic is. The main things to watch out for are:
- Large-area plastic lamination and hard-to-separate composites
- Unnecessarily large packaging with lots of empty space
- Superfluous packaging layers
- Complete documentation of the materials used
What companies should do now
- Take stock: record all the packaging you place on the market, with material, weight and size.
- Clarify your role: check whether you count as a manufacturer, importer or distributor. The obligations differ.
- Build documentation: keep material information and supplier evidence ready.
- Check recyclability: more in our article Recyclable packaging.
- Optimise packaging: reduce empty space, save material, prefer mono-material. More in our article How to reduce packaging material.
- Plan new packaging to be future-proof: take the 2030 requirements into account today.
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