PPWR Articles 6 and 7: future duties and exemption guide

Articles 6 and 7 matter for packaging design, but their core duties are future requirements, not current Gates in this tool. Keep them in the design roadmap; do not treat the exemption list as a task that must be completed for every material today.

When the duties start

• Article 6 recyclability: the 2030 performance-grade obligation starts on 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. Recyclability at scale follows in 2035.
• Article 7 recycled content: the minimum percentages start on 1 January 2030 or three years after the Article 7(8) implementing act enters into force, whichever is later.

The regulation as a whole applies from 12 August 2026, but that does not pull these later milestones forward. See the official text of Regulation (EU) 2025/40.

Article 6(11): recyclability exemptions

Article 6 does not apply in the same way to the categories below. The final category has an important limitation: Article 6(8) still applies.

1. Article 6(11)(a): immediate packaging for human and veterinary medicinal products.
2. Article 6(11)(b): contact-sensitive packaging for medical devices covered by Regulation (EU) 2017/745.
3. Article 6(11)(c): contact-sensitive packaging for in vitro diagnostic medical devices covered by Regulation (EU) 2017/746.
4. Article 6(11)(d): outer packaging needed to preserve the quality of medicinal products.
5. Article 6(11)(e): contact-sensitive packaging for infant formula, follow-on formula, processed cereal-based food, baby food, and food for special medical purposes under Regulation (EU) No 609/2013.
6. Article 6(11)(f): packaging used to transport dangerous goods under Directive 2008/68/EC.
7. Article 6(11)(g): sales packaging made from lightweight wood, cork, textile, rubber, ceramic, porcelain, or wax. This is not a complete exemption: Article 6(8) still applies.

Articles 7(4) and 7(5): recycled-content exemptions

The recycled-content minimums in Article 7(1) and 7(2) do not apply to the following categories:

1. Article 7(4)(a): immediate packaging for human and veterinary medicinal products.
2. Article 7(4)(b): contact-sensitive plastic packaging for medical devices, investigational devices, and devices used in performance studies under Regulation (EU) 2017/745.
3. Article 7(4)(c): contact-sensitive plastic packaging for in vitro diagnostic medical devices under Regulation (EU) 2017/746.
4. Article 7(4)(d): outer packaging needed to preserve the quality of medicinal products.
5. Article 7(4)(e): compostable plastic packaging.
6. Article 7(4)(f): packaging used to transport dangerous goods under Directive 2008/68/EC.
7. Article 7(4)(g): contact-sensitive plastic packaging for foods intended for infants and young children and for food for special medical purposes under Regulation (EU) No 609/2013.
8. Article 7(4)(h): packaging for supplies, components, and immediate packaging components used to manufacture medicinal products where medicinal-product quality standards require it.
9. Article 7(5)(a): plastic food-contact packaging where the recycled-content amount would endanger human health and cause non-compliance with Regulation (EC) No 1935/2004.
10. Article 7(5)(b): a plastic part representing less than 5% of the total weight of the packaging unit.

How to use this guide

Check these categories once at Case level when planning for 2030. Several depend on the product inside the packaging—such as medicines, medical devices, infant food, or dangerous goods—so this tool cannot infer them from material data alone. Confirm the classification and keep the supporting basis before relying on an exemption.

For Article 7(5)(b), calculate the percentage against the total packaging-unit weight, not just the plastic weight. Missing weight data is not evidence that the exemption applies.

This guide is planning information, not legal advice or an automatic exemption decision.