What Is PPWR? Regulation (EU) 2025/40 — Requirements & Who Must Comply
The Packaging and Packaging Waste Regulation covers all packaging placed on the EU market. It has applied since 12 August 2026.
Short answer first, then the detail. If you only need to know whether it applies to you, the first two sections are enough.
A regulation, not a directive
PPWR — Regulation (EU) 2025/40 — replaces the old Packaging and Packaging Waste Directive. The difference matters: a directive has to be transposed into national law by each Member State, which is how twenty-seven slightly different packaging regimes came about. A regulation applies directly and identically everywhere. It entered into force on 12 February 2025 and has applied since 12 August 2026.
Who it applies to
Anyone who places packaging or packaged goods on the EU market: manufacturers, importers, brand owners, distributors and online sellers shipping into the EU. If you are outside the EU and sell to EU customers, the obligation lands on whoever imports the goods — and increasingly, marketplaces require you to prove it is handled before they let you list.
What it requires
Two documents sit at the centre: an EU Declaration of Conformity under Article 39, in the model set out in Annex VIII, and the Annex VII technical documentation produced under the Article 38 conformity assessment. What you declare against are the substantive requirements in Articles 5 to 12 — substances of concern (Article 5), recyclability (Article 6), recycled content in plastic (Article 7), minimisation (Article 10), labelling (Article 12). Around those sit registration in the national producer register (Article 44) and, for companies not established in the Member State, an authorised representative for EPR (Article 45).
What happens if you don't comply
PPWR leaves penalties to each Member State, so there is no single EU-wide figure — the amounts, and how aggressively they are applied, differ significantly between countries. What is uniform is the mechanism: market-surveillance authorities work through a warning, then required corrective action, and only then the Article 62 measures — prohibiting sale, withdrawal, or recall. In practice the commercial risk usually arrives before the regulator does: a customer, retailer or marketplace asks for your Declaration of Conformity and you do not have one.
What to do first
Establish which requirements apply to your specific packaging, then issue the declaration and assemble the technical file behind it. The free check below does the first step in three questions.
What the regulation has not decided yet
Several PPWR requirements apply in principle but wait on delegated or implementing acts before they can be assessed against a method — Article 6(4) for the design-for-recycling methodology and recyclability grades, Article 7(8) for the calculation and verification of recycled content, and Article 12(6) for harmonised labelling details. A technical file drawn up today records these as pending, with the reason: it cannot state a final conclusion the Commission has not enabled. A TD issued now cannot state a final PPWR recyclability grade. This matters when choosing a template — a form that lets you type a recyclability grade into it today is offering you a field the regulation has not defined.
Deadlines
The dates that decide your product range
PPWR is already in force. The requirements that reshape packaging design land in 2030 — which is a design cycle away, not a decade.
12 February 2025
Regulation entered into force
Regulation (EU) 2025/40 replaced the old Packaging and Packaging Waste Directive.
- Now
12 August 2026
PPWR applies
Packaging on the EU market needs a Declaration of Conformity (Article 39) and technical documentation (Article 38). PFAS above the limits are prohibited in food-contact packaging.
1 January 2030
Recycled content and reuse targets bite
Minimum recycled content in plastic packaging (Article 7) and at least 40% reuse for transport packaging (Article 29).
1 January 2040
Reuse targets step up
Transport packaging reuse rises to 70% (Article 29).
What you actually end up holding
Two documents, and how they relate
Article 38 wants a technical file. Article 39 wants a declaration. They are not two copies of the same thing: the declaration cites the file rather than repeating it, and it is issued to you unsigned.
Your role
Where you sit decides what you owe
The same packaging creates different obligations depending on your role in the chain. The free check works this out for you.
Importers
You place the goods on the EU market, so the declaration and the technical file are yours to hold — even when the packaging was designed by someone else.
Brand owners
You control the packaging spec, which means you control recyclability, recycled content and labelling. The design decisions are where compliance is won or lost.
Distributors
You have to verify that the producer is in the national register (Article 44) and that the packaging is labelled correctly before you pass it on.
Online sellers
Selling into the EU from outside it means an authorised representative for EPR in each Member State (Article 45) — the step most cross-border sellers miss entirely.
Common questions
See which of these apply to your packaging
The requirements above are the full set. Which ones actually apply to you depends on your packaging structure, materials, use and who manufactures it — that is a calculation, not a reading exercise.
Get your free PPWR compliance checklist