PPWR – What’s changing for packaging

The Packaging and Packaging Waste Regulation (PPWR) has been in force since the start of 2025 and will apply directly in all EU Member States from 12 August 2026.  

As an EU regulation, it replaces the previous Packaging Directive and large parts of national regulations. In future, companies must document and label packaging in much greater detail and demonstrably optimise it in line with sustainability criteria.

The PPWR pursues four key objectives

Reducing packaging waste

Increase recyclability

Increase the use of recycled materials

Establishing reuse rates


The implementation of the PPWR will take place over a longer period, meaning that not all requirements need to be met from the outset. But don’t wait – better start now! 
A particular challenge: many technical details will not be clarified until 2027–2028 through delegated acts.  

The diagram below shows which requirements come into effect and when.

DATETo-Do
February 11, 2025
  • Entry into force of the PPWR
From August 12, 2026
  • Declaration of conformity (Art. 39)
  • Identification marking (Art. 15 (5)) type, batch, serial number
  • Manufacturer (Art. 15 (6)) name, trade name, tradename, address, email, …
  • Substances (Art. 5)
From Aufust, 2028
  • Labeling requirement (Art. 12) material & sorting instructions via pictograms
From 2030
  • Only packaging with a minimum recyclability of 70% may be placed on the market
  • Performance levels A, B & C count
  • Use of recycled content quotas for plastic packaging
  • Minimization of packaging, empty space regulation
  • Ban on certain types of packaging
  • Reuse targets
  • 5% reduction in packaging waste
2035
  • Level A, B & C in recyclability and Recycled at Scale (RaS)
  • 10% reduction in packaging waste
2038
  • Only grades A & B permitted for recyclability (at least 80%)
2040
  • Tightening of minimum recycled content quotas for KS packaging
  • 15% reduction in packaging waste

The obligations arising for companies under the PPWR depend on the type of packaging, the role of the market participant, the material and the product to be packaged (food/non-food).

The distribution or roles

Who is who in terms of the PPWR

ROLEDESCRIPTIONOBLIGATIONS
SupplierPerson who supplies packaging or packaging material to a manufacturer.Information and documentation obligation: provide the manufacturer with all information/documents required to demonstrate compliance, in a comprehensible and appropriate form (paper/electronic).
ManufacturerAny person who manufactures packaging or packaged products. This is usually the person who develops or manufactures packaging or packaged products under their own name or brand, regardless of whether other brands are also visible on the packaging or product . 
  • Only place compliant packaging on the market (in accordance with Articles 5 - 12)
  • Packaging labeling: Type/batch/serial number, name/address/contact details
  • Create a declaration of conformity and technical documentation, retain for at least 5 years
ProducerAny manufacturer, importer, or distributor who makes packaging (or packaged products) available for the first time in the territory of a Member State (including e - commerce) or unpacks packaged products without being the end user.
  • Registration obligation in each Member State where the packaging is made available or unpacked for the first time and where the packaging becomes waste.
  • Assumption of extended producer responsibility – payment of EPR fees.
DistributorPerson in the supply chain who resells packaging or packaged products in the EU, except for manufacturers or importers.

Check whether

  • Entry in the producer register exists (EPR obligation)
  • Declaration of conformity or technical documentation exists
  • Labeling obligation is fulfilled
  • Do not place non-compliant packaging on the market
  • In case of suspicion: Obligation to report to market surveillance authorities
     
ImporteurA person established in the Union who places packaging or packaged products from a third country (non - EU) on the market.
  • Only place compliant packaging on the market (in accordance with Articles 5 - 12)
  • Ensure that declaration of conformity and technical documentation are available
  • Labeling in accordance with Art. 12 must be available
  • If in doubt: do not place on the market

Each economical operator must therefore define their role/s and obligations. 

Declaration of conformity

Relevant PPWR articles (5–12)

From 12 August 2026, a declaration of conformity will be required for every type of packaging placed on the market for the first time. 
It is based on a formal conformity assessment procedure and must demonstrate compliance with all relevant articles of the PPWR (5–12).

The declaration of conformity must be drawn up by either the producer, manufacturer or importer. 
As a packaging manufacturer, we merely supply data for the packaging produced to customer order (regardless of whether it is printed or unprinted).

ArticleSubject areaRequirements for conformityKey dates
Art. 5Substances in packagingMinimisation of substances of concern; restriction of heavy metals in packaging; compliance with PFAS limits for food contact packaging.from 12 August 2026
Art. 6RecyclabilityPackaging must be recyclable and classified into recyclability classes.
  • Classes A–C from 1 January 2030
  • A–B only from 1 January 2038
Art. 7Recycled content in plastic packagingMinimum recycled content in plastic packaging depending on packaging category.
  • 10–35 % from 1 January 2030
  • 25–65 % from 1 January 2040
Art. 8Bio-based raw materialsReview and possible regulation of the use of bio-based raw materials in plastic packaging.Assessment by the European Commission by 12 February 2028
Art. 9Compostable packagingCertain packaging or labels must be industrially compostable.from 12 February 2028
Art. 10Minimisation of packagingThe weight and volume of packaging must be reduced to the minimum necessary for its function.from 1 January 2030
Art. 11Reusable packagingRequirements for reuse and refilling; Labelling and minimum circulation figures.Legal act valid until 12 February 2027
Art. 12LabellingHarmonised labelling regarding material, recyclability, compostability and, where applicable, reusability.
  • Details by 12 August 2026
  • Labelling requirement from 12 August 2028

We support you on your journey towards compliant packaging!

Best practice

Our aim is to continuously improve the recyclability of the product packaging we produce and maximise its recoverability. We seek alternatives for non-paper components or eliminate them entirely. See our practical examples here:


High-quality material recovery is our top priority. 
Assessment is currently carried out in accordance with legal and industry standards, such as the 95/5 rule. 

Where you should start now

Put your portfolio to the test

Are all your packaging and packaging components really necessary to protect products, ensure efficient logistics and communicate product characteristics?


Design for recycling is the top priority

If packaging is recyclable and its collection, sorting and recycling systems are in place, the foundation has been laid.


Data quality is decisive

Whether minimum standard, digital product passport or PPWR - every regulation is based on data that must be provided and networked by companies throughout the entire supply chain.


Standards make life easier

Whether calculating CO2 or assessing recyclability - defined methods, parameters and tolerances are required for solutions to be compared. Where these are missing, implementation is difficult.


Don't wait and see, get started!

Packaging is becoming a top priority. Not only does it embody the brand, it must also be compliant so that the products can continue to be placed on the market.

How we can support you

PERFORMANCE BASED DEVELOPMENT

Our developments are based on technical specifications and many years of experience from our development database. Technical specifications are essential for developing packaging that is as effective and efficient as possible. This applies to performance values such as BCT, ECT and Cobb value, as well as to application-specific barrier properties or recyclability.

RENEWABLE RECYCLED MATERIAL

Based on technical specifications, we determine the right material quality for the customer's requirements during the product development process. We focus on renewable raw materials, primarily wood fibres from responsible forestry (FSC® and PEFC™ certified), and we test alternative fibre sources such as grass, silphie, hemp, etc. We use paper and cardboard made from recycled fibres wherever possible and sensible.

MATERIAL EFFICIENCY | LIGHTWEIGHT

We select materials based on their technical values and save resources and CO2 with new papers and technologies. The focus is on using lightweight papers and custom flute profiles to achieve identical performance values with less material.

VOLUME OPTIMISATION

As much as necessary - as little as possible. This maxim guides us when developing custom packaging solutions. When it comes to volume optimisation, product protection and transport safety of the packaged goods are our top priorities.

DESIGN FOR RECYCLING

The aim is to maximise packaging and display recyclability and find alternatives for non-paper components or to eliminate them completely. High-quality material recycling via the recycling systems available throughout Europe is our top priority. We aim not only to use current state of the art technology but also to develop innovative solutions that extend today's possibilities.