EU Regulation 2025/40 on packaging and packaging waste (PPWR) entered into force on 11 February 2025 and will apply progressively from 2025 to 2040. It replaces Directive 94/62/EC and introduces the most comprehensive overhaul of EU packaging law in 30 years.
Scope
The PPWR applies to all packaging placed on the EU market regardless of material, sector, or supply chain position. It covers primary (consumer), secondary (grouped), and tertiary (transport) packaging. Both EU-based producers and non-EU companies importing packaged goods into the EU are subject to the regulation.
Recycled Content Requirements (Article 7)
The PPWR introduces mandatory minimum recycled content thresholds for plastic packaging:
| Packaging Category | 2030 Target | 2040 Target |
|---|---|---|
| Contact-sensitive plastic (food, medical) | 10% | 25% |
| Single-use plastic beverage bottles (PET) | 30% | 65% |
| Single-use plastic beverage bottles (other) | 30% | 60% |
| Other plastic packaging | 30% | 50% |
Recycled content must be calculated using the mass balance method or physical segregation. Third-party verification is required for recycled content declarations.
Packaging Minimisation (Article 9)
All packaging must be designed to minimise its weight and volume to the minimum necessary to ensure functionality. Specific prohibited packaging formats include: packaging with unnecessary space (void space exceeding 40% for e-commerce); packaging with double walls, false bottoms, or other deceptive features; and packaging that is not technically necessary for product protection or hygiene.
Reusability Targets (Articles 26–29)
The PPWR introduces mandatory reusable packaging targets for specific sectors by 2030:
| Sector | 2030 Target | 2040 Target |
|---|---|---|
| Cold beverages (takeaway) | 20% reusable | 80% reusable |
| Hot beverages (takeaway) | 20% reusable | 80% reusable |
| Ready-prepared food (takeaway) | 10% reusable | 40% reusable |
| Transport packaging (grouped) | 50% reusable | 90% reusable |
| E-commerce outer packaging | 10% reusable | 50% reusable |
Recyclability Requirements (Article 6)
From 2030, all packaging placed on the EU market must be recyclable. From 2035, all packaging must be recycled at scale (i.e., recycling infrastructure must exist for the packaging format). The European Commission will establish recyclability assessment criteria through delegated acts.
Digital Product Passport (Article 11)
From 2028, packaging must carry a data carrier (QR code or similar) linking to a digital product passport containing: material composition; recycled content percentage; recyclability information; and instructions for consumer sorting and disposal.
Key Deadlines
| Requirement | Deadline |
|---|---|
| PPWR enters into force | 11 February 2025 |
| Prohibited packaging formats banned | 2027 |
| Digital product passport | 2028 |
| DRS mandatory in all member states | 2029 |
| Recycled content thresholds (Phase 1) | 2030 |
| Reusability targets (Phase 1) | 2030 |
| All packaging recyclable | 2030 |
| All packaging recycled at scale | 2035 |
| Recycled content thresholds (Phase 2) | 2040 |