EU Packaging Rules, PPWR in 2026: general information
Updated: 3 days ago
From Directive to Regulation: What's Changing
The EU has replaced the Packaging and Packaging Waste Directive (PPWD 94/62/EC) with the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40. It was published in the Official Journal on 22 January 2025, entered into force on 11 February 2025, and most of its provisions have applied since 12 August 2026.
Businesses importing goods into the EU must prepare for stricter sustainability requirements and tighter market access rules. Non-compliance can lead to market access problems, financial penalties set by national authorities, and brand damage. The rules focus on recyclability, recycled content, reuse, labelling clarity and extended producer responsibility (EPR).
Why the PPWD Was Introduced
The original directive aimed to bring consistency to packaging rules across the EU. It set minimum standards for packaging materials, recycling systems and waste management, helping member states move toward a more circular economy.
Why the PPWR Matters
The new regulation is a major upgrade. Unlike a directive, a regulation applies directly in every EU country without being transposed into national law. This means:
Harmonised technical rules on packaging design, recyclability, recycled content and labelling
Clearer expectations for businesses
More detailed technical requirements for packaging design
Some things remain national, however. EPR registration, fees, enforcement and penalties are still handled country by country, and national labelling schemes continue to apply until the harmonised label takes effect. Importers should treat the PPWR as a complete modernisation of EU packaging policy, but not as a single EU-wide compliance process.
What the EU Wants to Achieve
The updated framework focuses on:
Reducing packaging waste through better design
Increasing reuse and recycling rates
Restricting certain hazardous substances, such as PFAS in food-contact packaging
Supporting circular economy goals with consistent EU-wide technical rules
Who Must Comply
Almost all packaging used for products entering the EU market is covered, including:
Food and beverage packaging
Cosmetics and personal care packaging
Industrial and transport packaging
Packaging used for online retail shipments
The PPWR builds on earlier EU initiatives such as single-use plastic (SUP) restrictions and higher recycling targets.
Key Requirements from PPWR That Importers Need to Prepare For
Extended Producer Responsibility (EPR)
Importers are treated as "producers" in each EU Member State where they first make packaging or packaged products available. As a producer, you must:
Register with the national producer register, and typically with a producer responsibility organisation (PRO), in each country where you place packaging on the market
Report packaging by material and weight and pay national fees for collection and recycling. These fees are moving toward modulation based on recyclability
Maintain detailed documentation for audits
Non-EU sellers shipping directly to EU customers must also appoint an EPR authorised representative in each country where their packaging reaches end users. This requirement applies from 12 August 2026.
Recycled Content in Plastic Packaging
For the first time across most plastic packaging, EU law sets minimum post-consumer recycled (PCR) content. From 1 January 2030, the minimum for the plastic parts of packaging is:
35% for most plastic packaging
30% for contact-sensitive packaging made mainly of PET
10% for other contact-sensitive plastic packaging
These rise to 65%, 50% and 25% respectively by 2040. "Contact-sensitive" packaging includes packaging for food, cosmetics and other regulated product categories. Key details:
Only post-consumer recyclate counts. Post-industrial recyclate does not satisfy the targets.
The percentage is calculated as an average per manufacturing plant per year, and plastic parts under 5% of packaging weight are exempt.
The 2030 date is a floor. The targets apply from 1 January 2030 or three years after the calculation implementing act, whichever is later.
Recyclability and Design Requirements
The PPWR introduces technical rules so that packaging can be recycled effectively. Detailed design-for-recycling criteria and recyclability grades will be set through delegated acts due by 1 January 2028. In outline:
From 1 January 2030, or 24 months after those acts enter into force if that is later, packaging must reach at least grade C (70% recyclable by weight).
From 1 January 2038, only grades A and B will be allowed.
The regulation also requires packaging to be recyclable at scale from 2035, or later depending on the relevant implementing act.
Expect the criteria to look at mixed materials, adhesives, inks, coatings and labels, and how easily components can be separated and sorted. This may require redesigning packaging that contains multiple materials or heavy decoration. The full recyclability conformity assessment is not required until the delegated acts enter into force, but collecting evidence now will make it much easier later.
Minimisation, Empty Space and Restricted Formats
The PPWR requires that packaging weight and volume be limited to what is needed for function. Key points:
Empty space: Grouped, transport and e-commerce packaging is capped at a 50% empty space ratio from 1 January 2030, or three years after the calculation method act if that is later.
Perceived volume: Features that only make a product look bigger, such as double walls, false bottoms and unnecessary layers, are prohibited, with narrow exemptions. Guidance differs on exactly when this starts to apply, so confirm the timing in the regulation text.
Restricted formats: From 1 January 2030, certain single-use packaging formats may not be placed on the market, including some single-use plastic grouped packaging, small fresh fruit and vegetable packs, single-use packaging for on-premises food and drink in the HORECA sector, and single-use cosmetics and toiletries packaging in accommodation.
Reuse and Recycling Targets
The PPWR keeps the existing recycling targets and adds new reuse obligations. Recycling targets are set at Member State level, so for importers they matter mainly through design rules and EPR fees. The main reuse points are:
From 1 January 2030, at least 40% of transport packaging must be reusable within a formal reuse system. This covers e-commerce packaging too. Cardboard boxes are exempt, as are micro-enterprises placing under 1,000 kg of packaging a year in a market.
Takeaway providers must let customers bring their own containers from 12 February 2027, and offer a reusable option from 12 February 2028.
Importers should evaluate whether their current transport and e-commerce packaging formats can fit these requirements.
Unified Labelling
Today, recycling labels vary from country to country. Under the PPWR, the EU will introduce a single harmonised label showing material composition, with additional marking for reusable packaging. Key timing points:
The harmonised material-composition label applies from 12 August 2028, or 24 months after the labelling implementing acts enter into force, whichever is later. Those acts were due in August 2026 and had not been adopted at the time of writing.
Reusable packaging must additionally carry a reusability marking from 12 February 2029, on the same conditional basis.
Until the harmonised label applies, national schemes still apply.
Importers will need to update artwork once the final pictograms are published. You can reserve space now.
Gradual Rollout
The PPWR takes effect in stages. After entering into force in February 2025, most provisions have applied since 12 August 2026. Further requirements follow later:
2028: harmonised material labels (or later)
2030: recycled-content targets, first recyclability requirements, empty-space cap, restricted formats, transport packaging reuse target (some dates float depending on implementing acts)
2035: recyclable at scale (or later)
2038: only recyclability grades A and B
2040: higher recycled-content and reuse targets
How Importers and Manufacturers Will Be Affected
Industries Facing the Biggest Changes
Some sectors will feel the impact more strongly due to complex packaging:
Food and beverage: multilayer films, single-use formats
Cosmetics: multiple components and decorative packaging (see our dedicated cosmetics page for more information)
Electronics: protective packaging with mixed materials
E-commerce: high packaging volume and inconsistent formats
Supply Chain Implications
Importers may need to:
Switch to new materials or suppliers
Redesign packaging to meet recyclability, recycled-content and reuse rules
Implement internal compliance checks
Cost and Operational Impact
Compliance may involve:
Investing in recyclable, PCR-based or reusable materials
Testing packaging to verify recyclability
Tracking EPR fees and reporting obligations across multiple countries
EU-Wide Standards
Because the PPWR's design and product rules are harmonised, one compliant pack can generally be sold across the EU, which reduces the need for country-specific variants. Businesses still need to handle EPR registration, reporting and fees country by country, appoint authorised representatives where required, and manage existing national labels until the harmonised label applies. This can be challenging for businesses with diverse product lines or multiple suppliers.
How Cosmetic Brand Owners Can Prepare Now
1. Review All Cosmetic Packaging
Audit all packs you place on the EU market (bottles, jars, tubes, airless systems, droppers, compacts, outer cartons), regardless of which agent sourced them.
Ask your sourcing agent for full specs and samples. Flag multi-material, heavily decorated or low-recyclability items for redesign.
2. Work Closely With Your Sourcing Agent and Their Suppliers
Make sure your agent understands that your packaging is contact-sensitive and must meet PPWR recyclability and PCR requirements. Instruct them to collect material specs, PCR certificates (separating post-consumer from post-industrial content) and recyclability data from each factory as standard.
Update your contracts with the agent. Make PPWR compliance (design, PCR content and data provision) a non-negotiable part of the sourcing brief.
3. Organise EPR Compliance for Your Cosmetic Lines
Map where each cosmetic SKU is sold. Confirm that you, not the agent, are registered for packaging EPR in each relevant country. If you are a non-EU seller shipping directly to EU customers, you also need an authorised representative in each country.
Set up internal processes to capture packaging weights and materials from your agent's data. This lets you report accurately and use eco-modulated fees as a design signal, since more recyclable, PCR-rich packs should reduce long-term EPR costs.
4. Update Labels and Technical Documentation
Work out your role. If you place packaging on the market under your own name, or you fill it, you may be the PPWR "manufacturer" and must draw up the EU Declaration of Conformity and technical file. If you import packaging made by others, verify the manufacturer's documentation and keep copies. Either way, keep the master documentation in-house and use test reports and data provided via your agent.
Keep a file per packaging family with material specs for each component, PCR calculations and certificates, supplier declarations, and recyclability data.
Plan artwork for the harmonised EU labelling system, and reserve space for pictograms and, where relevant, a QR code. Make sure your agent's suppliers can print what you need once the formats are published.
5. Monitor Regulatory and Supplier Performance
Track updates on recyclability criteria, cosmetic-specific empty-space ratios (a tighter ratio for cosmetics packaging could be introduced later), PCR calculation methods and labelling implementing acts. Translate these into updated sourcing instructions for your agent.
Regularly review both the agent's performance and the underlying factories, focusing on packaging updates, documentation quality and audit readiness, especially as 2030 approaches and recycled-content deadlines tighten.
Helpful Practices
Standardise materials to simplify compliance
Use digital tools to track packaging data
Integrate compliance checks into product development
Consider third-party verification for recyclability claims
These steps help importers maintain EU market access and reduce regulatory risk. See our Made in Europe products.
© Norse Packaging
This blog is for informational purposes only and is not legal advice, so please consult a qualified professional about your specific situation.
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