Specialist PPWR advice for manufacturers, brands and importers placing packaging on the EU market, inside or outside the EU. The regulation applies from 12 August 2026. We assess the portfolio, define the evidence each packaging type needs, and set up a file your team can maintain.
A declaration of conformity for all packaging, PFAS limits on food-contact packaging, heavy-metals limits and the duty to minimise substances of concern all begin on this date.
The PPWR is the EU's new packaging law, Regulation (EU) 2025/40. It replaces the old Packaging Directive and applies directly in every member state, with no national transposition needed. It covers every company that places packaged goods on the EU market, including importers and online sellers based outside the EU. Not everything starts at once, and the difference matters: several requirements are enforceable this August, and the rest give you years to plan.
These are the most immediate. The test is the date packaging is first made available on the EU market, not the date it was produced, so stock that has not yet been supplied has to meet them when it is.
Every packaging type needs a written EU declaration of conformity confirming that the regulation's requirements have been demonstrated. The manufacturer draws it up and takes responsibility for it, and it has to be kept current. A declaration that is missing or drawn up incorrectly is itself formal non-compliance, and the member state can require you to put an end to it.
Food-contact packaging may not be placed on the market at or above 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, or 50 ppm for PFAS including polymeric PFAS. If total fluorine comes back above 50 mg/kg, you have to be able to show authorities what that fluorine actually is.
The sum of lead, cadmium, mercury and hexavalent chromium in the packaging or any of its components may not exceed 100 mg/kg, and the presence of substances of concern has to be minimised. Compliance with this and with the PFAS limits must be demonstrated in your technical documentation, not simply asserted.
Preparation for these starts now and continues as your portfolio and the regulation change. Recyclability grades, recycled content and reuse depend on material, supplier and design decisions taken years before the dates apply.
Harmonised labels on material composition, to help consumers sort waste, apply from 12 August 2028, or 24 months after the Commission's implementing acts if that is later. Digital carriers such as QR codes will hold additional product and reuse information.
From 2028Packaging is graded A, B or C. From 1 January 2030, or 24 months after the design-for-recycling delegated acts if that is later, packaging must reach at least grade C. From 1 January 2038 it must reach grade B. The delegated acts setting the criteria are due by 1 January 2028.
From 2030From 1 January 2030, or 3 years after the Commission's implementing act if that is later, plastic packaging must contain minimum recycled content: 30% for contact-sensitive PET, 10% for other contact-sensitive plastics, 30% for single-use plastic beverage bottles and 35% for all other plastic packaging. The thresholds rise again in 2040.
From 2030From 1 January 2030, packaging must be designed to the minimum weight and volume needed for its function, justified against the Annex IV criteria. The 50% empty-space cap on grouped, transport and e-commerce packaging applies from 2030 at the earliest, and only once the Commission has set the calculation method.
From 2030Reuse targets cover sectors such as transport packaging and beverages. The duty to demonstrate you have met them starts 1 January 2030, or 18 months after the calculation methodology is in force if that is later.
From 2030Producers must register with the EPR scheme in each Member State where they place packaging, report volumes, and pay fees that are increasingly modulated by how recyclable the packaging is.
OngoingMost companies assemble PPWR from three suppliers: someone to read the regulation, someone to shape the strategy, and a tool to produce the declaration of conformity (DoC). All three are scoped together and run through one point of contact.
Clarify which entity carries the obligation, which markets and packaging types are in scope, which requirements apply, and where the priority gaps sit before any work is scoped.
Develop the evidence and documentation approach each packaging type needs, and the open decisions behind it, for review and signature by your authorised signatory.
Set governance, review points and update triggers as packaging and regulation change. Optional compliance software is recommended only where portfolio size and change frequency justify it.
Behind it, 20+ years across packaging design, materials and regulatory strategy, spanning brands, retailers and packaging-material suppliers, from structural development to portfolio-level implementation.
Early-stage brand, manufacturer that needs its file in place, or a business planning the years ahead, there is a way in. Every piece of work is fixed price, quoted after one call.
A focused briefing for your packaging or compliance team, on your portfolio and your deadline. You leave knowing which requirements apply to you, where your evidence gaps are, and what to do first. No long project to start it.
For smaller ranges that need to know exactly where they stand before the deadline, without a full portfolio review.
The full path to being ready for 12 August 2026. We check your packaging types, define the evidence each one needs, and support the technical documentation and declarations your team signs off. Kept current as your range changes.
We check your full portfolio against every requirement and when each one bites, so you are acting early instead of scrambling. Can run as ongoing support.
The regulation rolls out in phases from 2025 to 2040. These are the milestones that matter most.
The PPWR applies. Packaging must meet core requirements, backed by a declaration of conformity and technical documentation for each packaging type. Substance restrictions apply, including PFAS limits for food-contact packaging.
Harmonised labelling rules apply. Packaging must carry material-composition labels to help consumers sort waste.
Recyclability grades become binding and only packaging graded C or better may be sold. Minimum recycled-content targets for plastic packaging apply. Packaging must be designed to the minimum weight and volume needed, and the 50 percent empty-space limit for grouped, transport and e-commerce packaging applies. Reuse targets begin. These 2030 dates are conditional on the related delegated and implementing acts.
Packaging must be recycled at scale through real EU collection, sorting and recycling infrastructure (2035). Only packaging graded A or B may be placed on the market (2038). Higher recycled-content targets apply, reaching up to 65% for many plastic packaging types (2040).
Nine plain questions. Yes, no, or "I don't know." At the end you see exactly how much of your PPWR file you can actually stand behind today, and where the gaps are.
Every piece of work starts with your packaging portfolio and your deadline. We cover the full path to compliance and price it as fixed, not open-ended hours.
A structured review of your portfolio against the regulation, showing which packaging types fail which requirement, where the evidence is missing, and what to address first.
Technical documentation and EU declarations structured per packaging type for review and signature by your authorised signatory.
Design decisions that move packaging toward the higher recyclability grades and the minimisation criteria: formats, mono-material moves, adhesives, inks and closures.
Recycled-content sourcing and mass-balance options, plus PFAS, heavy-metal and substance-of-concern review for food-contact formats.
Material-composition and sorting information, QR-code and data-carrier preparation, so labelling is ready ahead of the 2028 requirements.
Producer registration, reporting and fee obligations across the EU markets where you place packaging, with guidance on keeping registrations current.
Ownership, revision triggers and practical sessions for packaging, procurement and quality teams, so compliance holds inside your organisation.
Your exposure depends on what you make and how you ship it. These are the sectors where it is sharpest.
Large SKU counts, fast launch cycles and multi-market labelling. The priority is getting your highest-volume packaging compliant first.
The hardest corner of the PPWR. PFAS limits on food-contact packaging from 2026, contact-sensitive recycled-content rules, and beverage-bottle targets.
Immediate packaging of medicines has specific exemptions, but secondary and transport packaging still must comply. Both sides need to be kept safe.
Hazardous-goods packaging, drums and transport packaging face minimisation, reuse and recyclability duties alongside existing transport rules.
High plastic shares and contact-sensitive formats mean real recycled-content and design-for-recycling pressure, without losing shelf performance.
The empty-space cap, right-sizing, and import responsibility for marketplace sellers. Here compliance and cost saving point in the same direction.
Also covered: cosmetics · electronics · pet food · logistics & transport packaging · contract packaging · private label
The PPWR is the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It sets binding rules for all packaging placed on the EU market, covering recyclability, recycled content, labelling, minimisation, reuse and restricted substances such as PFAS. It entered into force on 11 February 2025 and applies from 12 August 2026, replacing the earlier Packaging Directive 94/62/EC.
The core application date is 12 August 2026. From then, packaging must meet PPWR requirements and be supported by a declaration of conformity and technical documentation. Further duties follow in stages: harmonised labelling from 12 August 2028, recyclability grades and recycled-content targets from 2030, and stricter thresholds through 2038 and 2040.
Yes. The regulation applies to all packaging placed on the EU market, no matter where the company is based. Importers and non-EU sellers shipping packaged goods into the EU carry obligations, and non-compliant packaging can be refused at the border.
A PPWR consultant reviews your packaging portfolio, assesses it against the regulation, and builds a compliance plan. Typical work includes gap analysis, recyclability assessment, recycled-content and PFAS review for food-contact packaging, declarations of conformity, labelling preparation, and EPR registration.
Exposure differs by sector. Food and beverage companies face PFAS limits and contact-sensitive recycled-content rules. Pharma has specific exemptions. Chemical companies deal with hazardous-goods packaging. Sector experience shortens the path and avoids costly mistakes.
It depends on the size of your portfolio and the the work. Most companies start with a fixed-price declaration of conformity package for a defined set of packaging types, then expand if needed. Share your products and markets and you will get a clear scope and a fixed quote. The first orientation call is free.
Thirty minutes to identify your markets, packaging types, immediate exposure and evidence gaps, and the best place to start. Share your details below and you will get a reply within one business day.