PPWR timeline: the key dates to know

The European Organisation for Packaging and the Environment (Europen) has published a timeline of the EU’s Packaging and Packaging Waste Regulation requirements, including when they come into force, details of the Articles and recommendations for further guidance on provisions. We’ve taken a deep dive into the main points of the timeline, from requirements introduced in 2025 to those due to come into force in 2040.

2025 - 2026

Reusable packaging

To start with, Europen states that Article 11 of the PPWR establishes that from 11 February 2025, packaging placed on the market ‘shall be considered to be reusable’ where it fulfils all requirements listed in Article 11.

Substances in packaging

From 12^th August 2026, Article 5 establishes that the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components shall not exceed 100 mg/kg.

Also on the 12^th August 2026, Article 5 mandates that food contact packaging shall not be placed on the market if it contains PFAS in a concentration of or above certain given limits, including 25 ppb for any PFAS as measured with targeted PFAS analysis and 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors (with polymeric PFAS excluded from quantification).

The limits also include 50 ppm for PFASs (including polymeric PFAS). If the total fluorine exceeds 50 mg/kg, Europen says that upon request the manufacturer, importer or downstream user shall provide to the manufacturer or importer proof of the quantity of fluorine, measured as content of either PFAS or non-PFAS, in order for them to draw up the technical documentation referred to in Annex VII.

Europen notes that point 5 of the PPWR Guidance and Section III of the PPWR FAQ document provide helpful guidance on this provision.

2028 – 2029

Compostable packaging

By 12^th February 2028, Article 9 mandates that packaging referred to in Article 3, point 1 and sticky labels affixed to fruit and vegetables needs to be compatible with the standard for industrial composting in bio-waste treatment facilities and - where required by the Member States – be compatible with the home-composting standards referred to in paragraph 6 of Article 9.

Article 9 also establishes that packaging, including packaging made of biodegradable plastic polymers and other biodegradable materials (other than that referred to in paragraphs 1 and 2), shall be designed for material recycling in accordance with Article 6 without affecting the recyclability of other waste streams. Europen recommends point 10 of the PPWR Guidance and Section VI of the PPWR FAQ document for more guidance on these provisions.

Packaging labelling

From 12 August 2028 (or 24 months from the date of entry into force of the relevant implementing acts), Article 12 requires that packaging placed on the market shall be marked with a harmonized label containing information on its material composition to facilitate consumer sorting, and packaging subject to deposit and return systems (as referred to in Article 50) shall be marked with a clear and unambiguous label.

Packaging may also be marked with a harmonized colour label as well as the national label, established in the relevant implementing act adopted pursuant to Article 12. Packaging will also be marked with a label (and QR code, where applicable) containing information on the share of recycled content, complying with the specifications in the relevant implementing act and based on the methodology established pursuant to Article 7.

Labels containing information on the share of bio-based plastic content shall comply with specifications laid out in the relevant implementing act adopted pursuant to paragraph 6 of Article 12.

Europen states that from 12^th February 2029 (or 30 months from the date of entry into force of the relevant implementing act), Article 12 mandates that reusable packaging placed on the market has a label informing users that it is reusable, with further information made available through a QR code. Europen suggests referring to Section VIII of the PPWR FAQ document for further guidance.

2030 – 2040

Packaging minimization

By 1^st January 2030, Article 10 establishes that the manufacturer or importer ensures packaging placed on the market is designed with the minimum weight and volume necessary to be functional, considering its shape and material. The manufacturer or importer needs to ensure that packaging which does not comply with the performance criteria set out in Annex IV and packaging with characteristics only to increase the perceived volume of the product - such as double walls, false bottoms and unnecessary layers - is not placed on the market unless given exemptions apply.

Article 70 clarifies that the essential requirements for minimization under the PPWR will continue to apply until 31 December 2029.

Recyclable packaging by design

Article 6 mandates that, from 1^st January 2030 (or 24 months from the date of entry into force of the delegated acts, adopted pursuant to Article 6), packaging is designed for material recycling. Europen suggests referring to Point 6 of the PPWR Guidance and Section IV of the PPWR FAQ document for guidance.

Recycled content in plastic packaging

Article 7 states that from 1^st January 2030 (or 3 years from the date of entry into force of the implementing act), any plastic part of packaging placed on the market shall contain a minimum percentage of recycled content recovered from post-consumer plastic waste. This is measured per packaging type and format as referred to in Table 1 of Annex II, calculated as an average per manufacturing plant and year. Europen adds that that point 7 of the PPWR Guidance and Section V of the PPWR FAQ document provide guidance on this.

Packaging labelling (substances of concern)

Article 12 requires that 24 months following the date of entry into force of the implementing act, packaging placed on the market containing ‘substances of concern’ must be marked with ‘standardized, open, digital-marking technologies’, according to the methodology referred to in paragraph 7 of the Article. There is also a clause on exhaustion of stocks under Article 12 and specifications for displaying labels, QR codes or other standardized, open, digital-marking technology.

Recyclable packaging (at scale)

From 1^st January 2035 (or 5 years from the date of entry into force), Article 6 mandates that when packaging becomes waste, it can be collected separately in accordance with Article 48, sorted into specific waste streams without affecting the recyclability of other waste streams and recycled at scale. Point 6 of the PPWR Guidance and Section IV of the PPWR FAQ document provide guidance on this.

Recycled content in plastic packaging

Lastly, Europen outlines that according to Article 7, by 1^st January 2040 any plastic part of packaging placed on the market will contain a minimum percentage of recycled content recovered from post-consumer plastic waste per packaging type and format (as referred to in Table 1 of Annex II), calculated as an average per manufacturing plant and year. Point 7 of the PPWR Guidance and Section V of the PPWR FAQ document provide guidance on this.

Europen also underlines that the EU Declaration of Conformity (DoC) and relevant Time Directives (TD) are ‘living documents’, with manufacturers are expected to carry out conformity assessments only for the PPWR requirements that are already applicable at the time the EU DoC and TD are drawn up. Subsequent updates of the DoC and TD should be prepared as additional PPWR requirements become applicable over time.

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