PPWR: Where are we now, and how must we adapt?

The Packaging and Packaging Waste Regulation (PPWR) is one of the EU’s most significant pieces of circular economy legislation to date. Unlike the Packaging and Packaging Waste Directive it replaces, the PPWR applies legally across the EU, eliminating national inconsistencies and covering all packaging that enters the European market, including B2B and B2C. It mandates for areas including recyclability and recycled content; labelling and marking; reuse; extended producer responsibility (EPR) and restriction of hazardous substances.

The PPWR officially came into force in February 2025 but this year another countdown began: from 12 August 2026 the Regulation will legally apply across EU member states, with further obligations being phased in over the next decade. From this date forward, any packaging type on the EU market will require a valid, signed Declaration of Conformity(DoC) and an accompanying technical file.

And yet uncertainty remains in many key areas for those companies across the value chain who must comply, not to mention anybody importing goods to the European Union from outside. The situation is further complicated by the upcoming unveiling of the EU Circular Economy Act later this year, which will potentially intersect with some elements of the PPWR.

We have heard from many industry voices about the grey areas remaining and their concerns about varying levels of readiness across the industry. Recently published materials such as the EU’s guidance document and fact sheet, while answering some questions, have also served to create more. Many companies are still waiting for key delegated and implementing acts that will determine how certain requirements will work in practice, particularly around recyclability, labelling and reuse.

TIMELINE AND KEY REQUIREMENTS

Readers can already refer to our detailed timeline of how the PPWR will unfold over the years, but to give a very brief recap:

• Between 2025 and 2030, implementation will be focused on secondary legislation and market adaptation. By 2030 all packaging must be recyclable, the first recycled content and initial reuse targets will need to be met, and total bans on certain unnecessary single-use packaging will come into play.
• By 2035, packaging must not only be designed for recycling but must also be recyclable ‘at scale’.
• By 2040, the final packaging waste reduction target of 15% must be met, while additional reuse targets and recycled content targets will become more demanding.

Every piece of packaging will be assessed and assigned a recyclability performance grade ranging from A to E, based on three key factors: design‑for‑recycling characteristics, compatibility with collection and sorting systems, and actual recycling performance. From January 2030, only grades A, B, or C may be marketed in the EU. This threshold tightens in January 2038, when only grades A and B will be permissible.

Anna Perlina, PPWR consultant at Integrity Solutions, in a recent webinar hosted by our own Tim Sykes, explained that for those who are tasked with compliance it can be useful to think of the requirements of PPWR as fitting into three buckets: administration, traceability and communication; packaging design and materials; and financial responsibility (i.e. extended producer responsibility (EPR)).

Under the ‘administration, traceability and communication’ umbrella is included new processes that did not exist previously, such as the above-mentioned Declaration of Conformity and all the technical documentation around that. This also includes the obligation to include manufacturer import information on all the packaging and packaging identification.

When it comes to packaging design, says Anna, “the first milestone is limits on substances of concern and overall minimization in a few weeks. We then have a big milestone in 2030 when there will be a list of requirements coming into force regarding minimization, empty space and transport packaging, recyclability, recycled content, reuse and also banning of some plastic formats.”

The last category, ‘financial responsibility’, is related to the ‘polluter pays’ principle; most pressingly in this case, those companies obligated to pay for packaging waste will need to be registered in the relevant EPR scheme by 12^th August 2026.

MOST RECENT DEVELOPMENTS

But this is a live and unfolding topic with ongoing discussion around definitions and even calls for postponement. Before we look at some of the major challenges and ambiguities still facing the value chain, let’s also look briefly at some of the most recent events from the past few months.

In April 2026, industry CEOs sent a letter urging the European Commission to postpone the enforcement of the PPWR, to provide more time to respond to awaited clarifications on restrictions and definitions, including PFAS restrictions and plastic shrink wrap for multipacks.

Following this, the most recently updated guidance in the form of a new Commission Notice on the PPWR was published in June 2026. Among other things, it clarified its recommendations for a stepwise approach to PFAS in food-contact packaging. In the area of reuse, it confirmed that ‘making available’ does not require the actual completion of a sale, but requires the relevant economic operator to provide at least 10% of its beverages in reusable sales packaging.

The document also highlighted two exemptions from the PPWR’s recycled content requirements, as specified in Article 7(5): food-contact packaging where the presence of recycled content would pose a threat to human health, and plastic parts that represent less than 5% of the total weight of the packaging unit.

However, while it provided some clarity, the new Commission Notice also created further misunderstanding. (During the EU Waste Expert Group on 20 May 2026, the Commission announced that the existing document was outdated – but the official version published on 5 June had only undergone a few minor changes in the footnotes.)

Led by EuroCommerce, retailers and wholesalers urged EU environmental ministers to enforce a 12-month grace period and further clarification surrounding upcoming legal deadlines for the PPWR.

But even on this question there is not unanimity: in June 2026 other companies signed a joint call urging the European Commission not to reopen the PPWR – but instead to ensure its ‘timely and effective’ implementation through secondary legislation. Multiple businesses and industry associations pointed out that the Commission worked alongside stakeholders to adopt the PPWR through the Ordinary Legislative Procedure – argued to have ensured both ‘democratic legitimacy and technical robustness’.

It makes sense to assume that the PPWR will proceed as planned, but these calls and counter-calls illustrate how much confusion still remains around the Regulation.

CHALLENGES AND AREAS OF AMBIGUITY

Let’s now go on to examine in more detail just a few examples of those existing grey areas that have led to the calls for postponement.

Declaration of Conformity: Who is actually responsible?

As mentioned, the Declaration of Conformity (DooC) is the first of the PPWR measures to come into force on 12 August 2026. For those who want the full details on what this involves, refer to the article we published earlier this year, but briefly:

• It is a legally binding self-declaration, in which the manufacturer confirms that each individual type of packaging it places on the market meets the PPWR sustainability requirements.
• It is defined in Article 39 with the model structure detailed in Annex VIII. It covers minimization, recyclability, recycled content, reuse, substance restrictions and innovative packaging. Alongside this is the technical documentation to back up all claims.
• Declarations must be kept up-to-date and available in a language that can be easily understood in the member state where the packaging is placed.

Common questions asked include: when there are products which move all the way through the supply chain, which stakeholder is responsible for meeting the requirements set out in the PPWR? And furthermore, who is responsible for paying the fees associated with them?

When it comes to the first question, there is a distinction to be drawn between the ‘manufacturer’ and the ‘producer’. When it comes to compliance issues, it is the manufacturer that is responsible for ensuring the pack is labelled correctly because only they know precisely what has gone into the packaging.

When it comes to the registration itself and the fees, the responsibility is with the producer who will be placing the product on the market. To add to the complexity, an exception can be made with transport packaging: because this is normally placed on the market by the manufacturer, they are also classed as the producer and must take responsibility.

With regards to fees, Ton Knipscheer, executive director of the European Co-Packers Association and founder of TK Packaging Consulting, explained: “Whoever puts their name on the pack is responsible. Let’s say a contract manufacturer, private label producer or a contract packer produces something for company A and that company has their branding on the pack, they are responsible for all the fees and legislation under the PPWR’s EPR rules.

“Of course they will need their contract packer or private label producer to supply the correct information and may sometimes even try to put some of the responsibility into their lap, but legally, the one who takes the revenue for the end product must pay the fees.”

Classification 

Moving on from the topic of fundamental responsibilities, there are plenty of questions flying around in the ether as to what rules apply to which classifications of packaging, with all the frustrations that result from this. So where do we need a little more clarity here and how can companies approach this challenge?

According to Anna Perlina, “This is important, because classification of your packaging defines the effort you will need to put into achieving the applicable requirements. This is not as straightforward as it might seem. As a company, the very first question you need to ask yourself is: is this item even packaging at all?

In the case of an item such as a bottle this is unambiguous – a bottle is clearly a package. But when it comes to something like paper transport packaging, which contains components like tape and labels, where is the line drawn and who in the supply chain is responsible for which component? Sticky labels attached directly to fruit, and sleeves or labels applied directly to bottles, count as packaging.

Process films that are used simply to hold materials together during manufacturing but never reach retail shelves are currently excluded. The European Commission has also officially exempted businesses that use pallet wrappings and straps from the PPWR’s 100% reuse requirements, citing ‘disproportionate’ costs and supply chain impacts. Release liners for printed labels are an ongoing grey area.

Another question producers should ask is: is it part of the product or part of the packaging? Items that are intended to remain part of the product up to its end-use point, such as teabags, sausage casings and medical inhaler casings, are also exempt.

Once it has been identified whether an item is classified as packaging not, the PPWR now also divides packaging categories into the different intended end-uses: sales, grouped, transport and service. This replaces what the industry currently uses, which is simply primary or secondary packaging, and in practice can make classification even more complex for producers and packagers.

According to Anna, therefore, “It’s vital to understand that under the new categorization, a package can now have more than one classification. While the PPWR doesn’t explicitly say that, practice shows this to be the case: e.g. grouped packaging and transport packaging can be the same thing.”

It goes on. Producers also need to ask the question: is the packaging consumer-facing? If so, it is the consumer who will be disposing of that packaging. This impacts whether you need to implement sorting labelling or not; B2B operators will know how to dispose of the packaging so labelling may need to be less detailed. And yet another question: is the packaging single-use or reusable? Reusable packaging of course has additional requirements in terms of labelling, minimum number of rotations and so on.

Dispiritingly for some, this is by no means an exhaustive list of all the questions that need to be asked in order to classify an item of packaging, but just these few examples demonstrate the complexity of the looming rules.

How, then, do producers approach the knotty question of classification? Anna Perlina has this thankfully clear advice to offer: “What I suggest is to thoroughly document your choice and your position for each item and also use the risk-based approach. If it crossed your mind that it might be this type of packaging, then check it and double-check before documenting.”

Recyclability definitions

Article 6 of the PPWR requires packaging to be recyclable and sets out what requirements will need to be met in a two-stepped approach. As of 1 January 2030, packaging will have to comply with the design for recycling criteria and, as of 1 January 2035, the requirements will be further adjusted to ensure that recyclable packaging is also sufficiently and effectively collected, sorted and recycled (‘recycled at scale’).

Confusion here stems from the implications of these two different criteria: ‘designed for recyclability’ and ‘recycled at scale’. According to the PPWR, all packaging placed on the EU market must fulfil these two conditions in parallel by 2035.

According to Marius Tent, co-founder and director at both VIA Packaging and 360packmastery.com, “Everyone is talking about the first condition and the grading system associated with this, but we can’t focus only on this as from 2035 the packaging should be recycled at scale. Everyone is wondering what that means in reality.”

For the purposes of illustration, Marius uses the example of flexible packaging alone – widely understood as one of the most challenging formats to recycle at scale.

When it comes to recyclability, Historically, flexible packaging relied heavily on multi-material, multi-layer laminates (e.g., mixing PET, aluminum, and PE), which are notoriously difficult to recycle. To achieve PPWR compliance, industry leaders (such as through initiatives by CEFLEX) are transitioning toward mono-material structures (like all-Polyethylene or all-Polypropylene). 

Theoretical recyclability is no longer enough. Infrastructure must exist at an industrial scale to practically collect, sort, and process the packaging. Any polymers falling below the 55% recycling rate target will face strict market access prohibitions.

“If you look at the 2035 recycling at scale target, the industry needs to reach 55% for flexible packaging alone, and that’s the minimum. To get there, you have to collect, say, 82% of the packaging produced across member states and there are many conditions to fill there in terms of infrastructure and consumer behaviour. And then, once that packaging is collected, it should be sorted in that fraction. Another 82%. That means from the 82% already collected, 82% of that should be sorted – and then from all that 82% sorted, you have to recycle 82%. Multiplying those three things, 82 by 82 by 82, gives you just over 55%.”

Even beyond recyclability, the flexibles industry has a huge challenge to meet in sourcing the amount of PCR it will need to meet recycled content targets. A recent report by CEFLEX claims that EU Member States must source an additional 440,000 tonnes of post-consumer recyclate from flexible polyolefins annually to meet the Packaging and Packaging Waste Regulation’s recycled content targets.

According to CEFLEX, 2.5 million tonnes of post-consumer recyclate must be derived from flexible plastics to meet the Regulation’s recycled content target by 2030. By the same logic, an estimated 5.9 million tonnes of post-consumer recyclate must be derived from flexibles to meet the recycling rate targets for all plastic packaging formats in 2035.

Innovation in the area of recyclability has increasingly been targeted specifically to meet the requirements of the PPWR, among other legislation. We have already seen instances of this, and the idea of innovation being shaped by regulatory necessity is definitely something we should become used to. Earlier this year, for example, Walki and Dow’s mono-material MDO-PE pouch with a matte finish is set to unlock recyclability and high performance for frozen food packaging in compliance with the PPWR.

Single-use formats

Article 25 of the PPWR prohibits the use of specific single-use plastic packaging formats listed in Annex V, effective January 1, 2030. The goal is to eliminate unnecessary, wasteful packaging, including hotel miniature toiletries, condiment sachets, and supermarket fruit packaging under 1.5kg.

What are the implications here for business? Essentially, if your product contains more than 95% plastic than it is classed as single-use packaging. Therefore under Annex V there are six different formats which must be phased out by 1^stJanuary 2030, as follows:

• Grouped packaging: Single-use plastic collation films and shrink wrap used at the point-of-sale to bundle multiple bottles, cans, pots, or tubs (excluding grouped packaging essential for handling).
• Fresh produce packaging: Single-use plastic packaging for less than 1.5 kg of unprocessed fresh fruit and vegetables.
• HORECA dine-in packaging: Single-use plastic packaging for foods and beverages that are filled and consumed on-site within the premises of hotels, restaurants, and cafes.
• Condiment sachets: Single-use plastic packaging for condiments, preserves, sauces, coffee creamers, and sugar in the HORECA sector.
• Hotel miniatures: Single-use plastic packaging in the accommodation sector intended for an individual booking.
• Lightweight carrier bags: Very lightweight plastic carrier bags (typically those under 15 microns).

There have also been questions raised as to whether or how far the PPWR conflicts with Europe’s Single-Use Plastic Directive (SUPD). While there is no inherent conflict, both interact closely and do contain overlapping categories. For example:

• Direct modification: The PPWR acts as a lex specialis in relation to the SUPD. This means PPWR provisions, such as packaging bans or specific recycled content targets, directly modify or override conflicting or duplicative SUPD requirements to ensure harmonization across the EU.
• Overlapping measures: Both impose restrictions on certain single-use formats (e.g., condiment sachets and sauce packets), but PPWR rules take precedence where they provide more specific mandates on minimizing unnecessary packaging or harmful substances like PFAS.
• Unified approach: According to official EU guidance, the two regulations must be interpreted harmoniously. Key goals are to standardize EPR obligations, harmonized labeling, and waste prevention incentives across Member States.

TAKEAWAYS FOR BUSINESSES 

Whatever the ambiguities and wherever you stand on the question of postponing certain deadlines, there are clear penalties for non-compliance under PPWR Article 62. These are enforced by EU Member States and may include financial fines, market access denial, and product recalls. Non-compliant entities face potential fines ranging from €10,000 to €200,000, along with potential supply chain disruptions.

Assuming that the implementation proceeds as planned – and there is no real reason to assume it won’t – here are just some key points for companies to bear in mind.

• Define your role: Are you a manufacturer? An importer? A distributor? It’s important to clarify this as each are tackling completely different aspects of the PPWR obligations. As we mentioned, the one playing the manufacturer role will be signing the EU DOC by 12^th August this year.
• Traceability: By 2028–2029, all packaging must include harmonized labels indicating material types and disposal methods, with plastic packaging requiring explicit labels for recycled content. But companies should not wait until then – start now to ensure easy traceability.
• Be prepared for change: Like all huge and complex pieces of legislation, the PPWR is likely to evolve. EPR is one area that we can expect to grow and develop across the region as it’s going to be a key strategic tool. But Anna Perlina also stresses that the DOC and related obligations will be “an ongoing process of change management. So you need to make sure you establish an eco-system that allows change management similar to the quality management system.”
• Prioritize your efforts: Member states do not yet all have the necessary infrastructure to start checks on compliance and in reality it’s likely that many will struggle to begin with. Anna suggests looking at your company’s unique situation and risk level.

“For example, we can assume that sales packaging, because it’s on the shelf, will be subject to the earliest checks while shipping cases may not be one of the earliest priorities. We also know that there are some markets, such as Germany, that are further ahead in their planning so you have to look at it from that perspective as well – i.e. where will your products be placed? It also depends on overall company tolerance to risk, and how far you’d like to push.

“Be smart choosing your priorities, and then you improve as you go after the implementation date.”

Despite the confusion remaining, few would argue that the PPWR is not an essential piece of legislation in the EU’s drive towards a circular economy. All very well for a non-value chain member to say, perhaps, but the need for harmonization is pressing, and it would be strange indeed if the implementation of such an all-encompassing piece of legislation turned out to be a simple affair.

For further advice on how to prepare for the PPWR without waiting for postponements, read this guest post on the Packaging Europe website. And last but not least, we would of course like to draw readers’ attention to Europen’s essential PPWR Conformity Assessment Toolkit.

Inevitably, this is going to be an ongoing area of intense scrutiny and discussion and a major focus at the Sustainable Packaging Summit taking place in Utrecht from the 10th to the 12th of November this year.

Disclaimer: This article is for informational purposes only and does not constitute legal advice.

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