The ultimate guide to the Packaging and Packaging Waste Regulation in 2025

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The European Council has formally adopted the final text of the Packaging and Packaging Waste Regulation (PPWR), which entered into force on 11 February 2025. This sweeping legislation sets out binding targets for recycling, reuse, and packaging waste reduction across the EU, reshaping the packaging landscape for producers, retailers, and recyclers alike.

• Tight Recycling Deadlines: Member States must meet a 65% recycling rate by the end of 2025, increasing to 70% by 2030 – with higher thresholds for paper, glass, and metals, and lower ones for plastics and wood. Some flexibility is allowed, but minimum caps remain.
• Design for Recycling Is Mandatory: By 2030, all packaging must meet recyclability criteria – at least 70% recyclable by weight – or it won’t qualify as recyclable under EU law.
• Recycled Content Targets Locked In: PET food-contact packaging must contain 30% recycled content by 2030; non-PET food-contact plastic must meet 10%. Other plastic packaging must reach 35%. Targets rise significantly by 2040.
• Reuse Mandates Coming Fast: From 2030, specific reuse targets apply to beverage, transport, and takeaway packaging. Retailers over 400m² must allocate 10% of space to refill systems.
• PFAS and Labeling Rules Tighten: PFAS in food-contact packaging will be restricted from August 2026. All packaging (excluding DRS and transport) must carry harmonized sorting labels by 2028.
• Producer Responsibility Ramped Up: Extended Producer Responsibility (EPR) schemes now tie financial contributions to recyclability and recycled content. Producers also gain conditional priority access to recycled materials.

The PPWR signals a decisive shift from voluntary targets to enforceable obligations, prioritizing recyclability, reuse, and clear labelling across the EU. While exemptions exist, especially for hygiene-sensitive packaging, the overall direction is clear: packaging must become circular, fast. Businesses must act now to adapt their materials, systems, and reporting practices – or risk falling behind as enforcement ramps up and the market moves toward sustainability.

The Packaging and Packaging Waste Regulation is now in force, but does it address your biggest concerns? In this edition of the Brief, we break down the official text to discover how well it aligns with industry feedback – and what it means for you in the coming years.

New year, new rules

Following our in-depth guides to the Packaging and Packaging Waste Regulation (PPWR)’s development in 2023 and 2024, the completed text has been formally adopted by the European Council and entered into force on 11^th February 2025.

Its earliest targets are already looming, with Member States expected to reach a minimum recycling target of 65% by weight of all packaging waste generated by the end of this year. Broken down by material, this involves a 75% recycling rate for paper and cardboard; a 70% recycling rate for glass and ferrous metals; a 50% recycling rate for plastic and aluminium; and a 25% recycling rate for wood.

By 31^st December 2030, this will increase to a minimum recycling rate of 70% by weight of all packaging waste generated – 85% of paper and cardboard, 80% of ferrous metals, 75% of glass, 60% of aluminium, 55% of plastics, and 30% of wood.

(It is worth noting here that Member States are permitted to postpone the Regulation’s minimum recycling targets by up to five years and a maximum reduction of 15%, which also applies to minimum targets in future years – yet the recycling rates for glass, paper, and cardboard are capped at a minimum of 60% this year.)

Long-time readers might remember a white paper released by Smithers in 2023; it suggested that the disparity between the aforementioned targets stems from the expenses associated with collecting polymers compared to metal, fibre and glass. The purity, colour, processing performance, and decontamination of post-consumer resins also pose challenges when it comes to full circularity, hence the lower target for plastics.

However, another important consideration is the PPWR’s overlap with the Single-Use Plastics Directive, in which Member States are expected to separately collect at least 77% of single-use plastic products placed on the market in 2025. The same will apply every year until 2029, at which point the figure increases to 90%.

At a consumer level, the Regulation targets a ‘sustained reduction’ in the consumption of lightweight plastic bags; Member States must not consume more than 40 bags per person, or an equivalent target in weight. This rule will apply from 31^st December 2025 and on the same date in every subsequent year.

Perhaps it will come as some comfort to organizations like Copa-Cogeca, Freshfel Europe, and Europatat, who warned in a statement that banning packaging for fruit and vegetables weighing less than 1.5kg posed risks to product hygiene and shelf life, that very lightweight plastic bags are still permitted where they are necessary to prevent food waste or keep a product clean. An optional exemption for lightweight carrier bags made of proven industrially biodegradable plastic polymers may also suit their recommendation that the PPWR focus on a transition into recycled, biodegradable, and compostable materials, among other waste prevention strategies.

However, from January 2030, single-use plastic packaging will be banned for lightweight fruit and vegetables. Member States are permitted to establish exemptions if the bags are proven to prevent water or turgidity loss; prevent microbiological hazards, physical shocks, or oxidation; or prevent the mixing of organic and non-organic fruits and vegetables in line with the EU’s certification and labelling requirements.

Recycling

All packaging must be designed for recycling by 1^st January 2030. If a pack is less than 70% recyclable per unit in weight, it will not be defined as recyclable under EU law.

Two years ago, the Alliance for Beverage Cartons and the Environment (ACE) argued that there was too little high-quality recyclate in circulation to reach the PPWR draft’s proposed recycled content targets for contact-sensitive packaging, then proposed at 10% by 2030 and 50% by 2040. Yet minimum recycled content targets have not changed much in the meantime – the current draft only splits its expectations for contact-sensitive packaging made of PET (30%) and non-PET plastic (10%).

The latter target excludes single-use plastic beverage bottles, which have their own minimum recyclate content threshold of 30%. Any other type of packaging must reach 35% recycled content by 2030. Of course, all these minimum targets will increase by 1^st January 2040 – reaching 50% for non-bottle contact-sensitive packaging, and 65% for plastic bottles and all other packaging types.

None of the PPWR’s minimum recycled content targets will apply to packaging wherein the presence of recycled content poses safety concerns, which includes contact-sensitive packaging for medical or in vitro diagnostic devices, immediate packaging for human or animal medical products, packaging for products for babies or young children, or transport packaging for dangerous goods. Compostable packaging is also considered exempt.

In the lead-up to the plenary vote, organizations from the natural mineral water and soft drink industries called for a priority access right to recyclates for food-contact bottles – a measure expected to prevent unfair competition between industry players by ensuring that the appropriate amount of recyclate is allocated to the sectors most in need of them. In EuRIC’s view, however, priority access could negatively affect the internal market; instead, Member States should focus on raising recycling and collection rates.

In the current text, producers contributing to extended producer responsibility (EPR) schemes are granted priority access to recycled materials at market prices. How much recyclate they have access to is dependent on the amount of packaging the producer places on the market within a certain time frame.

On the subject of EPR, Member States must introduce a national register of producers to monitor EPR compliance within the first 18 months of the Regulation entering into force. Producers must register with the relevant authorities, to whom they will report their data – breaking down, by weight and material, the quantity of packaging they place on the market, or otherwise unpack without being an end user.

This will oblige them to cover the costs of collecting, sorting, recycling, and disposing of their packaging waste in line with the ‘polluter pays’ principle, wherein fees will correspond to the packaging’s recyclability performance grades. Delegated acts to standardize the process will be adopted by 1^st January 2028, and starting in 2030, financial contributions will be modulated based on the percentage of recycled content a producer uses in their packaging.

The European Recycling Industries Confederation (EuRIC) previously recommended that only post-consumer plastic packaging waste collected within the EU should count towards minimum recycled content targets. If European companies rely on cheaper recyclate from non-EU countries, which may have different standards for circularity, energy, and labour costs, EuRIC feared that a) the recyclate would be of lower quality and fall short of Europe’s circularity targets; and b) an uneven playing field would develop between European plastic recyclers and importers, resulting in unfair competition and less investment in circular value chains.

Just last year, it reiterated the importance of setting standards for imported plastic recyclate to align with the rules of the World Trade Organization, as well as the ban on Member States exporting plastic waste to non-OECD countries.

While the current Regulation does not exclude imports, it does hold them to EU standards, explicitly linking this to the preservation of the internal market. It tasks market surveillance authorities with the task of catching non-compliant recyclate at the borders and, to reduce overall reliance on imported resources, pushes for improved waste management systems.

On that note, all packaging must still be recycled at scale – that is, collected, sorted, and recycled via installed state-of-the-art infrastructure and processes – by 1^st January 2035; this must account for at least 75% of the EU population and include exported packaging waste.

While ACE’s suggestion for a 90% mandatory collection target encompassing beverage cartons has not been realized, Member States are still expected to ensure that 90% of single-use plastic beverage bottles and metal beverage containers with capacities of up to three litres must be collected via deposit return systems by 1^st January 2029. This will not apply to packaging for dairy drinks, spirits, wines, or other grapevine products.

In the HORECA sector, packaging that is opened, the product consumed, and the container returned on the premises is exempted from charging a deposit. Yet entire Member States will be considered exempt if their separate collection rates for the packaging in question exceeds 90% by weight within two years of the PPWR entering into force – or, alternatively, if an exemption request is submitted at least 24 months before the deadline, complete with a strategy with concrete actions for future progress.

Reuse and refill

As far back as 2023, signatories of a position paper (including Reloop, TOMRA, and the Ellen MacArthur Foundation) called for a concrete definition of a reusable pack; for example, a minimum number or reuse cycles. The current text states that packaging may be considered reusable if it is ‘designed to accomplish as many trips or rotations as possible in normally predictable conditions of use’, but it delegates the definition of a minimum number of reuses to the European Commission by a deadline of 12^th February 2027.

Another listed definition of a reusable pack is that it ‘fulfils applicable requirements regarding consumer health, safety and hygiene’ and can be unloaded, refilled or reloaded in line with ‘the applicable safety and hygiene requirements, including those on food safety’ – addressing previous concerns from FoodDrinkEurope that its reuse standards ‘[fall] short’ on hygiene. Additionally, reuse targets do not apply to food-contact transport packaging.

Yet the bulk of the discourse surrounding reuse and refill pertains to the minimum targets themselves, which include the following;

A specific timeline is laid out for food and beverage caterers; they must allow consumers to bring their own containers for pre-prepared, hot or cold takeaway products by 12^th February 2027, then give consumers the option to purchase such products in reusable packaging within the following year. Reuse targets for wine, spirit, and milk packaging, in particular, will be established by 12^th February 2027.

Deadlines are also set for refill infrastructure; as of 1^st January 2030, final distributors with a sales area of 400m² or more must dedicate at least 10% of their space to food and non-food refill systems. Member States are also encouraged, but not obligated, to establish similar systems for reusable packaging formats.

In response to earlier drafts of these targets, Metsä Group’s vice president of Climate and Circular Economy, Maija Pohjakallio, and Jarkko Tuominen, expressed reservations that ‘reuse is emphasized over recycling’ – raising the example of restaurants, where they feared a ban on single-use dine-in packaging would drive owners back to fossil-based plastics to meet reusable packaging deadlines. Nevertheless, this ban will still apply as of 1^st January 2030.

Similarly, Reloop, Zero Waste Europe, and The European Container Glass Federation (FEVE) warned that the then-draft text’s failure to include a minimum recycled content for glass (which, as we have seen, has now been rectified) and to mandate deposit return schemes for glass bottles could lead to an increase in single-use glass and cause environmental impacts. As of February 2025, the regulation states that ‘Member States might also decide to include other packaging in [deposit return] systems, in particular single-use glass bottles’.

The Committee on Environment’s revisions to the draft text in October 2023 also sparked concerns from UNESDA that, in the absence of exemption mechanisms, its ambitious reusable packaging targets would have ‘unintended adverse effects […] on currently well-functioning circular systems’ – and that enabling Member States to exceed these targets could lead to a ‘patchwork of national targets’ across Europe.

Nonetheless, the current text still permits countries to go beyond the minimum reuse rate. Where final distributors are concerned, exemptions remain fairly niche; those defined as micro-enterprises – and/or operating in sales areas smaller than 100m², a municipality with a population density below 54 persons per km², or on an island inhabited by less than 2,000 people – are considered eligible for exemptions.

Member States are also relieved of these targets if they exceed recycling rates per material by 5% or more in 2025, and are anticipated to do the same in 2030; if they are on track to meet waste prevention targets and can prove that their waste production per capita will reach or exceed 3% in 2028 (against a 2018 baseline); and/or if they have enacted a corporate waste prevention and recycling plan in line with the Regulation’s objectives.

Archana Jagannathan, chief sustainability officer at PepsiCo Europe, previously shared with us her concern that the PPWR did not acknowledge the potential of refill-at-home solutions to lessen the energy and resources required to run a public system, nor its ability to shorten and simplify refill loops. As of now, the PPWR does not mention them.

On the other end of the scale, European Plastics Converters (EuPC), IK Industrievereinigung Kunststoffverpackungen (IK), and Elipso have signed a document criticizing the current reuse regulations concerning plastic pallet wrappings and straps for transporting products. They argue that the EU Commission should temporarily exempt such packaging from full reuse obligations, instead suggesting a new proposal ‘based on a scientific analysis and impact assessment’.

Apparently, the wrappings and straps already contain post-consumer recyclate, are fully recyclable, and are frequently recycled into new films and straps; moreover, there is not yet believed to be an alternative material that balances low weight and high speed the way plastic does. Under the current PPWR, the organizations argue, transport companies will be using single-use and reusable packaging solutions at the same time from 2030 onwards, which raises financial concerns.

In response, a delegated act is in progress. Within the first half of 2025, the results of a study to prove the exemption requirements is set to be released, while legally binding exemptions are expected in the second. ISO-compliant life cycle analyses are also anticipated to compare different packaging units to reusable solutions, as well as paper and cardboard variants.

Waste and safety

Just as prevention tops the waste hierarchy, so too does the PPWR set waste prevention targets. Member States must reduce their packaging waste per capita against a 2018 baseline in five-year increments: 5% by 1^st January 2030, 10% by 1^st January 2035, and 15% by 1^st January 2040. These figures date all the way back to the provisional agreement, at which point Zero Waste Europe was among the organizations criticizing them as too low.

Matthew Kay, packaging policy lead at British Glass, has raised concerns about basing these metrics on weight. In his view, this runs the risk of lighter materials always taking precedence, regardless of their recyclability, end-of-life impact, or food safety. He raises the example of glass, which he acknowledges is a heavy and carbon-intensive material, but also claims is completely and infinitely recyclable without declining in quality – thus requiring fewer raw materials and cutting down on emissions.

Sooner still, though, packaging made from biodegradable materials must be designed for recycling (without contaminating material streams) by 12^th February 2028. Sticky labels applied to fruit and vegetables must also be industrially compostable within the same time frame.

Member States may choose to enforce a rule that, unless they are made of metal or lightweight plastic bags, single-serve units for tea, coffee and other beverages designed for use in a machine must be compostable to be sold on the market. This is not a mandatory requirement.

Otherwise, harmonized standards for packaging that can be composted either at home or through industrial bio-waste facilities are to be developed by 12^th February 2026.

However, the Alliance for Sustainable Packaging for Foods (ASPF) previously warned that the text favours recyclability over composting, which could limit the options available to fresh food manufacturers. Since various exemptions are currently optional, the organization worries that perishable foods could be subject to a ‘patchwork’ of different regulations across the continent, which could have implications for the single market.

The PPWR also cracks down on substances of concern. Manufacturers are expected to minimize the amount of substances of concern within their packaging’s materials, components, emissions, and waste management processes; microplastics are included in this expectation.

Member States must report any substances that negatively impact the reuse and recycling of packaging materials to the European Commission and the European Chemicals Agency (ECHA) by the end of this year, accompanied by relevant data and risk assessments wherever available.

As of 12^th August 2026, food-contact packaging meeting or exceeding certain levels of per- and polyfluorinated alkyl substance (PFAS) content will no longer be allowed on the EU market.

Among other specifications, PFAS content cannot exceed 25 parts per billion (ppb) as measured with targeted PFAS analysis, with the exception of polymeric PFAS; 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors (polymeric PFAs are also excluded here); or 50 ppm parts per million for PFAS (including polymeric PFAS).

Then, by the close of 2026, ECHA and the Commission will prepare a report weighing up the impacts of PFAS on reuse, recycling, and chemical safety. This might list the substances of concern found in packaging and packaging components, determining the extent to which they could harm human consumers and the environment.

These developments come after the Commission banned the use of Bisphenol A (BPA) in food-contact materials via Regulation (EU) 2024/3190. Reusable bottles, coatings for metal cans, and water distribution coolers are among the applications wherein BPA was found to have ‘potentially harmful effects on the immune system’.

Of course, consumers must understand what to do with their packaging waste, which is where the PPWR’s labelling measures come into play. Harmonized label and labelling guidelines will be made available by 12^th August 2026, but until then, the Regulation provides a general outline.

As of 12^th August 2028, all packaging (excluding DRS and transport packaging, although e-commerce packaging is still included) must bear a harmonized label informing consumers of the pack’s material composition and enabling them to sort the components effectively. This should be communicated through clear pictograms that are accessible to all, including disabled consumers.

Packaging intended for use in a deposit return scheme must be clearly labelled. Similarly, labels applied to compostable packaging should clarify that the material is industrially compostable, but unsuitable for home composting or leaving to decompose in nature; and standardized, digital-marking technology should highlight the presence of substances of concern in a pack.

A year later, reusable packaging must be clearly labelled. Further information about the corresponding reuse system and collection points must be provided via a QR code or another standardized data carrier.

All labels must be ‘affixed, printed or engraved visibly, legibly and firmly on the packaging’; where the size or material prevents this, it should be applied to the grouped packaging, or else via a single electronically readable code or other type of data carrier. Labels must not be designed in a way that confuses or misleads consumers.

Undoubtedly, the PPWR will continue to develop as its deadlines come to pass, and as its policies are reviewed over time. Keep your eyes on your Packaging Europe newsfeed – we will keep you updated as the legislation evolves and the industry responds.

We have also compiled a chronological, checkpoint list of the key dates the packaging industry needs to know; click here to take a look.

This report does not constitute legal advice or official regulatory guidance. For a full and specific rundown of how the Packaging and Packaging Waste Regulation affects your packaging, please refer to the full text.

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