The ultimate guide to the Packaging and Packaging Waste Regulation in 2026

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Intro

In this edition of the Brief, we recap developments in and around the Packaging and Packaging Waste Regulation from March 2025 to February 2026.

Key takeaways

• After the Packaging and Packaging Waste Regulation entered into force in February 2025, multiple industry players shared their resources and opinions on the new legislation. These included an interactive guidebook from Europen, the Rethink Plastic Alliance’s report on achieving EU sustainability goals, and an industry statement signed by 100+ businesses to close the gap between virgin and recycled plastic prices.
• By September 2025, the European Commission was reconsidering its €0.80/kg levy for non-recycled plastic packaging. While this measure doesn’t feature directly in the Packaging and Packaging Waste Regulation, its critics feared that the move could discourage investments in waste reduction infrastructure.
• Rumours arose in November 2025 that the European Commission might reopen the Regulation as part of its Environmental Simplification Package. Doing so was feared to cause delays, set back deadlines, and create widespread uncertainty for market operators.
• Ultimately, the Commission published its Environmental Omnibus in December 2025. Its simplification measures included a Frequently Asked Questions document, application dates, reuse targets, labelling requirements, PFAS testing, and more.
• So far in 2026, the Commission’s Joint Research Centre has published a proposal to harmonize the Regulation’s waste sorting labels. Germany has also become one of the first EU countries to transpose the Regulation into national law.

One year after the Packaging and Packaging Waste Regulation’s entry into force, where does our industry stand? Read on for a recap of the most significant developments over the last twelve months, from official updates to industry-wide action.

In need of a refresher? Take a look back at our ultimate guides to the Packaging and Packaging Waste Regulation in 2023, 2024, and 2025 to bring you up to speed. Alternatively, revisit our list of deadlines for a bird’s eye view of the current and upcoming rules.

The backdrop (March – November 2025)

Amidst what Plastics Recyclers Europe called the slowest growth in Europe’s plastic recycling capacity ‘in years’, the Rethink Plastic Alliance published a report and set out a roadmap to help the European Union meet its sustainability goals.

It argued that deposit return schemes should be enforced ‘as soon as possible’ to meet the Regulation’s 90% separate collection rate for plastic bottles and metal cans. All single-use packaging could be subjected to clean-up costs, it added, and an earmarked percentage of Extended Producer Responsibility (EPR) fees could then be allocated to waste prevention activities, including reusable packaging systems.

Financial incentives like consumer-facing levies, environmental taxes, and ring-fencing funds are also expected to fast-track the transition from single-use to reusable packaging systems. The report also advocated for a definitive list of substances of concern that not only impact human health and the environment, but impact the success of reusable and recyclable packaging systems.

EUROPEN went on to release an interactive guidebook to walk businesses through the Regulation. While it should not be used as definitive legal guidance, the resource offers a concise summary of the PPWR – including its links to other EU legislation – and features an interactive questionnaire to help users gauge how the new rules apply to their business. A glossary of legal terms is also included.

While it doesn’t feature directly in the Regulation’s text, the Commission sparked concern for EU-wide recycling rates when it considered scrapping the €0.80/kg levy for non-recycled plastic packaging in September.

First introduced to help offset Brexit’s impact on the EU budget, the resource reportedly generated a revenue of €7.2 billion – but a proposal presented to the European Council suggested that inflation has decreased its real value.

The Commission planned to raise the call rate by 25% to reach €1/kg in 2028. European Plastics Converters (EuPC), Plastics Europe, and Petcore Europe spoke out against this idea, asserting that it would “discourage investments in the necessary infrastructures and prompt Member States to seek alternative financing solutions that do not necessarily support waste reduction efforts.”

Instead, the companies asserted that the levy should bolster a dedicated fund to help Europe’s plastics industry tackle high energy prices, costs related to labour and environmental compliance, and continent-wide plant closures and de-industrialization via a circular economy.

Not only was this hoped to encourage sustainability-minded investments across Europe, but it was also anticipated to protect the plastics industry’s competitiveness and relieve companies from any further burdens.

Soon after, Searious Business led over one hundred organizations from the European plastics value chain in asking the Directorate-General for Environment to address the cost imbalance between virgin and recycled plastics – especially as recyclers are continually forced out of business, to the detriment of the EU’s circular economy goals.

The signatories also sought out fairer and more supportive market mechanisms for recyclers; higher standards for imports and recyclate quality; and assurance that the Regulation will unlock circularity and competitiveness for the European recycling market.

A final flourish (November 2025 – December 2025)

In November 2025, rumours arose that the Commission would reopen the Regulation as part of its Environmental Simplification Package.

A coalition of packaging companies, industry associations, and NGOs acknowledged that the trialogue negotiations had left “complexities” in the final text, but warned Environment Commissioner Jessika Roswall and Executive Vice-President Stéphane Séjourné that reopening the negotiation process would cause delays, push back deadlines, and lead to “crippling uncertainty.”

In a development with potential implications for the Regulation’s recycled content targets, a joint letter signed by the European Waste Management Association (FEAD), Recycling Europe, and Plastics Recyclers Europe tasked European Commissioner Jessika Roswall with introducing priority measures for European-made plastic recyclate.

More specifically, the signatories felt that beverage bottles placed on the EU market should be required to source recycled plastic exclusively from post-consumer waste collected and recycled in Europe.

They went on to suggest that all products manufactured in Europe should source their recyclate exclusively from European post-consumer waste – and that mirror clauses should be introduced to ensure that third-country imports align with European standards.

At the Sustainable Packaging Summit 2025, CEFLEX’s Graham Houlder urged Wolfgang Trunk, policy officer for the Packaging and Packaging Waste Regulation at the European Commission, for confirmation that the then-upcoming amendments to the Environmental Omnibus would not move the Regulation’s targets for 2026. Trunk confirmed that the Commission had no plans to alter short-term deadlines.

European Commissioner for Environment, Water Resilience and a Competitive Circular Economy Jessika Roswall also sat on a panel with industry leaders from Amazon, Mondelēz, Europen, and Systemiq to talk broader geopolitical and macroeconomic matters. Roswall promised that European industries and citizens would have a seat at the table in further legislative developments, including any revisions to the Packaging and Packaging Waste Regulation.

To round off the year, the Commission published the Environmental Omnibus in December. This introduced a series of simplification measures, such as a Frequently Asked Questions document for points raised in the call for evidence and bilateral exchanges: application dates, reuse targets, labelling requirements, PFAS testing, and more.

Pallet wrappings and straps had already been exempted from the Regulation’s strict reuse targets after industry playersand MEPs criticized the text. The Omnibus raised the possibility that other packaging formats, especially those with food safety and hygiene considerations, could follow suit.

Until then, the Commission emphasized that the call for evidence would inform the roll-out of implementing measures in 2026 and 2027.

Recent developments (January – February 2026)

That brings us to 2026. So far, the Commission’s Joint Research Centre (JRC) has released a proposal to harmonize the Regulation’s waste sorting labels.

Among the 25,000 EU citizens surveyed for the proposal, harmonized and intuitive pictograms emerged as the preferred method of conveying sorting instructions. Colour-coding the waste label to the colour of the receptacle was also recommended.

The proposal goes on to argue that labels should more clearly differentiate home-compostable and industrially compostable products. This includes ‘do not throw away in nature’ labels for packaging that will not degrade in the open air.

Digital data tools could serve as an accessible solution, the JRC suggests. QR codes could account for consumers facing language barriers or disabilities, but could also be customized to suit region- or country-specific waste management rules and limited labelling space.

Nevertheless, the proposal foresees upcoming challenges in the regulatory phase. Harmonizing colour and text requirements across the patchwork of national systems across the EU might be difficult; and clarity, user-friendliness, and space efficiency may become a problem for multi-component or composite packaging.

To end on an optimistic note, Germany has just become one of the frontrunners to transpose the PPWR into national law. Under the new Packaging Law Implementation Act (VerpackDG), producers of plastic packaging must achieve a recycling quota of 75% by 2028 – and, within that figure, 70% must be mechanically recycled.

Within the same time frame, market operators must achieve a 95% recycling rate for aluminium and ferrous metals. Institutions such as dual schemes and EPR organizations will also be expected to allocate a minimum share of their budgets to packaging waste prevention measures.

They must also introduce measures to promote reuse and refill operations on the German market. Options include public awareness campaigns or seed funding for new reuse systems.

The Central Agency Packaging Register (ZSVR) will be responsible for the licensing process, which will be automated for ease of use. Independent manufacturers must apply individually, while organizations that handle EPR for multiple companies will now be required to apply.

Incoming Packaging and Packaging Waste Regulation developments include harmonized label and labelling guidelines and a ban on packaging exceeding a certain PFAS limit – both due by the 12^th August 2026.

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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