Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) has generally applied since 12 August 2026. This marks an important milestone towards a more coherent European framework for packaging, bringing greater attention to the responsibilities of the economic operators that place packaging on the EU market.
From this date, manufacturers are required to demonstrate the conformity of packaging placed on the market with the applicable PPWR requirements. This includes maintaining the necessary technical documentation and drawing up an EU Declaration of Conformity. The Regulation also establishes important requirements for producers, including in relation to Extended Producer Responsibility (EPR), and reinforces the principle that those placing packaged products on the market must take responsibility for their environmental impact.
The entry into application does not mean that all PPWR obligations take effect at once. The Regulation introduces a phased timetable, with further requirements to be specified and applied over the coming years. Key forthcoming milestones include compostability requirements for certain packaging formats from February 2028; harmonised packaging-labelling requirements from August 2028; and labelling obligations for reusable packaging from February 2029.
From 1 January 2030, packaging-minimisation and design-for-recycling requirements, minimum recycled-content targets for plastic packaging and certain packaging restrictions will begin to apply. By 2035, packaging will need to be recyclable at scale, while 2040 will bring further reuse and recycled-content targets. These deadlines underline the importance for all actors in the value chain to begin preparing early, while recognising that the practical conditions for implementation will continue to evolve.
To support stakeholders in interpreting the Regulation, the European Commission has published the second edition of its PPWR Frequently Asked Questions. The updated document provides additional clarification on, among other topics, the definitions of producers and manufacturers, transport packaging, substances of concern, technical documentation, conformity requirements and EPR obligations.
For EXPRA, consistent implementation across Europe will be essential. Harmonisation should provide clear common requirements, avoid unnecessary fragmentation and support well-functioning national EPR systems. It should also ensure that obligations are applied fairly to all relevant producers, including online sellers and companies established outside the Member State where packaged products are placed on the market.
EXPRA will continue to contribute the experience of its members to the European debate, engage constructively with the Commission and follow the forthcoming secondary legislation closely. The next phase of PPWR implementation must translate the Regulation’s objectives into workable rules that support circular packaging systems, effective collection and sorting, high-quality recycling and fair, transparent EPR.
Important links:
Commission PPWR application update
Updated PPWR FAQ
Regulation (EU) 2025/40