PPWR, the new Packaging and Packaging Waste Regulation. What changes does Regulation (EU) 2025/40 introduce?
The new Regulation (EU) 2025/40 is one of the European Union’s most significant initiatives supporting the circular economy (an economic model based on keeping products and packaging materials in use for as long as possible through reuse and recycling, thereby reducing waste generation and the consumption of virgin resources). The EU Packaging and Packaging Waste Regulation aims to reduce the negative environmental impact of packaging and decrease the continuously growing volume of packaging waste generated on a regular basis. This document is commonly referred to as the “Packaging Regulation” or by its acronym, PPWR. Its provisions will apply directly in all Member States of the European Union.
What is PPWR?
PPWR (Packaging and Packaging Waste Regulation) – the EU regulation on packaging and packaging waste, whose primary objective is to streamline and reduce the negative impact associated with all packaging placed on the market. The new regulation replaces the existing directive; therefore, its provisions will apply uniformly across all Member States of the European Union.
What are the objectives of PPWR? These include:
reduction of packaging waste,
reduction of the amount of waste generated by consumers and businesses,
reduction of unnecessary packaging (e.g., placing a product that is already packaged into additional layers of packaging),
improvement of the recyclability of all types of packaging,
increased recovery rates and achievement of recycling targets,
development of the circular economy,
reduction of emissions associated with packaging production.
Who will be required to comply with the requirements of the PPWR Regulation?
The key requirements of the PPWR Regulation will apply across the entire market. The new packaging requirements will affect product manufacturers, packaging manufacturers, importers, distributors, as well as companies engaged in e-commerce.
The key packaging requirements include:
Mandatory packaging recyclability and design for recycling.
One of the key pillars of PPWR is the requirement for packaging recyclability and the obligation to design packaging in accordance with circular economy principles. The new packaging requirements are based on the Design for Recycling approach. The Design for Recycling criteria will determine whether a given packaging format is suitable for efficient processing and recycling at the end of its service life.
Recyclability Classes and RecyClass.
A major change introduced by PPWR will be the implementation of Recyclability Classes (Performance Grades). Packaging will be assessed based on how effectively it can be recycled. In practice, many companies will rely on tools such as RecyClass – a European packaging recyclability evaluation and certification system that supports the design of packaging compliant with recycling requirements and new EU legislation. Recyclability Classes (Performance Grades) are intended to assess and verify whether packaging complies with the applicable requirements and can continue to be placed on the market.
Recycled Content.
The next requirement will be the incorporation of a specified level of recycled content in plastic packaging. This requirement primarily affects industries that use plastic packaging. The mandated recycled content levels will increase gradually but steadily over time in order to promote the greater use of secondary raw materials.
Under the current circumstances, many companies will conduct assessments to determine whether their existing packaging materials and overall material composition comply with the requirements set out in the PPWR.
Reduction of Unnecessary Packaging.
One of the most widely discussed requirements is the reduction of unnecessary packaging. Companies will be required to minimize excessive packaging dimensions, empty space, and unnecessary protective components. The objective of this measure is to reduce packaging waste and decrease the volume of waste requiring collection, treatment, and disposal.
Mandatory Recycling Targets and Producer Responsibility.
PPWR also introduces mandatory recycling targets aimed at achieving the highest possible levels of material recovery. An important element of the regulation is the principle of Extended Producer Responsibility (EPR). This means that producers will bear greater responsibility for packaging throughout its entire life cycle.
Reusable Packaging Systems and Reuse Targets.
The PPWR Regulation promotes the implementation of reusable packaging systems while establishing specific reuse targets for selected sectors of the economy. Many companies will be required to invest in reusable packaging systems that help reduce the use of single-use packaging. This transition away from single-use packaging is a key driver of the changes that form part of the broader transformation of the packaging model.
Deposit Return Systems (DRS) and New Packaging Labelling Requirements.
The next important element is Deposit Return Systems (DRS), which are intended to increase the collection rates of beverage packaging. At the same time, harmonized packaging labelling is being introduced. The new packaging labelling requirements are designed to help consumers sort waste correctly and identify the materials from which packaging is made. The changes will also apply to self-adhesive labels, which must be designed in a manner that does not hinder recycling processes. In addition, transport packaging will be required to comply with new requirements related to recyclability and reuse.
Which industries will the packaging-related changes apply to?
These packaging-related changes will affect virtually all businesses that place packaged products on the market. Companies using transport packaging, plastic packaging, or packaging made from plastic materials will be required to verify the full compliance of their packaging with the new applicable requirements. Any business placing packaging on the market will be responsible for ensuring its compliance with the new regulations.
Among the sectors covered by the new packaging requirements are, among others:
- food manufacturers,
- packaging manufacturers,
- the cosmetics industry,
- the pharmaceutical industry,
- retail trade,
- retail chains,
- the e-commerce sector,
- the beverage industry,
- the food service sector, particularly with regard to takeaway food packaging,
- the logistics sector,
- transport and distribution of goods,
- manufacturers of chemicals,
- the consumer electronics and household appliances industry,
- the apparel industry,
- the B2B sector using transport and secondary packaging.
How much time do businesses have to implement the changes?
Regulation (EU) 2025/40 entered into force in 2025, and most businesses are already preparing to implement the new obligations, as some of the provisions will become applicable as early as August 2026. Additional requirements will be introduced in stages through 2030, 2035, and 2040. Therefore, it is advisable to start analysing the PPWR requirements now, assessing packaging compliance, evaluating recyclability, verifying recycled content, and designing packaging that meets the regulatory requirements and remains competitive in the future packaging market.
The greatest challenge will be:
- the obligation to design packaging in accordance with the Design for Recycling criteria,
- ensuring the required recycled content,
- achieving recycling targets,
- implementing Deposit Return Systems (DRS),
- adapting self-adhesive labels to the new identification and recycling requirements,
- ensuring that packaging compliant with the requirements can be placed on the market.
Key PPWR Dates
| Date / Deadline | Implications for Packaging | Practical Significance |
| 22 January 2025 | Publication of the PPWR as Regulation (EU) 2025/40 | Initiation of the formal implementation process |
| 11 February 2025 | Entry into force of the PPWR | Companies should begin mapping their packaging portfolio and suppliers |
| 12 August 2026 | The PPWR becomes directly applicable throughout the EU | From this date, packaging compliance must be actively managed |
| By 1 January 2028 | The Commission is to adopt delegated acts defining detailed Design for Recycling criteria and the recyclability assessment methodology | The delegated acts will specify the rules for determining A/B/C classes for individual packaging categories |
| 1 January 2030 or later | Packaging placed on the EU market must achieve at least Class C, corresponding to a minimum recyclability rate of 70% | Packaging with recyclability below 70% will be considered technically non-recyclable |
| 2030 | Introduction of the formal recyclability classification system: A, B, C | The classification will become an element of the packaging conformity assessment |
| 2035 | Packaging must be recyclable at scale within real-world collection, sorting, and recycling systems | The mere theoretical possibility of recycling will no longer be sufficient |
| 1 January 2038 | Class C is to be phased out as an acceptable compliance level | In practice, only Classes A and B will remain on the market as acceptable options for the long term |
EUNR and the Future of the Packaging Market
An important element of the new regulations will also be the EUNRs (European Union National Registers), which are intended to streamline the management of producer obligations at the European level. For many companies, this will entail additional packaging-related reporting obligations.
The new Packaging and Packaging Waste Regulation (PPWR) represents the most significant reform of the European packaging market in several decades. It introduces new requirements that will drive the transformation of packaging models, increase recycling obligations for packaging, accelerate the development of the circular economy, and impact the entire packaging market across EU Member States.
In this context, businesses will need to adapt their products, processes, and documentation. At the same time, it presents an opportunity to build a competitive advantage in a market where packaging compliance, recycling targets, and responsible packaging design will play an increasingly important role.
Summary – PPWR (Regulation (EU) 2025/40) and Its Impact on Businesses
The Packaging and Packaging Waste Regulation (PPWR), namely Regulation (EU) 2025/40 on packaging and packaging waste, is one of the most significant environmental reforms introduced by the European Union in recent years. Its primary objective is to reduce packaging waste, increase recycling rates, and accelerate the transition to a circular economy. Unlike the previous directive, the PPWR takes the form of a regulation, meaning that its provisions will apply directly and uniformly across all EU Member States.
The new legal requirements will affect virtually the entire packaging value chain – from packaging manufacturers, product manufacturers, importers, and distributors to companies engaged in e-commerce. In practice, this means that any company placing packaged products on the market will be required to adapt its processes, materials, and documentation to comply with the new requirements.
An important change will also be the introduction of recyclability classes (Performance Grades), which will enable the assessment of how effectively a specific packaging format can be materially recycled. Companies will use assessment systems such as RecyClass to carry out comprehensive packaging compliance verification.
The PPWR also introduces robust measures aimed at reducing so-called excessive packaging. Businesses will be required to minimise empty space within packaging, eliminate unnecessary protective layers, and optimise packaging volume.
In summary, the PPWR is not merely another environmental regulation but a comprehensive reform of the European packaging market. It will drive changes in packaging design, manufacturing, distribution, and end-of-life management on an unprecedented scale. For businesses, this means the need to invest in and adapt their processes to meet the new requirements. At the same time, companies that prepare early for the upcoming changes may gain a competitive advantage, improve material efficiency, and strengthen their reputation as responsible and sustainable businesses.