What is the PPWR?

The PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It has applied directly in all EU member states since 12 August 2026 and replaces the Packaging Directive 94/62/EC. It governs packaging across the entire life cycle: substances, recyclability, recycled content, reuse, packaging minimisation, labelling and extended producer responsibility.

Why the legal form makes the difference

A directive had to be transposed into national law by every member state, which produced 27 readings. A regulation applies directly: the same requirement word for word in Berlin, Barcelona and Bucharest. National rules such as the German packaging act are being adapted but do not change that direct application. For companies this shifts the work from national adaptation to evidence: no longer “what does this market require?” but “what do I substantiate it with?”.

What applies since the application date

• Substance restrictions (Article 5). The sum of the concentrations of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg in packaging and packaging components. There is no general exemption for small volumes or small companies.
• PFAS in food contact packaging (Article 5(5) and (6)). Three limits: 25 ppb for individual PFAS in targeted analysis, 250 ppb for the sum of targeted PFAS and 50 ppm for PFAS including polymeric PFAS. Where total fluorine exceeds 50 mg/kg, evidence must be provided on request of how much of the fluorine is attributable to PFAS.
• Conformity (Articles 15, 38, 39). Carry out the conformity assessment, compile the technical documentation and issue the EU declaration of conformity, for those requirements that already apply.
• The basic recyclability requirement under Article 6(1).

What follows later

The core material requirements arrive in stages, and several dates are lower bounds: if the corresponding legal act comes later, the date moves with it. Harmonised labelling of material composition from 2028 at the earliest, design-for-recycling criteria with performance grades and the first minimum recycled content for plastic packaging from 2030 at the earliest, the additional assessment of recycling at scale from 2035 at the earliest, only grades A or B from 2038, and the second quota stage from 2040.

Who carries the duties

The regulation distributes the duties; it does not distribute the evidence. Central responsibility for conformity sits with the producer, in practice often the brand owner, even where packaging or product were developed or manufactured by third parties. Suppliers have to provide the information and documents needed for that. Extended producer responsibility is a separate question: who counts as producer there depends on who first makes the packaging available in a given member state.

The text is in the Official Journal. Which requirement applies when, and who is responsible for it, is set out in detail on the PPWR page.