When do the PPWR requirements apply?

The PPWR has applied since 12 August 2026. It entered into force on 11 February 2025; after a transition period of 18 months it became applicable. The individual requirements arrive in stages.

The timetable

• Since 12.08.2026: substance restrictions including the PFAS limits for food contact packaging, the basic recyclability requirement under Article 6(1), and the duties of economic operators to carry out conformity assessment, compile technical documentation and issue the EU declaration of conformity for those requirements that already apply
• From 12.08.2028 at the earliest: harmonised labelling of material composition
• From 01.01.2030 at the earliest: harmonised design-for-recycling criteria and recyclability performance grades, plus the first minimum recycled content for plastic packaging
• From 01.01.2035 at the earliest: the additional assessment of whether packaging is recycled at scale
• From 01.01.2038: only packaging with recyclability grade A or B may be placed on the market
• From 01.01.2040: the second stage of minimum recycled content

Why several dates are lower bounds

Some of these are not fixed calendar dates. The design-for-recycling criteria, for example, apply from 1 January 2030 or 24 months after the corresponding delegated act enters into force, whichever is later. For companies that means the requirements are settled while the start date of individual details may move back. Plan against the earlier date: anyone who waits for the legal act has no lead time left.

What this means in practice

The deadlines from 2030 look distant but are not. Packaging that has to reach performance grade C in 2030 is being developed, signed off and tooled today. Decisions on material, multi-layer structure, label, adhesive and ink determine the later recyclability, and tools are not replaced every year.

What is immediate is this: check whether the substance limits under Article 5 are met and evidenced, clarify the three PFAS limits where there is food contact, and build the technical documentation for the requirements that already apply. The deadlines and duties in detail are on the PPWR page.