The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, replaces Directive 94/62/EC and has applied since 12 August 2026. It sets directly applicable EU rules on packaging substances, recyclability, recycled content, minimisation, reuse, labelling and extended producer responsibility. Many obligations phase in from 2028 to 2040 and several implementing acts were still pending in October 2026.
The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, is the EU law that sets uniform rules for all packaging placed on the EU market, covering substances, recyclability, recycled content, minimisation, reuse, labelling and extended producer responsibility (EPR). It entered into force on 11 February 2025, replaced Directive 94/62/EC and has applied since 12 August 2026, with many obligations phasing in between 2028 and 2040.
What is the PPWR and why does it matter?
The PPWR is a regulation, so it applies directly in every Member State without national transposition. This removes many national differences in packaging rules, although Member States still run EPR schemes, deposit return systems and penalties. The Regulation applies to all packaging, regardless of material, and to all sectors, including business-to-business transport packaging and e-commerce packaging.
For product data teams, the PPWR changes packaging from a logistics detail into a regulated product with its own conformity file. Packaging components, materials and weights become compliance data, and in time also label and data carrier content.
Who has obligations under the PPWR?
Obligations follow the economic operator roles of EU product law:
- Manufacturers carry out conformity assessment, draw up technical documentation and an EU declaration of conformity, and ensure labelling and identification.
- Importers place only compliant packaging on the market and check the manufacturer's documentation.
- Distributors verify that packaging carries the required labels and information.
- Fulfilment service providers ensure that packaging used in their services meets minimisation and other requirements.
- Producers (in the EPR sense) register in each Member State where they first make packaging available and finance end-of-life management.
The guidance adopted by the Commission on 30 March 2026, with an FAQ published in August 2026, explains how these roles apply to brands, retailers and online sellers.
What is the PPWR timeline?
The table lists key dates set in Regulation (EU) 2025/40. Several later dates depend on implementing or delegated acts.
| Date | Obligation |
|---|---|
| 11 February 2025 | Entry into force |
| 12 August 2026 | General application; conformity assessment, technical documentation and EU declaration of conformity; PFAS limits for food-contact packaging (Article 5) |
| 12 February 2027 | Deadline for national penalty rules |
| 12 August 2028 at the earliest | Harmonised material composition labelling (Article 12), or 24 months after the implementing acts apply, whichever is later |
| 1 January 2029 | Deposit return systems for single-use plastic bottles and metal beverage containers (with exemptions) |
| 1 January 2030 | Design for recycling (Article 6), minimum recycled content in plastic packaging (Article 7), minimisation (Article 10), maximum 50% empty space for grouped, transport and e-commerce packaging (Article 24), first reuse targets |
| 1 January 2035 | Packaging recyclable at scale |
| 1 January 2038 | Only recyclability grades A or B permitted |
| 1 January 2040 | Higher recycled content targets and further reuse targets |
What is still pending as of October 2026?
Several secondary acts were late or unadopted as of 17 October 2026:
- Harmonised labels (Article 12): the implementing acts were due by 12 August 2026; a draft was opened for feedback in September 2026 and adoption was expected in Q4 2026.
- EPR register format (Article 44): due by 12 February 2026; a draft implementing regulation was consulted on in August and September 2026 and had not been adopted.
- Recyclability grades (Article 6): delegated acts on design for recycling criteria are due by 1 January 2028.
- Reuse and minimisation: a first delegated act of 25 February 2026 exempts plastic pallet wrapping and straps from certain reuse targets; further acts follow from 2027.
The environmental omnibus proposal COM(2025) 982 of 10 December 2025 would suspend the authorised representative obligation in Article 45(3) until 1 January 2035. As of mid-October 2026 it remained under negotiation, so Article 45(3) applies.
What does the PPWR mean for product data?
The PPWR requires packaging data at component level, linked to each sellable item and maintained over time. Typical attributes include packaging type and level, materials, weights, recyclability evidence, recycled content, substances of concern, reusability and EPR registration numbers. The detailed attribute model is covered in PPWR product data requirements, and the link to passports in digital product passport explained.
Practical next steps
- Confirm the economic operator role for each packaging flow and market.
- Check that a technical documentation file and EU declaration of conformity exist for packaging placed on the market since 12 August 2026.
- Model packaging components as structured data in PIM or PLM, linked to items and GTINs.
- Monitor the Article 12 labelling and Article 44 register implementing acts and plan label artwork changes for 2028.
Platforms with packaging and compliance data capabilities are listed in the PXM Atlas vendor directory. For PIM selection and RFP guidance, see PIM Selection.
Frequently asked questions
When did the PPWR start to apply?
Regulation (EU) 2025/40 entered into force on 11 February 2025 and has applied since 12 August 2026. Several obligations have later dates set in the Regulation itself.
Has the PPWR been postponed?
No general postponement has been adopted. The Commission's environmental omnibus proposal of 10 December 2025 would suspend the authorised representative obligation in Article 45(3), but it remained a proposal as of 17 October 2026.
Who counts as a manufacturer under the PPWR?
The manufacturer is the person who manufactures packaging, or has it designed or manufactured, and markets it under its own name or trademark. Importers, distributors and fulfilment service providers have their own obligations.