PPWR: Packaging & Packaging Waste Regulation
Adapt your packaging to EU Regulation 2025/40 (PPWR)
The entry into force of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR – Packaging and Packaging Waste Regulation) marks a structural shift for all companies that produce, use, or place packaging on the European market.
The PPWR introduces a new approach to packaging design, management, and compliance, with direct impacts on:
- packaging design;
- materials used;
- recyclability and reuse;
- hazardous substances;
- labeling;
- technical documentation;
- responsibilities throughout the supply chain.
From the food sector to retail, from manufacturing industries to e-commerce, companies will be required to demonstrate packaging compliance through technical assessments, documented data, and increasingly structured verification processes.
Who the PPWR applies to
One of the most significant aspects of EU Regulation 2025/40 is the broad scope of its application.
The PPWR does not apply exclusively to packaging manufacturers, but to all companies placing packaging or packaged products on the European market, regardless of the industry sector or the material used.
The regulation applies to all packaging intended for the European Union market, including:
- primary packaging;
- secondary packaging;
- grouped packaging;
- transport packaging;
- e-commerce packaging;
- single-use packaging;
- food packaging;
- industrial and commercial packaging.
All major packaging materials are covered, including:
- plastic;
- paper and cardboard;
- glass;
- metal;
- wood;
- aluminum;
- composite materials.
Which economic operators are involved
The regulation introduces specific obligations for different actors across the supply chain.
Manufacturers
Companies that manufacture packaging or packaged products, or market them under their own brand, are responsible for compliance with PPWR requirements, including conformity assessment obligations, technical documentation, and the EU declaration of conformity.
Importers
Companies introducing packaging or packaged products into the European Union from non-EU countries must ensure that such packaging complies with the requirements of the regulation before being placed on the market.
Distributors
Distributors and commercial operators also have specific responsibilities in ensuring that the packaging made available on the market complies with the applicable regulatory requirements.
The most affected sectors
Although the PPWR has a cross-sectoral scope, some industries will be particularly impacted by the obligations introduced by the regulation, including:
- food & beverage;
- food packaging and food contact
- materials (FCMs);
- large-scale retail and retail;
- e-commerce;
- cosmetics;
- pharmaceuticals;
- nutraceuticals;
- Ho.Re.Ca.;
- manufacturing industry;
- logistics and transportation.
For many companies, the PPWR will require a review of materials, packaging design, technical documentation, supplier management, and compliance processes throughout the entire supply chain.
What changes with the PPWR
With the entry into force of the PPWR, the European Union is introducing a significant shift in the approach to packaging and packaging waste management.
Regulation (EU) 2025/40 replaces the previous Directive 94/62/EC, moving from a system based on different national transpositions to a regulation directly applicable in all Member States.
The objective is to create a harmonized European framework, reducing regulatory differences between countries and increasing the level of control over the sustainability of packaging placed on the market.
For companies, this means dealing with more structured, measurable, and documentable requirements involving not only the final packaging, but also design, supply chain, materials, and compliance processes.
The Main Obligations Introduced by the Regulation
The PPWR introduces specific requirements that will progressively apply to all types of packaging.
The main regulated areas include:
- packaging recyclability;
- minimum recycled content;
- reduction of packaging weight and volume;
- restrictions on single-use packaging;
- compostability requirements;
- reuse and refill systems;
- harmonized European labeling;
- restrictions on hazardous substances such as PFAS and heavy metals;
- traceability obligations;
- EU declaration of conformity for packaging.
Many of the obligations introduced by the regulation will require companies to collect technical data, prepare structured documentation, and implement conformity assessment processes throughout the entire supply chain.
An Operational impact on design, procurement, and compliance
The PPWR should not be interpreted solely as an environmental regulation.
The new provisions will have concrete impacts on:
- packaging design;
- material selection;
- procurement;
- supplier qualification;
- document management;
- laboratory activities;
- labeling;
- sustainability;
- regulatory compliance.
In many cases, existing packaging solutions will need to be reviewed to verify compliance with future requirements regarding recyclability, reuse, or recycled content.
For this reason, many companies are already starting preliminary technical assessment and gap analysis activities on their packaging portfolios.
Timeline PPWR: key deadlines
The PPWR introduces a progressive implementation of requirements, with obligations entering into force at different stages between 2026 and 2040.
Understanding the regulation timeline is essential for properly planning compliance activities, avoiding operational issues, and structuring the compliance pathway in advance.
| 11 February 2025 | Entry into force of the PPWR |
| 12 August 2026 | The first obligations under the regulation become applicable, including:
|
| 12 February 2027 | Requirements relating to refill systems in the Ho.Re.Ca. sector begin to apply.
By this stage, several delegated acts and operational guidelines are also expected regarding:
|
| 12 February 2028 | Requirements relating to the following enter into force:
The regulation also introduces increasingly stringent criteria against overpackaging, with particular focus on unnecessary packaging and excessive empty space. |
| 12 August 2028 | The new European rules on harmonized packaging labeling become applicable.
Labels must facilitate:
Digital systems such as QR codes and dematerialized information tools will also be introduced. |
| 1 January 2030 | Some of the most impactful PPWR requirements enter into force, including:
|
| 2035 – 2038 | Starting from 2035, only packaging recyclable at scale will be allowed on the market. |
| From 2038 | Only packaging belonging to the highest recyclability performance classes may be placed on the market. |
| 2040 | The regulation introduces further increases relating to:
|
The main requirements introduced by the PPWR
EU Regulation 2025/40 introduces new sustainability requirements aimed at redefining how packaging is designed, produced, used, and managed throughout the entire supply chain.
The objective of the regulation is to promote a more circular packaging model by reducing the environmental impact of packaging and increasing the level of regulatory harmonization within the European Union.
For many companies, this will require reviewing materials, technical documentation, procurement processes, and packaging design criteria.
Among the most relevant aspects introduced by the PPWR are:
PFAS and hazardous substances in packaging
The PPWR introduces specific restrictions concerning the presence of hazardous substances in packaging, with particular attention to PFAS in food contact materials.
From 12 August 2026, food contact packaging will have to comply with specific conformity thresholds, which must be demonstrated through technical documentation and analytical evidence.
For many companies, it will therefore be essential to integrate regulatory verification activities and laboratory testing.
Thanks to the synergy with the international Tentamus network, TentaConsult Italia supports companies through:
- PFAS, total fluorine, and heavy metals analysis;
- food safety and migration testing on sensitive food contact packaging;
- shelf-life studies for packaging reduction and optimization projects.
Reuse, refill, and packaging reduction
Progressive application: starting from 2027
The PPWR introduces progressive targets for packaging reuse and requirements aimed at reducing packaging weight, volume, and unnecessary packaging.
Key deadlines include:
- from 12 February 2027: refill systems for the Ho.Re.Ca. sector;
- from 12 February 2028: obligations relating to reusable packaging in the Ho.Re.Ca. sector;
- from 1 January 2030: mandatory minimum reuse targets for specific packaging categories and limits on empty space in e-commerce and transport packaging.
Particular attention will be given to:
- single-use packaging;
- e-commerce packaging;
- grouped packaging;
- refill systems;
- packaging for the Ho.Re.Ca. sector.
Companies will therefore need to assess not only the compliance of the materials used, but also the overall efficiency of the packaging system from a circular economy perspective.
Harmonized European Labeling
Application: from 12 August 2028
The regulation introduces a harmonized European packaging labeling system.
The new labels will aim to facilitate:
- material identification;
- separate waste collection;
- proper end-of-life packaging management;
- packaging traceability.
Digital tools such as QR codes and dematerialized information systems will also be introduced.
Packaging Recyclability
Application: from 1 January 2030
Starting from 2030, all packaging must be designed to be recyclable according to harmonized European criteria.
The assessment will not concern only the theoretical recyclability of packaging, but also the actual ability of the packaging to be collected, sorted, and recycled within existing industrial processes.
This will require particular attention in the selection of:
- materials;
- multi-material structures;
- coatings;
- adhesives;
- components and assembly systems.
Minimum Recycled Content
Application: from 1 January 2030
The regulation introduces mandatory minimum percentages of recycled content for certain types of plastic packaging.
Companies will therefore need to demonstrate the use of post-consumer recycled material through supply chain data, technical specifications, and supporting documentation.
This aspect will have a particularly significant impact on plastic packaging intended for the food, retail, and consumer goods sectors.
TentaConsult Italia support for PPWR compliance
Adapting to the PPWR requires a multidisciplinary approach involving regulatory, technical, documentary, and analytical aspects.
TentaConsult Italia supports companies, manufacturers, and packaging supply chain operators with structured services designed to facilitate compliance with EU Regulation 2025/40.
Regulatory and Strategic Consulting
We support companies in interpreting the regulation and defining a compliance pathway aligned with the requirements applicable to their packaging solutions.
Services include:
- PPWR training: requirements and obligations;
- Regulatory updates: monitoring and communication;
- Technical and regulatory assessments: packaging compliance verification and gap analysis;
- Strategic support: development of conformity assessment systems and supply chain analysis for the preparation of the EU Declaration of Conformity;
- Specific packaging compliance evaluations: targeted conformity assessments.
Laboratory Analysis and Technical Support
Through the Tentamus network, we integrate consulting services with specialized analytical activities for the technical verification of compliance.
Activities include:
- PFAS, total fluorine, and heavy metals analysis;
- food safety and migration testing on sensitive food contact packaging;
- shelf-life studies for packaging reduction and optimization projects.
FAQ
What is the PPWR?
The PPWR (Packaging and Packaging Waste Regulation) is the new European Regulation EU 2025/40 on packaging and packaging waste. The regulation replaces Directive 94/62/EC and introduces harmonized European requirements for packaging sustainability and compliance.
When does the PPWR become applicable?
The regulation entered into force on 11 February 2025, while the first obligations will apply from 12 August 2026. Requirements will be introduced progressively until 2040.
Which companies does the PPWR apply to?
The PPWR applies to all companies placing packaging or packaged products on the European market, including manufacturers, importers, distributors, e-commerce operators, and companies marketing products under their own brand.
Does the PPWR also apply to food packaging?
Yes. Food contact packaging is among the categories most affected by the regulation, particularly regarding PFAS, food safety, migration testing, and hazardous substances.
Does the PPWR introduce obligations regarding PFAS?
Yes. From 12 August 2026, food contact packaging must not exceed the specific PFAS thresholds established by the regulation.
Will the EU Declaration of Conformity for packaging become mandatory?
Yes. The PPWR introduces the obligation to prepare an EU Declaration of Conformity for packaging, supported by technical documentation and conformity assessment activities.
Will all packaging have to be recyclable?
From 2030, all packaging must comply with specific recyclability criteria established by the PPWR. From 2038 onward, only packaging belonging to the highest recyclability performance classes will be allowed on the market.
Does the PPWR introduce labeling obligations?
Yes. From 12 August 2028, a harmonized European labeling system will become applicable to facilitate separate waste collection and end-of-life packaging management.
Can TentaConsult Italia also support laboratory activities?
Yes. In addition to technical and regulatory support activities, thanks to the Tentamus network, TentaConsult Italia can support companies with:
- PFAS testing;
- total fluorine analysis;
- food contact materials (FCM/MOCA) and migration testing;
- heavy metals testing;
- shelf-life studies;
- technical packaging assessments.