Complying with the EU Packaging and Packaging Waste Regulation (PPWR)
Packaging is crucial for product protection and transport, but fragmented regulations create economic burdens and market inconsistencies. It also has significant environmental impacts, consuming 40% of plastics and 50% of paper in the European Union (EU) and generating 36% of municipal solid waste. High waste levels, low reuse, and inefficient recycling impede the transition to a low-carbon circular economy. To address these challenges, the EU Packaging and Packaging Waste Regulation (PPWR) establishes comprehensive rules for the entire packaging life cycle.
What is the objective of the EU Packaging and Packaging Waste Regulation?
By 2030, packaging across the EU must be reusable or recyclable in an economically viable manner, with clear waste reduction targets driving these efforts. The PPWR introduces strict requirements to reduce excessive packaging, simplify packaging for improved recyclability, and increase the use of reusable packaging. To minimize reliance on single-use packaging, the regulation promotes reuse systems and encourages eco-friendly product design.
EU-wide recyclability standards align design-for-recycling criteria to ensure packaging can be recycled efficiently. Waste prevention measures prioritize reducing packaging waste at the source, while reuse and recycling initiatives reduce environmental impact. The PPWR sets binding reuse targets, restricts certain single-use packaging types, and supports the transition to a circular economy.
When are the important deadlines for the PPWR?
The PPWR introduces key deadlines to enhance packaging sustainability and recyclability across the EU.
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December 19, 2024: The regulation was officially adopted by the European Parliament and the Council.
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January 22, 2025: The European Council published the PPWR, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 while repealing Directive 94/62/EC.
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August 12, 2026: The regulation enters into force, with Directive 94/62/EC repealed, except for specific provisions.
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February 12, 2029: Article 67(5) takes effect.
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January 1, 2030: All packaging must meet at least a grade C recyclability standard to remain on the market.
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January 1, 2038: Packaging must attain at least a grade B recyclability standard for continued market placement.
What is the scope of the EU Packaging Regulation?
The EU Packaging and Packaging Waste Regulation applies to all packaging and packaging waste in the EU, regardless of material, sector, or type. It introduces clear packaging classifications, distinguishing between sales, grouped, and transport packaging. Certain items, like cups, food containers, and sandwich bags, are only considered packaging when used for food and beverages at the point of sale. However, tea and coffee bags, as well as single-serve coffee and tea units, are considered packaging due to contamination risks in waste streams.
Labels affixed to products, like fruit stickers, fall under packaging regulations, while composite packaging is defined as units containing more than 5% additional material. Items integral to a product and disposed of with it—such as adhesives, paints, and varnishes—are not classified as packaging. Additionally, single-use plastic packaging remains regulated under Directive (EU) 2019/904, regardless of its plastic content. Responsibility for compliance falls on producers, excluding farmers and primary sector businesses.
Packaging requirements
Under the PPWR, packaging is considered "placed on the market" when first distributed or used, whether sold or provided for free. However, packaging already on the market before the regulation takes effect is exempt from the new sustainability and labeling requirements. To reduce waste, packaging must minimize volume and weight while ensuring product safety, hygiene, and consumer acceptance. A key focus is increasing recycled content in plastic packaging through improved recycling systems and higher-quality secondary raw materials.
Packaging must be either highly reusable or fully recyclable, with a recyclability grade of A, B, or C. This grade is based on:
- design-for-recycling criteria starting in 2030
- both design-for-recycling and recycled-at-scale criteria starting in 2035.
Only packaging rated C or higher will be permitted on the market, with stricter rules in 2038 requiring a minimum grade of B. Businesses must comply with these recyclability standards by January 1, 2030, allowing time for adaptation.
Additionally, the regulation aims to reduce packaging waste sent to landfills, aligning with the waste hierarchy. To protect human health and the environment, it restricts hazardous substances such as lead, cadmium, mercury, and hexavalent chromium, requiring their gradual phase-out.
Additional restrictions under the EU Packaging Regulation
Bisphenol A (BPA), commonly used in food-contact materials such as plastic kitchenware and can linings, poses health risks even at low exposure levels, as confirmed by a 2023 EFSA assessment. On December 19, 2024, the European Commission adopted a ban on BPA in food packaging materials to safeguard health and the environment. An 18-month phase out period following this date accounts for industry adaptation to the ban. Additionally, the regulation limits harmful substances in packaging at the source to ensure safer materials throughout their life cycle, including during waste management.
Enforcement and penalties
The European Commission has the authority to set minimum reuse rotations for commonly used packaging formats and adopt delegated and implementing acts to ensure uniform application across Member States. Compliance is enforced through market surveillance, with Member States establishing effective, proportionate, and dissuasive penalties for violations. Economic operators must provide authorities with relevant information to demonstrate compliance, while producers bear financial responsibility for packaging waste management under Extended Producer Responsibility (EPR), covering collection, sorting, and recycling. These measures ensure a consistent and enforceable regulatory framework across the EU.
What is the role of PFAS in the EU packaging regulation?
Per- and polyfluorinated alkyl substances (PFAS) are widely used synthetic chemicals, particularly in food-contact materials and packaging, but their persistence in the environment and serious health risks make them a major concern. To protect human health, the PPWR restricts PFAS in food-contact packaging when exceeding specific thresholds.
Additionally, the European Commission will review these restrictions to ensure coherence with other EU regulations and prevent regulatory overlaps. The new rules further mandate minimizing substances of concern in packaging, reinforcing efforts to reduce exposure and environmental contamination.
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