The Packaging and Packaging Waste Regulation (EU) 2025/40 sets out sustainability and labelling requirements for packaging throughout its life cycle, including production, use and waste management.
What Does it cover?
The regulation covers all packaging and packaging waste, regardless of material or origin (industrial, retail, household, etc.). The Regulation covers:
- all packaging and packaging waste, regardless of material or origin,
- sets requirements for manufacturing, composition, and reusable or recoverable nature of all packaging placed on the EU market,
- includes packaging waste management and prevention measures
Annex I of the regulation includes a list of examples of items that ‘are’ and ‘are not’ packaging.
What are the new rules?
The Packaging and Packaging Waste Regulation, or “PPWR”, is about greening our packaging in Europe. That means cutting down on waste, making packaging more eco-friendly, and giving you sustainable choices.
It introduces requirements to:
- Make all packaging recyclable by 2030.
- Decrease the use of ’virgin’ materials in packaging.
- Increase packaging made from recycled materials.
- Limit unnecessary packaging and introduce more reusable options.
- Minimise the presence of harmful substances, to protect human health and the environment. All packaging must be recyclable, meaning that it must be:
– designed for material recycling;
– able to be collected, sorted and recycled at scale when it becomes waste. - Promote innovation in new circular business models; producers are responsible for the entire life cycle of their packaging, including waste management.
- An EU declaration of conformity will need to be issued for packaging placed and/or used in relation to making available products on the EU market / Union.
When will this be implemented?
The PPWR came into force on the 11 February 2025 and applies from August 2026. It replaces the existing Packaging and Packaging Waste Directive 94/62/EC (PPWD).
What do I need to do to comply?
As producers will be responsible for the entire life cycle of their packaging, including waste management. Under what the regulation is calling ‘extended producer responsibility’ producers must:
- cover the necessary costs of collection, sorting and recycling
- incentivise eco-design and recyclability through modulated fees
- ensure financial transparency and accountability
- register and report via the relevant member states extended producer responsibility (EPR) scheme
Manufacturers and importers must:
- conduct conformity assessments(manufacturers) or ensure that a conformity assessment has been carried out (importers), and maintain technical documentation for a period of 5 years, or 10 years in the case of reusable packaging;
- issue an EU declaration of conformity (manufacturer), stating that their packaging meets the regulation’s requirements;
- ensure proper labelling and documentation;
- take corrective action (e.g. recall or withdraw) if non-compliance is suspected and inform authorities.
- The new Regulation will apply to all packaging and packaging waste, although micro-enterprises will be subject to lighter rules.
Further key points can be found here: Packaging and packaging waste (from 2026) | EUR-Lex
What is the difference between a ‘Producer’ and ‘Manufacturer’?
The regulation defines the ‘manufacturer’ … “as any natural or legal person that manufactures packaging or a packaged product”.
Whereas the ‘producer’ is defined as a manufacturer, importer or distributor.
The producer and other economic operators have additional clarifications within the definitions (Article 3) of the regulation.
Do I need to register as a ‘producer’?
Under the extended producer responsibility (EPR) scheme, all Member States shall establish a database for the registration of producers. Producers, or its authorised representative for extended producer responsibility, must register and report into this database going forward.
From February 2026, member states will have 18 months to establish the database/register.
Producers, or its authorised representative for extended producer responsibility, shall report by June for each full preceding calendar year, and producers will therefore have to report to the national EPR registers according to the new harmonised rules for the first time by 1 June 2029.
Further information and guidance: