The EU packaging regulation replaced a directive with directly applicable law

Regulation (EU) 2025/40, the EU packaging regulation known as the PPWR, was published in the Official Journal on 22 January 2025, entered into force on 11 February 2025 and applies from 12 August 2026. Regulation (EU) 2025/40 repeals Directive 94/62/EC and amends Regulation (EU) 2019/1020 on market surveillance and Directive (EU) 2019/904 on single-use plastics.

Because it is a regulation and not a directive, no national transposition stands between the text and the operator. The same wording applies in Romania, in Germany and in Poland from the same date, and a national packaging law can no longer produce twenty-seven different readings of the same requirement.

This page maps what the EU packaging regulation actually requires, when each obligation starts, which start dates are fixed and which are tied to acts the Commission has not yet adopted, and how the text reaches the United Kingdom. Every statement below is tied to the article or the official document that carries it.

The PPWR text stands as published, with corrigenda in six language versions

No amendment to Regulation (EU) 2025/40 has been adopted. Six corrigenda have been published, and every one of them corrects a specific language version rather than the substance: French in May 2025, Czech and Bulgarian in September 2025, Swedish in November 2025, Italian in November 2025, Spanish in July 2026 and German in August 2026. There is no English-language corrigendum.

Two Commission documents sit beside Regulation (EU) 2025/40 and are routinely mistaken for it. The interpretive guidance, Commission Notice C(2026) 3702, was published in the Official Journal C, 2026/3084 on 10 June 2026. It is a notice, not a delegated act: it explains, it does not create obligations. The FAQ published by the Directorate-General for Environment on 3 August 2026 has the same character.

One delegated act has been adopted under the Regulation and is described further down. Everything else in the 2028 to 2035 calendar waits on delegated or implementing acts that do not yet exist, which is why several of the dates below are conditional rather than fixed.

What the EU packaging regulation actually required on 12 August 2026

Four families of obligation under Regulation (EU) 2025/40 took effect immediately. The fourth is the one most often placed in 2030 by mistake.

Annex VII and Annex VIII, the two paperwork annexes

Two annexes carry the paperwork. Annex VII of Regulation (EU) 2025/40 sets out what the technical documentation must contain, and it is the file the conformity assessment of Article 38 produces. Annex VIII sets out the model for the EU declaration of conformity required by Article 39, one per packaging type. By drawing it up, the manufacturer assumes responsibility for the packaging’s compliance, Article 39(4). Both are kept for 5 years for single-use packaging and 10 years for reusable, Article 15(3). Both are covered field by field on the declaration of conformity page.

Article 45(3), the duty to appoint an authorised representative for extended producer responsibility in Member States where the producer is not established, also applies from that date. A Commission proposal of 10 December 2025 would suspend it until 1 January 2035, but that proposal has not been adopted, so the obligation stands.

PPWR key dates, and which of them are conditional

Regulation (EU) 2025/40 staggers its obligations over fifteen years. Several of the headline dates are not fixed: the text says the obligation starts on a calendar date or a set period after a delegated or implementing act enters into force, whichever is the latest. If the act arrives late, the obligation moves with it.

PPWR dates from entry into force to 2028

PPWR dates from 2029 to 2040

One reading habit saves a great deal of confusion. In supplier conversations the 2030 dates are quoted as if they were settled, when four of them move with acts the Commission has until 2028 to adopt. The August 2026 dates, by contrast, are unconditional and are already being enforced through purchasing requirements.

PPWR obligations attach to roles, and one company can hold several

Regulation (EU) 2025/40 applies to all packaging placed on the EU market, whatever the material, and to all packaging waste, whatever its origin. It makes no distinction between consumer and business supply chains, so transport and grouped packaging sit inside the scope next to sales packaging. What decides who owes what is the definitions in Article 3 of Regulation (EU) 2025/40, not the shape of the org chart.

The manufacturer definition, in full

Two things follow that catch people out. Own-brand marketing makes you the manufacturer even when someone else runs the machines. And the micro-enterprise rule does not exempt anyone: it moves the manufacturer role onto the supplier, and only where that supplier is in the same Member State.

The four roles the articles create

In flexible packaging these roles stack. A converter can be the manufacturer of packaging sold under its own range, a supplier of information under Article 16 for film converted to a customer specification, and a producer for EPR in the markets where it sells directly. Which documents each party owes changes with the answer, which is why the mapping is done per contract. The full allocation is set out on the declaration of conformity page.

Recyclability arrives in three layers, on three different dates

This is where most timelines go wrong, because Regulation (EU) 2025/40 splits one idea across three provisions with three start dates.

Article 6(1) states that all packaging placed on the market shall be recyclable, and it carries no deadline of its own, so it applies from 12 August 2026. Article 6(2)(a) adds the design-for-recycling criteria, from 1 January 2030 or 24 months after the delegated acts under Article 6(4), whichever is the latest. Article 6(2)(b) adds separate collection, sorting and recycling at scale, from 1 January 2035 or 5 years after the implementing acts under Article 6(5), which are themselves due by 1 January 2030.

Until the design-for-recycling date arrives, the Commission’s position is that the earlier regime governs: manufacturers comply with the requirements under Directive 94/62/EC and the related harmonised standards, for instance EN 13430:2004 on packaging recoverable by material recycling. The Commission adds a point worth keeping in the file: manufacturers do not need to perform the Article 38 and Annex VII conformity assessment for recyclability until the Article 6(4) delegated acts enter into force.

Grades A, B and C decide market access

Article 6(3) is the provision that ties market access to the grade. The manufacturer assesses recyclability on the basis of the acts under paragraphs 4 and 5, the result is expressed in grades A, B or C from Table 3 of Annex II, and from 1 January 2030, or 24 months after the delegated acts, packaging shall not be placed on the market unless it is recyclable within grades A, B or C. From 1 January 2038 it must be within grades A or B. Table 3 sets the thresholds at 95 %, 80 % and 70 %; below 70 % the packaging is non-compliant with the grades, technically non-recyclable, and its placing on the market is restricted. There is no fourth grade. The grades are set out on the recyclability grades page.

Recycled content is averaged per plant and per year, not per pouch

The EU packaging regulation sets minimum recycled content in plastic packaging in Article 7, applicable from 1 January 2030, or three years after the implementing act under Article 7(8) enters into force, whichever is the latest. Four categories carry different percentages: 30 % for contact-sensitive PET packaging other than single-use beverage bottles, 10 % for contact-sensitive packaging in other plastics with the same carve-out, 30 % for single-use plastic beverage bottles whatever the polymer, and 35 % for the rest. Article 7(2) raises them to 50, 25, 65 and 65 % from 1 January 2040.

The measurement rule in the EU packaging regulation is the part that changes procurement, and it is worth quoting to buyers. The targets are calculated as an average per manufacturing plant and per year, and the Regulation’s recitals define the manufacturing plant as one industrial facility where packaging is manufactured. A buyer asking for the full percentage in every individual delivery is asking for more than the EU packaging regulation requires.

The two exclusion regimes

Two exclusion regimes sit beside the targets and are frequently merged. Article 7(4) excludes categories of packaging, among them medicinal products, medical devices, in vitro diagnostics, food for special medical purposes, infant formula, dangerous goods and plant protection products. Article 7(5) excludes, automatically and without approval, plastic food-contact packaging where the recycled content would threaten health and breach Regulation (EC) No 1935/2004, and “any plastic part representing less than 5 % of the total weight of the whole packaging unit”.

Neither list is the same as the exclusions from recyclability in Article 6(11). Three separate lists, partly overlapping, is a distinction most secondary summaries lose. The thresholds, the calculation mechanics and the difference between post-consumer and pre-consumer material are on the recycled content page.

PPWR substance limits: one carried over, one new

The 100 mg/kg ceiling for the sum of lead, cadmium, mercury and hexavalent chromium in Article 5(4) of Regulation (EU) 2025/40 is not new. It continues the regime Directive 94/62/EC applied for three decades. Article 70(3) keeps Decisions 2001/171/EC and 2009/292/EC in force until the Commission repeals them by delegated acts under Article 5(8): the first lets glass packaging exceed the limit where the excess comes from adding recycled glass, the second covers plastic crates and pallets.

The PFAS limits in Article 5(5) are new, apply to food-contact packaging only, and have no sell-off period. The three values, the testing approach the Commission recommends, the PTFE question and what PFAS-free means for paper and for film are covered on the PFAS in food packaging page.

The one delegated act adopted so far concerns pallet wrappings and straps

The only delegated act adopted under the EU packaging regulation so far, Commission Delegated Decision (EU) 2026/429 of 25 February 2026, was published in the Official Journal on 6 May 2026 and entered into force twenty days later. It was adopted on the basis of Article 29(18), point (a).

What it does, in its own words: “Economic operators that use pallet wrappings or straps for stabilisation and protection of products put on pallets during transport are exempted from the 100 % reuse requirements of these packaging formats established in Article 29(2) and (3) of Regulation (EU) 2025/40.”

Two details are worth reading precisely. The exemption attaches to the operator, not to the packaging format, and it covers paragraphs (2) and (3) of Article 29 only. Paragraph (2) concerns transport within the same company or between linked or partner companies in the Union, and paragraph (3) transport between companies within the same Member State. Descriptions that present this as a blanket exemption for stretch film go further than the act does.

PPWR penalties are national, and the text names no amounts

The EU packaging regulation leaves the penalty rules to the Member States in Article 68, which had to lay them down and notify the Commission by 12 February 2027, and to make them effective, proportionate and dissuasive. For infringements of Articles 24 to 29, the national rules must include administrative fines. Regulation (EU) 2025/40 itself contains no figures, so any specific fine quoted as “the PPWR penalty” comes from a national draft rather than from EU law. Separately from fines, non-conforming packaging faces market measures under the safeguard procedures: withdrawal, recall or a marketing ban.

The EU packaging regulation reaches Northern Ireland, not Great Britain

The EU packaging regulation does not form part of the law of Great Britain. It applies in Northern Ireland through the Windsor Framework, because Article 13(3) of that Framework means the reference to Directive 94/62/EC in point 25 of its Annex 2 is now read as referring to Regulation (EU) 2025/40.

Commission Notice C/2025/946 of 4 February 2025 lists the provisions that fall outside that scope, and it does so by article rather than by theme: Article 23; Articles 29 to 33; Article 34 and Article 56(1)(b), unless the United Kingdom in respect of Northern Ireland takes measures to reduce the consumption of lightweight plastic carrier bags; Articles 41 to 55; paragraphs 1(a), 1(c) and 6 of Article 56; and Articles 57 and 63.

For a company in Great Britain nothing changes in domestic law, and the United Kingdom runs its own packaging legislation. The Regulation still reaches it commercially: packaging on goods sold into the Union or into Northern Ireland must comply, and EU customers ask for the documentation that proves it. In practice the Regulation arrives at British brands through the specification sheet and the supplier audit, not through a statute.

Frequently asked questions

Is the EU packaging regulation in force, or still a proposal?

In force and unamended. Regulation (EU) 2025/40, the PPWR regulation, was published on 22 January 2025, entered into force on 11 February 2025 and applies from 12 August 2026. Six corrigenda have been published, each correcting a single language version, and none of them in English. No amending act has been adopted.

Does the EU packaging regulation apply to business-to-business packaging?

Yes. Under the EU packaging regulation, sales, grouped and transport packaging are all covered, so a purely industrial flow is inside the scope just like a retail pouch. Some obligations are aimed specifically at business flows, among them the 50 % empty space ratio for grouped, transport and e-commerce packaging and the re-use targets for transport packaging.

Do I have to prove recyclability today, or from 2030?

Both statements are half right, which is why the question about the EU packaging regulation keeps returning. The duty in the EU packaging regulation that all packaging be recyclable applies from 12 August 2026. The design-for-recycling criteria that give the duty its measurable content arrive from 2030 at the earliest, and until the Article 6(4) delegated acts are in force the Commission says no Article 38 conformity assessment is required for recyclability.

Has the EU banned plastic packaging?

No. The EU packaging regulation restricts specific formats for specific uses from 1 January 2030 through Annex V, and it phases out packaging that fails the future recyclability requirements. Plastic packaging designed for recycling and meeting the recycled content thresholds remains fully marketable. Directive (EU) 2019/904 separately bans particular single-use plastic items, and that is a different act.

What is the difference between a manufacturer and a producer?

The manufacturer is defined in Article 3(1), point (13) of the EU packaging regulation, and carries the product-side obligations: conformity, technical documentation, declaration of conformity. The producer is the operator that first makes packaged products available in a Member State and carries the extended producer responsibility obligations there. One company frequently holds both roles, in different markets, under different articles.

Does a non-EU manufacturer need an authorised representative?

The EU packaging regulation contains two different authorised representatives and mixing them up is the most common error in supplier questionnaires. The one under Article 17 is appointed by the manufacturer through a written mandate and holds the product-side documentation. The one under Article 45(3) is the producer-side, extended producer responsibility figure, required where a producer owes EPR obligations in a Member State in which it is not established. Different mandates, different articles.

Which Directive 94/62/EC rules still apply?

Directive 94/62/EC was repealed with effect from 12 August 2026, but Article 70 keeps parts of it alive: its Article 9(1) and (2), for the minimisation essential requirements, until 31 December 2029; its Article 8(2) until 30 months after the implementing act under Article 12(6); other provisions until 31 December 2028. References to the repealed Directive are read against the correlation table in Annex XIII, Article 70(5).

Sources

Regulation (EU) 2025/40, the EU packaging regulation, official text on EUR-Lex. Articles are quoted from the Commission Notice published in the Official Journal C, 2026/3084 of 10 June 2026, which reproduces them in full, and from the Commission FAQ of 3 August 2026. Commission Delegated Decision (EU) 2026/429 of 25 February 2026 for the pallet wrappings and straps exemption. Commission Notice C/2025/946 of 4 February 2025 for Northern Ireland. Commission Decision 2001/171/EC for the glass derogation, Decision 97/129/EC for material identification, Directive (EU) 2018/852 and Regulation (EU) 2019/1020. The harmonised standards listed under Directive 94/62/EC for EN 13428 and EN 13430. Proposal COM(2025) 982 of 10 December 2025, procedure 2025/0395(COD), which remains before the co-legislators.

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Content reviewed by Laura Ionescu · 17.08.2026