Who is affected?
The short answer: PPWR covers all packaging – whatever the material, and whether it's sales packaging, multipacks or transport packaging.
Your obligations depend on your role in the value chain – whether you act as manufacturer, importer or distributor. Those roles are not always straightforward: they can vary from company to company and from product to product, and how they play out in practice may also depend on the guidance still to come from the EU. The first step is therefore to clarify which roles – and which obligations – apply to your business.
What's coming – and when?
PPWR is phased in gradually. Here are some of the key milestones:
12 August 2026 – the rules start to apply
Requirements on documentation and traceability take effect, the roles across the value chain are sharply defined, and limits arrive on substances of concern – including limit values for heavy metals. At the core of the new requirements is the Declaration of Conformity (DoC): technical documentation must be available on request and kept for 5 years for single-use packaging and 10 years for reusable packaging.
For food-contact packaging, PPWR introduces a specific restriction in Article 5(5): from 12 August 2026, food-contact packaging may not be placed on the EU market if it contains PFAS at or above the limit values set out in the regulation.
12 August 2028 (expected) – harmonised labelling requirements
Packaging must be labelled with information on material content to common EU standards, so consumers can easily sort it correctly – the same pictograms across the whole of the EU. Note that the date is indicative: the requirement applies 42 months after the regulation's entry into force or 24 months after the adoption of the implementing acts, whichever is later.
12 February 2029 – labelling of reusable packaging
Reusable packaging must carry its own separate label.
1 January 2030 – the design requirements
All packaging must be designed for recycling and classified into recyclability grades (A, B and C). Minimum requirements arrive for recycled plastic in new packaging. Packaging must be minimised – empty space in transport and e-commerce packaging may make up no more than 50% (and yes, air and bubble wrap count). At the same time, a range of single-use formats will be banned – for example, plastic packaging around fresh fruit and veg under 1.5 kg.
2038 – the bar rises again
From 2038, only the best recyclability grades (A and B) may be used.