European Packaging and Packaging Waste Regulation: Summary of Provisions and New Guidance

Background to the PPWR

The EU Packaging and Packaging Waste Regulation (PPWR) was adopted on 19 December 2024 and entered into force on 11 February 2025, replacing the Packaging and Packaging Waste Directive. It establishes sustainability and labelling requirements across the entire packaging life cycle, from production to use and waste management, in support of the EU’s circular economy objectives and 2050 climate neutrality target. Only packaging that complies with the PPWR may be placed on the EU market, with “packaging” defined broadly as any item intended to be used by an economic operator for the containment, protection, handling, delivery, or presentation of products, regardless of material.

With the 12 August 2026 application date approaching, this article provides an overview of the PPWR framework, including its core objectives, the range of economic operators affected, and key sustainability, recyclability, labelling, and waste-reduction requirements. We also highlight the European Commission’s recent implementation guidance and FAQs published on 30 March 2026, outline selected compliance dates, and suggest practical steps companies can take now to prepare for compliance.

The PPWR’s core objectives are:

• preventing unnecessary packaging and promoting reuse, refill, and recycling;
• harmonising national measures to avoid trade barriers and competition distortions; and
• contributing to the EU’s broader circular economy and climate neutrality goals.

The PPWR applies to all packaging and packaging waste, regardless of material or origin (industrial, retail, or household). The regulation complements existing EU laws on sustainable products set out under the Circular Economy Action Plan, such as the Ecodesign for Sustainable Products Regulation and the Batteries Regulation. For more information on the EU’s circular economy and product-related frameworks, refer to this Latham article.

The PPWR affects a wide range of economic operators involved in the packaging supply chain, including:

• Manufacturers: companies that design, manufacture, or have packaging manufactured under their own name or trademark
• Importers: companies that place packaging or packaged products from outside the EU onto the EU market
• Distributors: companies that make packaging available on the market but are not the manufacturer, importer, or producer
• Fulfilment service providers: companies that provide warehousing, packaging, addressing, and dispatching services for products sold online
• E-commerce operators: online platforms and retailers that sell packaged products to EU consumers

Notably, the PPWR applies regardless of whether a company is based in the EU. Non-EU companies placing packaging or packaged products on the EU market must comply and may need to appoint an authorised representative within the EU.

A non-exhaustive overview of key PPWR provisions follows, to give an overview of the range and scope of requirements. Note that some deadlines may be extended depending on the timing of secondary legislation.

Sustainability Related Obligations

Substances of Concern (Article 5)

Packaging placed on the EU market should be manufactured to minimise the presence and concentration of substances of concern.

From 12 August 2026, the PPWR prohibits placing food-contact packaging on the market if it contains per- and poly-fluoroalkyl substances (PFAS) at or above specified concentration limits. PFAS are a large group of chemicals, often referred to as “forever chemicals”, as their structure means they do not readily biodegrade. Beyond the PPWR, the EU is pursuing a broader “universal” restriction on a wide range of PFAS under REACH, with a proposal submitted by five Member States in 2023 that would ban virtually all PFAS uses, subject to limited exemptions and transition periods.

Recyclability (Article 6)

Under Article 6 of the PPWR, all packaging placed on the EU market must be recyclable. Specifically, from 1 January 2030, packaging must be designed for “material recycling”, enabling the resulting secondary raw materials to substitute primary raw materials. From 1 January 2035, packaging must also be recyclable “at scale”, meaning it can be collected, sorted, and recycled through established infrastructure. The Commission will establish recyclability performance grades (A-E) through delegated and implementing acts, with packaging not meeting the minimum performance grade (initially grade C or better) considered non-compliant and therefore considered technically non-recyclable.  From 1 January 2038, all packaging shall be recyclable within grades A or B.

Minimum Recycled Content (Article 7)

The PPWR sets percentages for the minimum proportion of recycled content for any plastic part of packaging placed on the market, with the specific proportion depending on packaging type.  These thresholds enter into effect from 1 January 2030 or three years after relevant implementing acts are enacted, with higher thresholds coming into effect from 1 January 2040.

Packaging Minimisation (Article 10)

From 1 January 2030, the manufacturer or importer of packaging into the EU shall ensure that the packaging is designed so that its weight and volume are reduced to the minimum necessary to ensure its functionality.

Reusable Packaging (Article 11 and Article 26)

The PPWR promotes reusable packaging as an alternative to single-use formats. Packaging is considered reusable if it is designed to accomplish multiple trips or rotations, can be emptied or unloaded without damage, and is capable of being refurbished whilst meeting safety requirements, alongside further requirements.

Entities must ensure there is a system in place for the reuse of packaging, including an incentive to ensure the collection of the packaging. The Commission is required to adopt delegated legislation by 12 February 2027, which will establish a minimum number of rotations for reusable packaging.

Labelling Requirements (Articles 12–14)

From the later of 12 August 2028 or 24 months from the date of entry into force of the relevant implementing acts, packaging placed on the market shall be required to be marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting.

The Commission will adopt implementing acts specifying the format, design, and placement of these labels, which seek to replace the current patchwork of national labelling schemes with a single EU-wide system.

Obligations to Reduce Packaging and Packaging Waste

Reducing Excessive Packaging (Article 24)

The PPWR intends to address excessive packaging by regulating the ratios of empty space within packaging. From 1 January 2030, economic operators filling grouped, transport, or e-commerce packaging must ensure the maximum empty space ratio does not exceed 50%. Empty space is calculated as the difference between the overall volume of the packaging and the volume of the packaged product. The Commission will adopt implementing acts establishing the methodology for calculating empty space by 12 February 2028, and the empty space ratio will be reviewed by 12 February 2032 to assess whether stricter limits are warranted.

Restricted Packaging Formats – Single-use Plastics (Article 25)

Article 25 of the PPWR restricts certain single-use packaging formats from 1 January 2030. Prohibited formats include single-use plastic grouped packaging for cans and bottles, single-use packaging for fresh fruits and vegetables under 1.5kg, single-use hotel miniatures (toiletries under 50ml or 100g), and single-use plastic carrier bags under 15 microns of thickness. The full list of restricted packaging formats is available in Annex V. Member States are able grant exemptions where they are deemed necessary for hygiene, food safety, or environmental reasons.

Refill Obligations (Article 28)

Member States should support the establishment of refill systems as part of the PPWR’s broader objectives to reduce single-use packaging and promote reuse. Where economic operators offer the possibility to purchase products through refill, they should inform end users of the conditions for refill, including hygiene requirements and the types of containers that may be used. End users bringing their own containers bear responsibility for the cleanliness and suitability of those containers, whilst economic operators must provide clear instructions at the point of sale.

Management of Packaging and Packaging Waste

Waste Prevention Targets (Article 43)

The PPWR sets binding waste prevention targets at a Member State level. By 31 December 2030, Member States must reduce packaging waste generated per capita by 5% compared to 2018 levels. This target increases to 10% by 31 December 2035 and 15% by 31 December 2040. These targets aim to address the continuous growth in packaging waste across the EU and encourage changes in packaging design and consumption patterns.

Extended Producer Responsibility (Article 44-47)

EPR is central to the PPWR’s framework. Under the PPWR, producers bear financial responsibility for the entire life cycle of their packaging, including collection, sorting, recycling, and disposal costs. EPR fees must be modulated based on recyclability, recycled content, reusability, and the presence of substances of concern, and are intended to incentivise ecodesign. Member States must ensure EPR schemes cover all packaging and that fee structures are transparent. Financial contributions paid by producers will apply 18 months from the date of entry into force of the relevant delegated and implementing acts, with fees modulated in accordance with recyclability performance grades as set out in those acts.

Implementation Guidance

On 30 March 2026, the Commission published a guidance document and FAQs to clarify aspects where the PPWR could require further interpretation. The guidance addresses key definitions, including when a company qualifies as a “manufacturer” versus a “producer”, and which items fall within the scope of “packaging” under Annex I criteria. These classifications in turn determine compliance obligations, such as labelling requirements and EPR.

The guidance also clarifies restrictions on single-use packaging, the PFAS restriction in food-contact packaging, and the application of reuse and refill targets. It intends to provide practical guidance on EPR obligations and the establishment of deposit and return systems.

The accompanying FAQs address practical issues raised by stakeholders since the PPWR’s adoption, and the Commission has stated it will update the FAQ document as needed.

Key Compliance Dates

The PPWR introduces requirements on a phased basis. Selected key dates include:

• 12 August 2026: PPWR application date; PFAS restrictions in food-contact packaging take effect
• 12 August 2028 (or later): Harmonised labelling requirements apply
• 1 January 2030: Design for recyclability required; minimum recycled content thresholds apply; single-use packaging restrictions begin; empty space limits take effect; packaging minimisation requirements apply; certain EPR fees commence
• 1 January 2035: Packaging must be recyclable “at scale” through established infrastructure
• 1 January 2038: All packaging must achieve recyclability grade A or B
• 1 January 2040: Higher minimum recycled content thresholds apply

Next Steps and Preparation

The PPWR framework will continue to develop through implementing and delegated acts. Several delegated and implementing acts are currently being prepared, covering harmonised registration and reporting formats for EPR, labelling for waste sorting by consumers, recycled content requirements in plastic packaging, and recyclability criteria. These are being developed in cooperation with Member States, stakeholders, and trading partners. Further, the Commission intends to monitor and facilitate implementation to ensure a smooth rollout of the new rules.

Companies should first clarify their role or roles under the PPWR (whether as a manufacturer, producer, importer, distributor, or fulfilment service provider) as this determines specific compliance obligations. Producers should engage with EPR organisations in the relevant Member States and prepare for modulated fee structures that will apply 18 months from the date of entry into force of the relevant delegated and implementing acts. Companies selling through e-commerce channels should also review their obligations regarding packaging used for delivery.

Companies should begin preparing now for PPWR compliance, particularly given the 12 August 2026 application date for a number of the provisions. A useful starting point is to conduct a packaging audit to identify all packaging placed on the EU market and assess current compliance with sustainability, recyclability, and labelling requirements. Companies should also review their supply chains to understand where packaging originates and ensure that suppliers can provide the necessary compliance documentation.

Finally, companies should monitor the development of delegated and implementing acts, as these will provide important detail on recyclability criteria, labelling specifications, and recycled content requirements. Engaging with industry associations and participating in stakeholder consultations can help ensure that company perspectives are considered as the regulatory framework is finalised. Given the broad scope of the PPWR and its interaction with national packaging laws, companies may also benefit from seeking advice to develop a comprehensive compliance strategy.

This article was prepared with the assistance of Samantha Banfield and James Thompson at Latham & Watkins.

Latham & Watkins will continue to monitor developments relating to the European sustainability regulatory landscape.