PPWR checker. Your packaging duties, dated.
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) sets EU-wide rules on packaging substances, documentation, labelling, recyclability, recycled content, empty space, re-use and producer responsibility, and has applied since 12 August 2026. Tick your role, materials and packaging types, and this checker lists the obligations that apply to you on a dated timeline, with the documents to ask your packaging supplier for.
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A first check, not legal advice. Where a date reads “or later”, the obligation starts on that date or a set time after the Commission's implementing or delegated act, whichever is later. National rules on EPR fees and registers also apply.
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Three steps. One clear answer.
- 01
Tick your roles, such as brand owner, importer or e-commerce seller, and say where you are established and how many EU countries you sell in.
- 02
Choose your packaging materials and types: sales, transport or e-commerce, food-contact or reusable.
- 03
Read your obligations on a dated timeline, which ones already apply, and the list of documents to request from your packaging supplier.
Dates and requirements come from Regulation (EU) 2025/40, which applies from 12 August 2026 (Art. 71). Provisions without their own date apply from then: heavy metals (sum of lead, cadmium, mercury and hexavalent chromium up to 100 mg/kg, Art. 5(4)), PFAS limits in food-contact packaging (Art. 5(5)), conformity assessment, technical documentation and EU declaration of conformity (Art. 15, Annex VII), importer identification (Art. 18(3)) and the EPR authorised representative for producers selling directly to end users in other Member States (Art. 45(3)). Later dates: sales packaging empty space minimised by 12 February 2028; harmonised labels from 12 August 2028; recyclability grade A to C, plastic recycled content (Art. 7), 50% maximum empty space ratio (Art. 24), 40% reusable transport packaging (Art. 29, cardboard boxes exempt) and Annex V restrictions from 1 January 2030; recycled at scale from 2035; grade A or B from 2038. Several dates move later if the Commission's implementing or delegated acts arrive late, as the Regulation states.
- EUR-Lex: Regulation (EU) 2025/40 on packaging and packaging waste
- European Commission: packaging waste
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[email protected]When does the PPWR apply?
Regulation (EU) 2025/40 entered into force on 11 February 2025 and has applied generally since 12 August 2026. Several requirements, such as harmonised labels, recyclability grades and recycled content, start later, from 2028 to 2040.
What are the PFAS limits for food-contact packaging?
Since 12 August 2026, food-contact packaging may not contain PFAS at or above 25 ppb for any single PFAS or 250 ppb for the sum of PFAS measured by targeted analysis, or 50 ppm for total PFAS including polymeric PFAS.
Do non-EU sellers need an authorised representative under the PPWR?
Producers that sell packaging or packaged products directly to end users in another Member State, including from outside the EU, must appoint an EPR authorised representative in each such country. A December 2025 Commission proposal would suspend this duty, but it is not yet law.
What does the PPWR require for plastic packaging recycled content?
From 1 January 2030, or 3 years after the calculation rules are adopted if later, each plastic part must contain minimum post-consumer recycled content: 30% for contact-sensitive PET, 10% for other contact-sensitive plastics, 30% for single-use beverage bottles and 35% for other plastic packaging.
What is the empty space rule for e-commerce packaging?
From 1 January 2030, or 3 years after the calculation method is adopted if later, businesses filling grouped, transport or e-commerce packaging must keep the empty space ratio at or below 50%.
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