Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, entered into force on 11th of February 2025. It replaces 31 years of fragmented national packaging law with a single framework that applies directly and uniformly across all 27 EU member states. If you manufacture, distribute, or import food in flexible packaging, this regulation changes what you can put on the market, and how.
The previous Packaging and Packaging Waste Directive dated from 1994 required each EU member state to write its own national law producing 27 different interpretations, 27 different timelines, and 27 different compliance environments. Companies selling across multiple EU markets navigated a patchwork of rules.
Who it applies to
PPWR covers any economic operator placing packaging on the EU market — whether empty or filled, manufactured in the EU or imported. This includes manufacturers, importers, distributors, brand owners, and packaging material suppliers. If you put packaging on the EU market, you are in scope.
The right time to act is now
General application begins 12 August 2026. Most substantive obligations — recyclability, recycled content, minimisation — apply from 2030. That sounds distant, but it is not.
Packaging development cycles, material qualification, machine trials, and supply chain transitions take significant time under normal conditions. The delegated acts that will define the specific recyclability criteria and recycled content thresholds are being finalised now, in 2026 and 2027. You need to understand the criteria before you can assess compliance and the assessment needs to happen before you can redesign.
PPWR introduces obligations across recyclability, recycled content, hazardous substances, packaging minimisation, and producer responsibility. For flexible food packaging, each of these areas has a direct material consequence and some carry deadlines that are closer than most companies currently assume. The PFAS limits apply from August 2026. Recyclability criteria are being finalised now. Recycled content targets for plastic packaging apply from 2030, but the development cycles required to meet them start long before that date. The 5 areas below are the ones that require action.
This is the earliest hard deadline in PPWR. From 12th of August 2026, food contact packaging containing PFAS above the following thresholds may not be placed on the EU market:
• 25 ppb for any individual PFAS
• 250 ppb for the sum of all PFAS
• 50 ppm for polymeric PFAS
PFAS (per- and polyfluoroalkyl substances) have been widely used as functional coatings and barrier components in food packaging. Films and flexible packaging containing PFAS-based functional layers will require reformulation before the August 2026 deadline.
The restriction applies to both intentionally added and unintentionally present PFAS. It applies to the entire packaging unit, including inks, varnishes, adhesives, and coatings.
What this means in practice: If any element of your current packaging including functional coatings or printing components, contains PFAS, reformulation is required before 12th of August 2026. This is not a 2030 obligation. The clock is running now.
Any company placing packaged goods on an EU market must participate in an EPR scheme in each member state where it operates. PPWR harmonises EPR obligations across all 27 member states including registration requirements, reporting formats, reporting frequency, and the framework for fee modulation.
EPR registration and participation obligations apply from 12th of August 2026, the general application date of the regulation. This is not a 2030 obligation. If you place packaging on EU markets, EPR registration in each relevant member state is required within months, not years.
Fee modulation — where EPR fees are adjusted based on packaging recyclability performance grade — will be harmonised once the relevant delegated act under Article 6(4) enters into force. This act is expected by January 2028. Until then, member states continue to apply their existing national eco-modulation schemes. Several EU markets already operate modulated fee structures. PPWR harmonises and strengthens the system — it does not introduce it from scratch.
The first harmonised EPR reporting deadline under PPWR is 1st of June 2029. Producers must report to each national producer register by June for the full preceding calendar year.
What this means in practice: EPR registration is not a future consideration — it applies in less than 18 months for companies not already registered under the previous directive. The recyclability grade of your packaging will determine your fee burden once the harmonised modulation framework applies. Higher grade, lower fees. Lower grade, higher fees. This is a quantifiable operational cost built directly into the system.
All packaging placed on the EU market must be recyclable in an economically viable way by 2030. PPWR introduces a performance grading system: packaging will be assessed against design for recycling (DfR) criteria and assigned a performance grade. Non-recyclable packaging will not be permitted on the EU market after this date.
For flexible food packaging, this has direct material implications. Most current multilayer laminate structures, the standard for MAP, vacuum, and thermoforming applications, qualify as composite packaging under PPWR if secondary materials exceed 5% of total packaging weight. These structures will need to be assessed against the DfR criteria once the delegated act is finalised. Some will qualify, others will require material redesign.
What this means in practice for food manufacturers: Your current film structure needs a recyclability assessment against PPWR criteria. The assessment must be reflected in a Declaration of Conformity (DoC) for each sales packaging unit.
PPWR introduces mandatory minimum recycled content levels for plastic packaging. The specific targets vary by packaging category and whether the packaging is contact-sensitive:
• Non-contact-sensitive plastic packaging (e.g. pallet wrapping): 35% recycled content by 2030
• Contact-sensitive plastic packaging other than PET: 10% by 2030
• Single-use PET beverage bottles: 30% by 2030
For food contact applications, recycled content must also comply with EU food contact legislation — specifically Regulation (EU) 10/2011 and Regulation (EU) 2022/1616, which govern food-contact-compliant recyclates. Not all recycled plastic meets food contact requirements. The interaction between PPWR recycled content targets and food contact law is one of the most complex compliance areas in the regulation.
What this means in practice: Identify whether your packaging is contact-sensitive and which polymer it is made from. Then determine the applicable 2030 target. Factor in the food contact compliance requirement for the recycled material, the pool of compliant recyclate is currently limited.
PPWR requires that packaging be reduced to the minimum necessary to fulfil its function. From 2030, packaging must not include unnecessary void space, double walls, false bottoms, or other elements that increase perceived volume without functional justification.
For grouped, transport, and e-commerce packaging, a maximum 50% empty space threshold applies. For sales packaging, there is no fixed threshold but economic operators must demonstrate in their technical documentation that void space is minimised to what is functionally necessary.
What this means in practice: Document the functional justification for your current packaging format and material specifications. This documentation will be central to conformity assessment under PPWR.
Most current flexible food packaging is a multilayer laminate: different polymer layers, each performing a specific function like oxygen barrier, moisture resistance, puncture strength, seal integrity or printability.
Under PPWR, multilayer structures where secondary materials exceed 5% of total packaging weight qualify as composite packaging. Composite packaging faces more demanding recyclability assessment criteria than mono-material structures.
Mono-material alternatives, built from a single polymer family, are more compatible with mechanical recycling and are likely to achieve higher recyclability performance grades. But moving from a multilayer laminate to a mono-material structure is not a simple material substitution. It is a re-engineering of the packaging's functional performance.
Moving to a recyclable format that compromises food safety or shelf life is not a compliant solution under EU food law, regardless of its recyclability grade.
PPWR enters into force
General application: PPWR replaces PPWD; PFAS limits for food contact packaging apply; general substances of concern minimisation applies
Commission to adopt guidelines on packaging bans (Annex V); implementing act on reuse target calculation
Compostability requirements apply; implementing act on empty space calculation methodology
DRS separate collection targets (90%) apply; first EPR reporting under harmonised PPWR rules due June 2029
All packaging must be recyclable; recycled content targets for plastic packaging apply; minimisation requirements apply; packaging bans (Annex V) apply; reuse targets apply
Higher recyclability thresholds; Commission review of exemptions
Waste reduction target: −15% vs 2018 baseline
Your packaging material suppliers are required to provide you with all technical information and documentation necessary to demonstrate conformity. This includes material composition data, recyclability assessments, PFAS test results, and recycled content certificates. Suppliers who cannot provide this documentation will put your compliance at risk.
Your customers (food processors and brand owners) need to demonstrate conformity for the packaging they place on the market. The technical documentation they need starts with the material data you and your suppliers provide. Your ability to supply compliant, documented materials is becoming a commercial prerequisite, not just a compliance requirement.
As a distributor placing packaging on EU member state markets for the first time, you may qualify as a producer under PPWR, triggering EPR registration and reporting obligations in each relevant market. The producer definition depends on the specific transaction: who holds the brand name, who is the first to make the packaging available in a given member state, and whether the recipient is an end user or a commercial buyer who will resell.
Packaging lawfully placed on the EU market before 12 August 2026 — or before the relevant application date of a specific provision — may remain on the market without being recalled or withdrawn. However, from the relevant application dates, all new packaging placed on the market must comply. There is no exhaustion of stocks provision for recycled content requirements.
No. PPWR does not ban specific material structures. It introduces recyclability performance criteria. A multilayer structure assessed against the design for recycling criteria may qualify for an acceptable recyclability grade — depending on the specific material combination and the criteria established in the delegated act under Article 6(4), expected by January 2028.
PFAS limits for food contact packaging apply from 12 August 2026. They apply to the entire packaging unit, including inks, varnishes, adhesives, and coatings — not just the base film. The limits cover both intentionally added and unintentionally present PFAS.
The Declaration of Conformity (DoC) is the formal document manufacturers must draw up demonstrating that their packaging complies with PPWR requirements. It must be drawn up for each packaging type — not the packaging design in general. It covers all integrated and separate components of the packaging unit. Where packaging is subject to multiple EU regulations (e.g. PPWR and food contact legislation), a single combined DoC may be drawn up.
Recyclability refers to whether a packaging material and design can be recycled in an economically viable way — assessed through the design for recycling criteria. Recycled content refers to the proportion of recycled material incorporated into new packaging. Both are separate PPWR requirements with separate targets and timelines. A packaging can be recyclable without containing recycled content, and vice versa.
There is no general exemption for micro-enterprises from PPWR obligations. All economic operators placing packaging on the EU market are in scope. However, one specific rule applies: if a manufacturer is a micro-enterprise and its packaging supplier is established in the same member state, the supplier, not the micro-enterprise manufacturer, becomes the producer for EPR purposes. Reduced reporting obligations apply to producers making less than 10 tonnes of packaging available per year in a member state.
Eco-modulation means that EPR fees paid by producers are adjusted based on the recyclability performance grade of their packaging. Higher recyclability grade = lower fee. Lower recyclability grade = higher fee. PPWR harmonises the framework for eco-modulation across all 27 member states. Member states may also apply additional modulation criteria such as recycled content and reusability.
We manufacture flexible packaging: extrusion, printing, cutting, quality control, all under one roof. We have direct knowledge of the material structures we supply and can provide the technical documentation your compliance assessment requires. We offer a review of your current packaging formats against PPWR recyclability criteria, assessment of PFAS risk in your current material specifications, and guidance on where mono-material transitions are technically viable today.
We review your packaging formats and give you a direct answer. What is compliant today. What needs to change. By when. No generic guidance. A specific assessment for your application and your supply chain.
