What changes need to be made to your packaging? An overview of the PPWR requirements

Most articles about the PPWR list the requirements: recycled content, recyclability, and prohibited packaging types. That’s helpful, but it leaves out the step that requires the most work in practice: demonstrating that your packaging complies, with technical documentation and a declaration of conformity. Many companies don’t have anything ready for that yet.

In this article, we outline the requirements for each topic, paying at least as much attention to the burden of proof. We base our analysis on Regulation (EU) 2025/40 and refer to the relevant articles and annexes throughout. This article is part of our overview of the new European Packaging Regulation.

Many companies are already subject to the current European Packaging Directive (PPWD) and the resulting national regulations. With the introduction of the PPWR, a number of important changes will take effect. A relevant change for smaller producers is that existing national exemptions—such as the Dutch threshold of 50,000 kg of packaging material per year—will eventually be phased out. As a result, even companies that place relatively small quantities of packaging on the market will more often have to comply with registration and reporting obligations under the extended producer responsibility (EPR) framework. However, this change will not take effect until 2026.

First of all: just getting by isn’t enough

The PPWR not only requires that your packaging comply with the standards, but also that you can prove it. For each requirement, in a dossier, whenever a regulator or a customer requests it. That responsibility lies with the manufacturer: the party that places the packaging or the packaged product on the market under its own name or brand. You can read about exactly how these roles work in our article on the roles under the PPWR. Keep that in mind as we go through the requirements: for each requirement below, you’ll need to be able to demonstrate compliance later on.

Requirements by Theme

The table lists the most important requirements, sorted by their effective dates. Below that, we provide a brief explanation for each topic.

These are the most important requirements, but there are more. Would you like a complete overview for your situation? Then use our free PPWR tool.

We’ll discuss the declaration of conformity and traceability separately later on, as they are the focus of this article. First, let’s cover the other topics, in chronological order.

Substances of Concern and PFAS (Art. 5)

Starting August 12, 2026, you must minimize the presence and concentration of substances of concern. A strict limit of 100 mg/kg applies to the sum of lead, cadmium, mercury, and hexavalent chromium. For packaging that comes into contact with food, strict limits for PFAS will apply as of the same date (Art. 5, para. 5), with no phase-out period for packaging placed on the market after that date.

Labeling (Art. 12)

Starting August 12, 2028, a harmonized label indicating the material composition will be introduced, featuring pictograms to help consumers sort their waste. Starting February 12, 2029, a label for reusable packaging will be added, featuring a QR code linking to the reuse system. This single EU label will replace national schemes, such as France’s Triman.

Recycled content (Art. 7)

Starting January 1, 2030, plastic packaging must contain a minimum percentage of recycled material: ranging from 10% to 35%, depending on the type of packaging, with the percentage increasing toward 2040. The material must come from collected post-consumer plastic waste. The exact calculation method will be specified in special implementing rules; we’d be happy to work with you to determine which percentage applies to your packaging and how to document it for each type of packaging.

Recyclability (Art. 6)

Starting January 1, 2030, all packaging must be designed for recycling. Recyclability classes ranging from A through E will be introduced: starting in 2030, only class C or higher will be allowed on the market; starting in 2038, that requirement will be class B. The exact criteria will be established through specific implementing regulations. Until 2030, the recyclability requirements from the old Packaging Directive (PPWD) will apply. If you currently comply with those requirements, no legal action is required yet, but the preparation will take more time than that date might suggest.

Minimalism and Empty Space (Art. 10 and Art. 24)

Starting January 1, 2030, packaging must be as light and compact as functionally necessary. For group packaging, transport packaging, and shipping boxes, a maximum of 50% empty space applies. Please note: filler materials such as paper scraps, air cushions, bubble wrap, and Styrofoam count as empty space. For those who ship a lot online, this is often an eye-opener.

Reuse (Art. 11 and Art. 29)

The first reuse targets will take effect on January 1, 2030. Transport packaging used for shipments within the EU must be at least 40% reusable within a reuse system, with a target of 70% by 2040. For transport between business units and within the same group of subsidiaries, a 100% requirement applies. Separate targets apply to group packaging and beverage packaging, and cardboard boxes are exempt. Determining which targets apply to your specific packaging streams is typically something that needs to be assessed on a stream-by-stream basis.

Prohibited packaging types: the most tangible requirement

Effective January 1, 2030, the PPWR will completely ban a number of single-use plastic packaging items (Art. 25 and Annex V). These include:

• Group packaging made of disposable plastic.
• Single-use plastic for pre-packaged fresh fruits and vegetables weighing less than 1.5 kg.
• Single-use plastic for food and beverages consumed on-site in the hospitality industry: trays, plates, cups, bags, and containers.
• Single-serving disposable plastic items in the food service industry, such as sauces, coffee creamer, sugar, and spices.
• Mini-sized toiletries for accommodations, such as mini shampoo bottles.
• Very lightweight plastic shopping bags.

Visual (for design): “Banned starting in 2030” with icons of the prohibited packaging types shown above. Brand colors: petrol (#1B3A4B) and orange (#FF6B35).

Together with the PFAS limit for food contact, these are the requirements that will have the most immediate, tangible impact on your product lineup and your purchasing.

How do you demonstrate compliance?

Please note: this is not a 2030 requirement; this obligation takes effect as of August 12, 2026. The PPWR requires two things from you:

• A declaration of conformity with a fixed set of required fields.
• Technical documentation that demonstrates, for each requirement, that your packaging complies.

This includes traceability: your packaging must be traceable back to the manufacturer, with identification information on or attached to the packaging. You must retain the documentation for five years; for reusable packaging, ten years.

You conduct the assessment yourself through an internal conformity assessment. This means you do not need a notified body or an external inspection, but the burden of proof lies entirely with you. If even one required field is missing from the declaration of conformity, the declaration is considered invalid—as if you had none at all.

This is something many companies still underestimate in practice. The physical packaging is relatively easy to get in order, but compiling the documentation—including the data and test reports you need to obtain from your suppliers—takes time and coordination. And that documentation must be ready by August 2026.

Be mindful of your environmental claims

If you make a claim related to a PPWR topic—for example, that your packaging is “100% recyclable” or contains a certain percentage of recycled material—you will soon only be allowed to do so if that claim exceeds the minimum requirements and is substantiated in your technical documentation (Art. 14). You must also specify exactly what the claim applies to: a specific component, the entire package, or all of your packaging. In short: your packaging labels and marketing materials must align with the information in your dossier.

Where do you start?

Don’t tackle all the requirements at once, and don’t focus on communication. Start with an assessment: go through your packaging, determine which requirements apply to each package, and prioritize based on the deadline that’s coming up first. You can find the timeline for this in our article on the PPWR deadlines, and anyone who’s still unsure about their role can find the answer in our article on roles.

Would you like to see what needs to be changed for each package and get a draft declaration of conformity? Then use our free PPWR tool. As a PPWR consultant, we’re also happy to assist you with the technical documentation and validation.

Frequently Asked Questions

Does all my packaging have to be recyclable by 2030?

This is already the case under the PPWD; however, the requirements set forth in this precursor to the PPWR are not as specific. According to the PPWR, starting January 1, 2030, only packaging with a minimum of Class C may be placed on the market, and starting in 2038, that requirement will be Class B. There are, however, exemptions, including for primary packaging of pharmaceuticals, contact-sensitive packaging of medical devices, and packaging for hazardous substances.

Does the recycled content requirement also apply to cardboard or paper?

The percentages for recycled content apply only to plastic. However, paper and cardboard packaging are still subject to the PPWR: they, too, must meet the general requirements, such as recyclability, minimization, labeling, and producer responsibility. For certain reuse purposes, particularly in transport packaging, an exception applies to cardboard boxes.

Do I need an inspection agency?

No. You conduct the conformity assessment yourself, so you don’t need a notified body. However, the burden of proof rests entirely with you.

Is there a PPWR certificate or certification mark?

No. There is no official EU certificate or label that certifies that your packaging is “PPWR-compliant.” You must demonstrate this yourself through your technical documentation and your declaration of conformity, and the authorities may request and review that documentation at a later date. So be skeptical if a party offers you a PPWR certificate: such a document has no legal standing.

Does the PPWR apply even if I manufacture outside the EU?

Yes. The PPWR applies to all packaging placed on the EU market, regardless of where it was manufactured. Importers must verify that the manufacturer has issued the declaration of conformity. If you place your packaging on the market under your own name or brand, you are considered the manufacturer, and the responsibility for the documentation lies with you.

What if I don’t meet the requirements?

In that case, your packaging cannot be sold on the market. Enforcement is carried out at the national level, with fines and exclusion from sales channels as possible consequences. It is therefore not a set of guidelines that can be ignored.