PPWR EU Packaging Regulation

If you import into the EU any product that ships in a box, wraps in plastic film, sits in a jar, or carries a cardboard hangtag, the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, applies to you from 12 August 2026. Not to your packaging supplier in Guangzhou, not to your freight forwarder in Rotterdam, but to you, the EU-established business that places the packaged goods on the EU market. PPWR replaces the previous Packaging and Packaging Waste Directive 94/62/EC, harmonises the rules across all 27 Member States without national transposition, and introduces new duties on substances, recyclability, recycled content, labelling, reuse, and documentation. This guide covers what changed, the timeline through 2040, who carries the duties, and how to collect the data your supplier in Asia needs to give you before the container ships.

What Is the PPWR? (Regulation (EU) 2025/40 in Force Since 11 February 2025)

The Packaging and Packaging Waste Regulation, or PPWR, is Regulation (EU) 2025/40, the EU-wide law governing how packaging is designed, placed on the market, labelled, and disposed of. It replaces the previous Packaging and Packaging Waste Directive 94/62/EC and, unlike a directive, applies directly in all 27 Member States without national transposition.

The Regulation was published in the Official Journal on 22 January 2025 and entered into force 20 days later, on 11 February 2025. It applies generally from 12 August 2026, an 18 month transition period. Its scope covers all packaging placed on the EU market, whether business-to-business or business-to-consumer, and whether primary, secondary, tertiary, or service packaging.

Because it is a regulation rather than a directive, there is no separate national version to check: the same rules apply in Germany, France, Poland and every other Member State without local variation, though enforcement and extended producer responsibility fees remain set nationally under Article 44. UK exporters shipping into the EU are also affected, since UK packaging becomes third country packaging once it reaches an EU border.

The 12 August 2026 Application Date and the Repeal of Directive 94/62/EC

PPWR entered into force on 11 February 2025 and applies generally from 12 August 2026, the date on which Directive 94/62/EC is repealed under Article 66. Additional provisions phase in over more than a decade, and several of the later dates are conditional on the European Commission adopting delegated or implementing acts first.

Date	What applies
22 January 2025	Regulation published in the Official Journal
11 February 2025	Entry into force
12 August 2026	General application; Directive 94/62/EC repealed; Article 5 heavy metals and food-contact PFAS limits apply
12 February 2028	Compostable packaging format requirements (Article 9)
12 August 2028	Harmonised material composition labelling (Article 12), or 24 months after the relevant implementing act, whichever is later
12 February 2029	Reusable packaging labelling and QR code, or 30 months after the relevant implementing act, whichever is later
1 January 2030	Recyclability grades A, B or C only (Article 6); recycled content targets (Article 7); void space limit of 50 percent for grouped, transport and e-commerce packaging (Article 24); HORECA restrictions (Annex V); reusable packaging targets
1 January 2035	Packaging must also be recycled at scale in practice
1 January 2040	Higher recycled content and reuse targets

The 2030 dates are not all equally fixed. Article 6 ties the recyclability grade requirement to 1 January 2030 or 24 months after the delegated act on design-for-recycling criteria enters into force, whichever is later, and the Commission is due to adopt that act by 1 January 2028. Article 7 uses a similar mechanism for recycled content, and Article 24 for the void space limit, each referencing 1 January 2030 or a fixed period after the relevant implementing act, whichever is later. The HORECA restrictions under Annex V are not expressed with the same conditional wording in the Regulation. Treat the recyclability, recycled content and void space dates as the earliest realistic date rather than a guaranteed one.

Who Carries the PPWR Duties? (Manufacturers, Importers, Distributors, Fulfilment Service Providers)

Four roles carry duties under PPWR: the manufacturer, the importer, the distributor, and, newly recognised, the fulfilment service provider. Each has distinct obligations, and the duties scale up the closer a business sits to the point of first placing packaging on the EU market.

The point that causes the most confusion on the ground: your packaging supplier in China or Vietnam is not the legal entity responsible under PPWR. The EU-established importer is, and carries the obligation to verify conformity, hold the Declaration of Conformity, and produce technical documentation.

A related trap is Article 21. If an EU importer places packaging on the market under its own brand, or modifies packaging in a way that affects its compliance, that importer becomes the manufacturer in the eyes of the law and inherits the full manufacturer obligations, including carrying out the conformity assessment itself. This matters most for private label brands sourcing packaging directly from an Asian supplier and branding it as their own.

Extended producer responsibility fees are set separately by each Member State under Article 44 and are outside the scope of this guide. UK exporters selling into the EU carry the same importer-side duties from 12 August 2026 as any other third country supplier.

Substances of Concern (Article 5): Heavy Metals Confirmed, PFAS on Food-Contact Only

Article 5 of the PPWR sets substance limits in packaging. Heavy metal limits are carried over from the previous Directive largely unchanged, and PFAS limits are new but apply only to food-contact packaging.

The heavy metals limit combines lead, cadmium, mercury and hexavalent chromium at a maximum of 100 mg per kg by weight, across all packaging materials, plastic, paper, metal, glass or wood. This threshold is not tightened from the Directive it replaces. Ask your packaging supplier for a substance composition data sheet, and cross-check it with a heavy metals screening through an ISO 17025-accredited partner laboratory network.

The PFAS limits are new and apply only to food-contact packaging, from 12 August 2026, under Article 5(5). Three thresholds apply together: 25 micrograms per kilogram for any individual non-polymeric PFAS substance detected through targeted analysis, 250 micrograms per kilogram for the sum of all such PFAS, and 50 mg per kilogram for total PFAS including polymeric forms. Total fluorine testing under 50 ppm generally means the packaging is compliant without further testing; above that, the supplier needs to show how much of the fluorine is from PFAS rather than another source.

Cosmetic and promotional packaging are not covered by these PFAS thresholds. A broader PFAS restriction is separately under consideration at ECHA under REACH, a distinct piece of legislation still under review. For substances in packaging more broadly, REACH continues to apply in parallel through its own SVHC and Annex XVII restrictions; see AQF's REACH compliance guide. For importers also selling into California, heavy metals disclosure works differently there: the EU limits use, California requires a warning label above certain thresholds; see AQF's Prop 65 compliance guide. Toy packaging can also overlap with EU toy safety chemistry rules; see AQF's toy safety testing guide.

Recyclability Requirements (Article 6): Grades A, B, C from 1 January 2030

Article 6 requires packaging to be designed for recycling. From the date described above, only packaging graded A, B, or C on the recyclability performance scale can be placed on the EU market, and from 1 January 2035, packaging must also be recycled at scale in practice, meaning the collection, sorting and recycling infrastructure actually exists.

Recyclability is assessed against a design-for-recycling matrix covering material composition, separability of components, and the presence of disruptors, adhesive labels, incompatible inks, or non-recyclable coatings and laminates that interfere with sorting or reprocessing. Grades run from A, the most recyclable, down to E; only A, B and C remain sellable in the EU from the applicable 2030 date.

The factory-side implication is straightforward but often skipped: your packaging supplier needs to be able to document composition percentages and label, closure and coating specifications well enough to support a recyclability grade claim. Recyclability is not only a chemistry question either; a packaging format also needs to survive the distribution and reuse cycle physically. For the physical side of that, see AQF's packaging testing guide and ASTM D4169 distribution testing standard. Multi-material cosmetic packaging, such as airless pumps and laminated tubes, is a common weak point for recyclability grading; see AQF's cosmetic packaging guide for that category specifically.

Recycled Content Targets (Article 7): 30 to 65 Percent by 2030 and 2040

Article 7 sets minimum percentages of post-consumer recycled content in the plastic parts of packaging, subject to the same conditional timing described in the timeline above.

Plastic packaging type	2030	2040
Contact-sensitive PET packaging (except beverage bottles)	30 percent	50 percent
Contact-sensitive plastic packaging other than PET (except beverage bottles)	10 percent	25 percent
Single-use plastic beverage bottles	30 percent	65 percent
Other plastic packaging	35 percent	65 percent

Contact-sensitive covers packaging for food, cosmetics, medical, veterinary and other products where material safety rules already apply. Only post-consumer recycled content counts toward these targets; recycled offcuts recirculated within a factory's own production do not.

The evidentiary chain matters as much as the percentage. A recycled content claim needs to be backed by chain-of-custody documentation from the supplier, and ISCC PLUS mass balance certification has become the de facto standard used across Asia for tracing post-consumer recycled content through a supply chain. The European Commission is expected to adopt implementing acts on the calculation and verification methodology, but until that happens, mass balance certification remains the working standard suppliers and importers rely on.

Harmonised Labelling (Article 12) and the QR Code from 12 August 2028

From the applicable date in 2028, packaging placed on the EU market must carry a harmonised, pictogram-based label showing material composition, to help consumers sort waste correctly. The exact label design will be set by the European Commission through an implementing act.

The label is expected to cover material composition, such as plastic types, paper, metal, glass or wood, plus sorting guidance, and may be delivered through a QR code or other digital data carrier for smaller packaging formats. From 12 February 2029, or 30 months after the relevant implementing act, reusable packaging must additionally carry a label confirming it is reusable, with a QR code linking to information on the applicable reuse system and collection points.

PPWR does not create a formal Digital Product Passport. That concept is regulated separately under the Ecodesign for Sustainable Products Regulation. What PPWR actually requires is harmonised material composition labelling, plus a QR code for reusable packaging specifically. Packaging artwork and printing plates will need updating ahead of the 2028 date, and pre-production samples are worth checking against the final label specification once it is published.

HORECA Restrictions (Annex V): The 1 January 2030 Ban on Cosmetic Minis in Hotels

From 1 January 2030, Annex V of the PPWR prohibits certain single-use packaging formats in the hospitality sector. The most discussed of these, for AQF's clients, is the ban on small-format single-use packaging for cosmetic, hygiene and toiletry products supplied in hotels and similar accommodation.

Hotel shampoo, conditioner, shower gel and body lotion in single-use minis, typically small PET bottles or PP tubes, will no longer be allowed in EU accommodation from that date. Transition options include refillable in-room dispensers, larger bulk-format packaging, or B2B refill systems supplied to the property directly. Annex V also restricts a handful of other single-use formats, including certain packaging for food and drink consumed on premises in the hospitality sector.

Packaging suppliers in Asia producing hotel amenity kits will need to plan this transition well ahead of 2030, since retooling for refillable or bulk formats takes lead time. See AQF's cosmetic packaging guide for the category-specific detail on this shift.

Compliance for Importers: Declaration of Conformity, Technical Documentation, the 10-Day Rule

As the EU-established importer, you need to verify that the manufacturer has completed a conformity assessment, keep the EU Declaration of Conformity on file, and be able to produce technical documentation to national market surveillance authorities within 10 days of a reasoned request, under Article 18(8).

The Declaration of Conformity, following the Annex VIII format, is a written self-declaration from the manufacturer confirming the packaging meets Articles 5 to 12. It includes a unique reference number, manufacturer identification, a packaging description, the standards or specifications relied on, and the responsible signatory. It must be kept for 5 years for single-use packaging and 10 years for reusable packaging.

The technical documentation, following the Annex VII structure, is the evidence behind that declaration: packaging design description, material composition analysis, Article 5 substance data, recyclability grade evidence, recycled content chain-of-custody documents, labelling artwork, and any relevant test reports.

The 10-day rule under Article 18(8) is where this becomes a practical problem rather than a paperwork exercise. A business running hundreds of packaging types across several suppliers cannot assemble this documentation from scratch when an authority asks for it; the data needs to already exist, organised, before the request arrives. As covered above, an importer that rebrands packaging under its own name takes on the full manufacturer obligations under Article 21. For EU compliance support beyond packaging specifically, see AQF's lab testing and EU compliance services.

AQF's PPWR Workflow: Collecting the Data at the Factory Before Your Container Ships

AQF is not a testing laboratory. AQF is the party working inside the packaging factory in Asia, at the point where most of the evidence behind a Declaration of Conformity is actually generated.

The work runs in five parts. First, a supplier PPWR readiness audit covering substance composition, recyclability design, recycled content sourcing and labelling artwork, carried out on site at the packaging supplier's factory in China, Vietnam or India; see AQF's factory audit service. Second, sampling for substance verification, where an inspector collects a representative batch sample and arranges testing through the heavy metals and chemistry screening service, including PFAS screening where the packaging is food-contact. Third, recycled content chain-of-custody verification, requesting the mass balance certificate from the supplier and checking it against batch documentation. Fourth, assembling the documentation package into a structured file that supports the EU importer's own Declaration of Conformity. Fifth, a pre-shipment inspection confirming the shipped batch matches the sampled and documented packaging.

AQF does not build your Declaration of Conformity for you, and does not replace the manufacturer's own conformity assessment obligations. What AQF does is collect and verify the underlying evidence at the source, so the EU importer has what is needed to complete that documentation before 12 August 2026 and beyond.

Frequently Asked Questions

What is the PPWR?

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, is the EU-wide framework governing all packaging placed on the EU market. It was published in the Official Journal on 22 January 2025, entered into force on 11 February 2025 and applies generally from 12 August 2026. It replaces Directive 94/62/EC and is directly applicable in all 27 Member States, with no national transposition.

When does the PPWR apply?

The general application date is 12 August 2026, when Directive 94/62/EC is repealed. Further provisions phase in afterwards: harmonised labelling from 12 August 2028, reusable packaging labels and QR codes from 12 February 2029, and recyclability grades, recycled content targets and void space limits from 1 January 2030, though these three 2030 dates depend on the Commission adopting secondary legislation on schedule and could move later. HORECA restrictions apply from 1 January 2030 as a fixed date.

Does the PPWR apply to me if I import from China into the EU?

Yes. Any business placing packaging on the EU market carries duties under the PPWR. As the EU-established importer, you must verify the manufacturer has completed the conformity assessment, keep the Declaration of Conformity on file, and produce technical documentation within 10 days of a request under Article 18(8).

What substances does Article 5 of the PPWR restrict?

Article 5 sets a combined maximum of 100 mg per kg for lead, cadmium, mercury and hexavalent chromium in packaging. It also sets PFAS limits for food-contact packaging from 12 August 2026, under Article 5(5): 25 micrograms per kg for any individual PFAS, 250 micrograms per kg for the sum, and 50 mg per kg for total PFAS including polymeric forms.

Does the PFAS restriction apply to cosmetic or promotional packaging?

No. The PPWR's PFAS limits in Article 5 apply only to food-contact packaging. Cosmetic and promotional packaging are not covered by these thresholds. A separate, broader PFAS restriction is under review at ECHA under REACH, but it is not part of the PPWR.

Does the PPWR require a Digital Product Passport?

No. The PPWR requires harmonised material composition labelling from 12 August 2028 and, for reusable packaging, a QR code from 12 February 2029. A formal Digital Product Passport is regulated separately, under the Ecodesign for Sustainable Products Regulation.

What is a PPWR Declaration of Conformity?

A written self-declaration from the manufacturer, following the Annex VIII format, confirming the packaging meets Articles 5 to 12. It includes a reference number, manufacturer details, packaging description, the standards used, and the signatory. It must be retained for 5 years for single-use packaging and 10 years for reusable packaging.

What are the PPWR recycled content targets?

From the applicable 2030 date, plastic packaging parts must contain minimum recycled content: 30 percent for contact-sensitive PET packaging, 10 percent for other contact-sensitive plastics, 30 percent for single-use plastic beverage bottles, and 35 percent for other plastic packaging. These rise to 50, 25, 65 and 65 percent respectively by 2040.

Are hotel cosmetic minis banned by the PPWR?

Yes, from 1 January 2030. Annex V prohibits certain single-use packaging formats in the accommodation sector, including small-format cosmetic, hygiene and toiletry packaging supplied in hotels. Importers supplying that channel need to transition to refillable or larger-format packaging by that date.

What happens if my packaging does not meet PPWR requirements?

National market surveillance authorities can require corrective action, restrict or prohibit the packaging from the EU market, order a recall, and impose penalties set by each Member State. Non-conforming packaging can also be blocked at import and lead to disposal costs at the importer's expense.