The new EU Packaging Regulation (PPWR) – Requirements and practical steps

New PPWR Requirements: What Companies Need to Prepare For

Reusability of Packaging (Reuse Targets)

The PPWR requires a significant expansion of reuse systems. In the future, a substantial proportion of packaging must be reusable. For example, by 2030 at least 40% of sales and transport packaging used in the B2C sector must be reusable. This share will increase gradually until 2040 (for transport packaging in the B2B sector, 100% reuse is targeted in the long term). Similar targets—sometimes lower—apply to specific packaging types such as beverage packaging (e.g., 10% by 2030). Companies that use reusable packaging must integrate it into an organized reuse system from the start of application of the regulation or establish their own system. This means that return and refill infrastructures must exist, such as deposit or return systems, and consumers should be incentivized to return empty reusable packaging.

In practice, certain single-use packaging formats will also be banned or replaced. For example, restaurants, cafés and takeaway establishments must allow customers to bring their own containers for food and beverages and refrain from single-use packaging. In the hospitality sector, single-use portion packaging (e.g., mini shampoos or soaps) may no longer be provided from 2030 onward; refill dispensers will become mandatory. Transport packaging within the EU is also expected to increasingly shift to reusable solutions. For example, 40% of goods shipped to end customers must be delivered in reusable packaging by 2030. (However, some exceptions are foreseen—such as traditional cardboard shipping boxes—which may influence the actual impact.)

The key message: reusability will become the new standard. Companies should therefore evaluate which of their packaging formats can be converted to reusable systems in order to meet the quotas.

Recyclability of All Packaging (Design for Recycling)

In addition to reuse, recyclability is a central element of the PPWR. By 2030 at the latest, only packaging that is considered recyclable may be placed on the market. The regulation introduces specific criteria for this purpose. Packaging is considered recyclable if at least 70% of its material can be recycled. Packaging with a recyclability rate below 70% will be classified as non-recyclable from 2030 and may no longer be placed on the EU market. (Innovative packaging solutions that do not yet meet the criteria may benefit from a transition period of up to five years.)

By 2035, the requirements will become stricter: recyclability must then be demonstrated at industrial scale. In other words, it will no longer be sufficient for packaging to be theoretically recyclable—it must also be recyclable in practice in large volumes. From 2038 onward, the required recycling rate will increase further to 80%. Based on current recycling performance, some packaging types—such as certain beverage cartons (composite packaging)—could become non-compliant if their recycling rates remain below this threshold.

For companies, this means that every packaging solution must meet “design for recycling” criteria. Materials and construction must allow a high percentage of the packaging to enter recycling streams. Composite materials and difficult-to-separate components should be avoided. The PPWR also foresees performance classes to evaluate recyclability. Companies that fail to comply will no longer be able to sell such packaging from 2030 onward. Consequently, existing packaging designs should be optimized for recyclability as soon as possible.

Minimum Recycled Content (Use of Recyclates)

For the first time, the EU will introduce binding recycled-content targets for packaging materials.

These requirements currently apply only to plastic packaging, with tiered minimum levels for post-consumer recycled plastic (PCR).

From 2030, plastic packaging must contain between 10% and 35% PCR, depending on the application. Examples include:

• 30% recycled content for contact-sensitive PET packaging (e.g., food packaging made of PET)

• 10% recycled content for other plastic packaging with food contact (except PET)

• 30% recycled content on average for single-use plastic beverage bottles (a requirement already established in the Single-Use Plastics Directive)

• 35% recycled content for all other plastic packaging without food contact

These targets increase significantly by 2040:

• 50% PCR for PET food packaging

• 25% PCR for other plastic food packaging

• 65% PCR for other plastic packaging

Single-use plastic beverage bottles must contain 65% recycled plastic by 2040.

In practice, manufacturers must track and verify the recycled content of their packaging. The quotas are calculated as annual averages per packaging type and manufacturing facility. Supporting documentation—such as material balances or certification—must be included in the technical documentation for each packaging type.

Companies should therefore prepare to analyze their material flows in detail and require suppliers to disclose recycled-content data.

Packaging Design Requirements (Minimization and Bans)

The PPWR stipulates that packaging must be designed to minimize resource use. The weight and volume of packaging must be reduced to the minimum necessary level. Overpackaging will become unacceptable.

From 2030, binding criteria for packaging minimization will apply (Annex IV of the regulation). For example, the empty space ratio between product and packaging in shipping boxes, grouped packaging, or e-commerce packaging must not exceed 50%.

In other words, boxes that are half filled with air or filler material will no longer be permitted. This measure aims to eliminate misleading packaging practices such as oversized cereal boxes that are only partially filled.

The PPWR also bans certain packaging formats, particularly single-use plastic packaging. Examples include:

• Packaging fruit and vegetables under 1.5 kg in single-use plastic

• Single-use portion packaging for condiments, sugar, or cream in restaurants and hotels

• Miniature hotel toiletry bottles such as shampoo or soap

• Very lightweight plastic carrier bags, such as thin produce bags

Although some exceptions and sector-specific rules may apply, the overall objective is clear: unnecessary single-use packaging should disappear from the market.

The PPWR also introduces substance restrictions. Hazardous substances in packaging must be minimized. In particular:

• Heavy metals (lead, cadmium, mercury, hexavalent chromium) are limited to 100 mg/kg each.

• PFAS chemicals (per- and polyfluoroalkyl substances) in food-contact packaging will be restricted, and above certain concentrations they will be prohibited from 2026 onward.

Manufacturers must therefore ensure that their packaging materials do not contain problematic substances above permitted levels.

Uniform Labelling Requirements (Material and Disposal)

The PPWR introduces EU-wide harmonised labelling requirements for packaging. In the future, every package must clearly indicate what material it is made of and how it should be disposed of or recycled. This measure is intended to enable consumers to correctly separate packaging waste and to facilitate recycling.

A key element is a standardised labelling system using symbols and/or digital codes. As early as 2028, the Regulation will require every package to carry an identification marker—such as a QR code—that can provide additional information when scanned.

In addition, certain basic information must appear directly on the packaging once the Regulation enters into force, including:

• an identification element (e.g., a batch or serial number), and

• contact details of the manufacturer or importer (name, brand, address).

From 2028, extended labelling requirements will become mandatory. Packaging must then indicate:

• the materials it is made from,

• whether it is compostable,

• the percentage of recycled content, and

• whether it is reusable.

In addition, waste collection containers across the EU will be labelled in a uniform manner, enabling consumers to correctly assign packaging to the appropriate recycling or residual waste bin.

From 2030, packaging must also indicate the presence of any Substances of Very High Concern (SVHC).

For companies, this means having all relevant data and specifications readily available. Packaging designs will need to be adapted to create space for this information. Standardised symbols will be defined at EU level, while national schemes such as the “Green Dot” are likely to become less prominent over time.

These labelling obligations require forward planning, as packaging will need to be newly printed or equipped with codes. It is important that these additions do not obscure advertising elements or essential product information, making close coordination with packaging designers advisable.

The overarching goal of these measures is greater transparency: consumers should be able to recognise at a glance—or via a quick scan—how to handle packaging correctly, while manufacturers are made responsible for providing complete and accurate information.

Documentation and Evidence Requirements (EPR and Conformity)

In addition to the technical requirements, the PPWR also tightens the administrative obligations for companies placing packaging on the market. In the future, companies will have to provide more comprehensive proof that they comply with the rules. This includes, first, a conformity assessment for each packaging type: manufacturers (i.e., “producers” within the meaning of the Regulation) must prepare a form of technical file/technical datasheet documenting that the packaging complies with Articles 5–12 of the PPWR (e.g., meets applicable limit values, is designed for recycling, fulfils the recycled-content requirement, etc.). This technical documentation must be made available to competent authorities on request and includes, among other things, evidence of recycled content and recyclability. Companies should therefore be prepared to systematically collect the necessary data and certificates.

Another major area is extended producer responsibility (Extended Producer Responsibility, EPR). The PPWR harmonises EPR requirements across the EU and introduces producer registers. From 2027, any producer that places packaging on the market in an EU Member State must be registered in that country’s packaging register. If the company has no establishment in that Member State, it must appoint an authorised representative locally to fulfil the obligations on its behalf. In Germany, for example, the LUCID packaging register already exists; comparable registers will be introduced in all Member States. From 2027, online marketplaces (e.g., Amazon, eBay) may only allow sellers that have fulfilled their EPR obligations—meaning they must verify that merchants are registered and pay the required licensing fees.

Reporting obligations will also be standardised: producers must report their packaging quantities (by material type and weight) annually to the authorities. The first report under the new system will be due in 2027. It is possible that reporting will be handled centrally via an EU portal or at least under harmonised standards to avoid, for example, duplicate reporting across several countries. For small companies placing less than 10 tonnes of packaging per year on the market, the Regulation provides for potential simplifications. These could include simplified reporting or exemptions from certain quotas—details are still being developed. Importantly, the fundamental obligations (such as recyclable design) will apply in the long term to all companies, regardless of size.

Within the EPR framework, companies remain responsible for covering the costs of managing their packaging waste (licensing fees paid to compliance schemes and/or national recycling funds). However, these fees are expected to become eco-modulated, meaning environmentally friendly packaging will be financially favoured and problematic packaging will become significantly more expensive. The aim is to create incentives to design packaging so it is easier to recycle and to increase the use of recycled plastic. In practice, this could mean that companies placing hard-to-recycle packaging on the market (e.g., composite materials without a viable recycling pathway) will pay substantially higher contributions than companies using mono-material, readily recyclable packaging. For cost reasons as well, companies should therefore strive to meet PPWR standards.

Finally, the PPWR calls for expanded return and deposit-refund systems. By 2029 at the latest, all Member States must have deposit systems in place for single-use plastic and metal beverage containers up to 3 litres. When such beverages are sold, a deposit must be charged and refunded to consumers upon return of the container. Companies in the beverage industry must be prepared to integrate their single-use containers into a deposit system—if no national system exists yet, one will need to be established. In addition, per-capita packaging waste is to be reduced by 5% by 2030 (and by 15% by 2040) compared to 2018. While these reduction targets are primarily addressed to Member States, they underline the political pressure on businesses to reduce packaging.

Interim conclusion: Companies in all sectors—whether food, e-commerce, consumer goods or industry—must review their packaging and processes. Large corporations with complex packaging portfolios face major tasks, but so do smaller retailers that may use only a few packaging types. While very small companies placing packaging on the market (< 10 t/year) may face slightly less bureaucracy, the new design and environmental requirements will ultimately apply to every business. In the next section, we show concrete steps you can take to make your company PPWR-ready.

Practical Guide: How to Prepare Your Company for the PPWR

The following steps will help you prepare systematically for the new requirements. Depending on your company size and industry, they can be adapted and should ideally be initiated at an early stage.

1. Conduct an internal packaging assessment

First, obtain an overarching overview of all packaging that you use or place on the market. As part of an internal assessment, record the following: Which packaging types and materials do you use (primary packaging for products, secondary packaging, shipping cartons, cushioning/fill material, labels, etc.)? What annual volume/weight is generated for each packaging type? For each packaging format, document the material composition (type of plastic, share of paper, composite structures, etc.), whether it is reusable or single-use, and whether it already contains recycled content.

Also check whether certain packaging types are affected by specific rules, such as single-use plastic packaging for fruit and vegetables, service packaging in the hospitality sector, or very small single-portion formats.

Based on this inventory, you can then carry out targeted gap analyses: Which of your packaging formats already largely meet the future requirements—and which do not? Identify “critical” packaging, for example packaging that is not recyclable (composite films, mixed materials, black plastics, etc.), contains no recycled content, or is unnecessarily complex (oversized, multiple seals, etc.). Also note where product requirements impose constraints—for example in food packaging (hygiene, food safety) or dangerous goods packaging. A thorough assessment provides the foundation for all subsequent steps.

2. Involve suppliers and packaging manufacturers

Implementing the PPWR requirements can only succeed through close collaboration with your partners and suppliers. Therefore, involve your packaging manufacturers and suppliers in the process at an early stage. Inform your packaging suppliers (manufacturers of cartons, films, bottles, etc.) about the upcoming requirements and actively ask what solutions they can offer. Request supporting documentation and specifications, for example: Is the packaging you purchase already demonstrably recyclable? What level of recycled content does the material currently contain, and are increases planned? Are there certifications or tests verifying recyclability (e.g., according to the PTS standard for paper or RecyClass for plastics)?

Work together with your suppliers to identify improvements. Many packaging manufacturers are currently developing new materials—for example mono-material plastic films that replace traditional composites, or reinforced thinner films designed to reduce material usage. Make use of this expertise for your own purposes. Clearly signal to your suppliers at an early stage that, from a certain point onward, you will only procure PPWR-compliant packaging—this will encourage them to transition more quickly.

Internal stakeholders and additional suppliers should also be involved. If you source goods that already arrive packaged (e.g., imported products), include your product suppliers in the process. Require them to ensure that their packaging also complies with the new rules—if necessary, responsibilities should be clarified contractually. Communication is crucial here: consider organising workshops or information sessions with your key packaging and material suppliers in order to discuss and develop joint solutions.

3. Assess and Document Recyclability

Review each of the packaging formats you identified and evaluate how recyclable they are. Use recognized criteria or assessment standards as guidance (such as Design for Recycling guidelines, recommendations from the German Central Packaging Register Authority, or CEFLEX standards for flexible packaging). Ask questions such as:

• Material purity: Is the packaging made from a single primary material or from multiple different components? (Mono-material packaging is generally easier to recycle than composite materials.)

• Separability: Can different layers or components be easily separated from one another? (For example, removing labels, separating lids from cups, or separating layers in composite films.)

• Colorants and additives: Does the plastic contain problematic dyes (e.g., carbon black) or additives that could interfere with recycling processes?

• Existing recycling streams: Is there already an established recycling infrastructure for this packaging? (Some plastics are widely collected and recycled, while others—such as certain multilayer packaging formats—are not.)

• Recycling yield: What proportion of the material can actually be recovered? (For complex packaging, this share is often relatively low.)

Document the results of this assessment carefully. For packaging that is clearly not sufficiently recyclable (e.g., composite materials combining aluminium and plastic where less than 70% can be recycled), a redesign or replacement should be planned—no later than 2030, when such packaging may no longer be placed on the market.

Packaging that is already largely recyclable today (such as single-material PET bottles or uncoated cardboard boxes) will likely meet the 70% threshold. Nevertheless, even in these cases further optimisation may be possible—for example by using alternative label adhesives that allow paper fibres to be recovered more efficiently.

Important: Keep the relevant documentation readily available. Authorities may require proof of how recyclability has been ensured. This evidence may come from independent testing institutes, supplier test results, or recognised certification schemes.

Your technical documentation should clearly specify the intended recycling stream for the packaging (paper, glass, plastic, etc.) and the expected recycling rate. This will ensure you are prepared once the mandatory recyclability requirement becomes fully enforceable from 2030 onward.

4. Analyse and Optimise the Use of Recycled Content in Plastics

Review your use of recycled materials across the various packaging types. In Step 1, you already identified where recycled content is currently used. The next step is to compare these values with the requirements of the PPWR. Create an overview showing which of your packaging types already meet the minimum recycled-content quotas and which do not. Particular priority should be given to plastic packaging, as clear quotas will apply here from 2030 onward (10%, 30%, or 35%, depending on the category).

For each relevant packaging type, ask yourself: How can the share of recycled material be increased? Possible approaches include:

• Increase the use of post-consumer recyclates (PCR) in plastic packaging. Many films, bags, and bottles can already be produced with a certain percentage of recycled material. Speak with your plastic suppliers about available grades and qualities. In some cases, material testing may be necessary to ensure that functionality—such as barrier properties for food packaging—remains intact.

• Increase the proportion of recycled fibres in paper and cardboard packaging. Shipping cartons and cardboard product packaging can often be manufactured using almost 100% recycled material, if this is not already the case. Check whether switching from virgin-fibre board to recycled board is possible without compromising appearance or tactile quality.

• Consider recycled content in glass packaging. In Germany, glass packaging typically already contains a high proportion of cullet (around 60–90% recycled glass). Ensure that you use colour-sorted glass, since green glass, for example, allows higher recycled-content rates than clear glass.

• Assess recycled content in metal packaging. For metal packaging such as beverage cans, food cans, or closures, ask your suppliers what proportion of secondary metal is already used and whether it can be increased.

Take sector-specific requirements into account. Packaging with food contact is subject to strict regulations—for example, recycled plastic cannot simply be used for primary food packaging unless it comes from approved recycling processes (such as rPET used for beverage bottles). In some cases, exceptions or lower quotas apply (such as the 10% requirement for non-PET plastic food packaging).

Establish a monitoring system to regularly track the recycled content used in your packaging. Larger companies in particular should track key metrics by material type and product line in order to demonstrate progress to authorities and customers. This will allow you to continuously optimise your packaging year by year—especially since the quotas increase further by 2040, and even stricter targets may be introduced in the future.

5. Implement Labelling and Information Requirements

Plan the implementation of the new labelling requirements well in advance. This step requires both organisational preparation (data management) and graphic adjustments to your packaging.

Data and IT:
Ensure that you have all the necessary information available for each packaging type so it can later be provided via a code or printed directly on the packaging. This includes: material types and proportions, the presence of hazardous or problematic substances, recycled content (%), where applicable compostability and reusability properties, as well as manufacturer information. Ideally, this data should be maintained centrally in your product database or a dedicated packaging register. Keep in mind that any design changes will also need to be updated accordingly.

Design and printing:
Review where additional labelling can be integrated on your packaging. From 2028 onward, several pieces of information must appear on packaging in a clearly readable format. These may include pictograms (for example a material symbol similar to today’s recycling codes) as well as short texts or numbers (such as “30% recycled content”). It is possible that EU-wide standardised symbols will be introduced—monitor the delegated acts of the European Commission in the coming years for further details. You should prepare your packaging designers for upcoming layout changes. In some cases, redesigning labels, film prints, carton layouts, or other packaging elements may be necessary in order to incorporate the required information without significantly compromising branding.

Introduce QR codes:
By 2026 at the latest, every package must carry a machine-readable QR code or similar digital marker. Consider how this will be implemented technically: for example, will the code be integrated into the packaging print, or applied as a label? The code must be linked to your internal data records. One option is to embed a URL linking to a product or company webpage where all required information is accessible. Some companies are also considering enhancing existing QR codes (e.g., those used for marketing purposes) with mandatory information in order to avoid printing additional codes.

Train employees:
Ensure that your marketing and packaging development teams are familiar with the new labelling obligations. They should understand which information will be required and when, and how to determine the necessary specifications. Internal processes may need to be established to coordinate approvals for new packaging texts and symbols. Your customer service team should also be informed, as consumers may begin asking questions about the new codes and symbols from 2026/2028 onward.

Inform consumers:
Use the transition period to gradually familiarise your customers with the new practices. For example, retailers can already communicate messages such as: “Our packaging contains 80% recycled material and is fully recyclable—please dispose of it in the recycling system.” Instructions for proper disposal (e.g., “Please dispose of this in the paper recycling bin”) not only support recycling but also prepare consumers for the upcoming mandatory labelling requirements. In the hospitality and food service sector, businesses should already actively inform customers that they may bring their own containers—this builds acceptance and routine before it becomes mandatory under the regulation.

6. Adapt Processes for Extended Producer Responsibility

The new obligations relating to registration, reporting, and extended producer responsibility (EPR) also require adjustments to internal processes. Companies should address the following points:

Ensure registration:
Review in which countries you are already registered in packaging registers and where gaps may exist. By 2027, you must be registered in every EU country where you first place packaging on the market. For example, if you supply customers in France from Germany, you will either need your own registered entity there or appoint an authorised representative in France who can register and represent you. Start identifying such representatives or service providers early, as otherwise sales restrictions could apply from 2027 onward. Keep all registration numbers documented centrally so that you can provide them when required (e.g., to online marketplaces).

Collect reporting data:
Establish a system that allows you to efficiently prepare packaging volume reports. Most likely, you will need to report the quantities of each material type (plastic, paper, glass, metal, etc.) annually, possibly separated into primary and secondary packaging. Coordinate with your accounting department or ERP system to determine whether such data is already recorded (e.g., purchasing or sales statistics by packaging type). If necessary, introduce new workflows—for example ensuring that product management maintains material master data for each packaging type, which can then be aggregated for reporting. The better your data foundation, the easier it will be to fulfil reporting obligations from 2027 onward. Keep in mind that incorrect or missing reports may result in penalties.

Licensing and cost planning:
Assess how eco-modulated fees may affect your costs. If you already pay licensing fees for packaging today, the fee structure may change in the future. Packaging that is difficult to recycle will likely become more expensive. Plan a budget for potentially increasing disposal costs associated with problematic materials—or, ideally, reduce these materials to save costs. For example, you might consider replacing a plastic packaging type that is currently difficult to recycle—not only to comply with legal requirements, but also to avoid high future licensing fees. Conversely, investments in recyclable packaging may pay off through lower compliance scheme fees.

Define internal responsibilities:
The new tasks—registration in multiple countries, regular reporting, and compliance monitoring—require clear internal responsibilities. Determine who in your organisation should manage these issues. Larger companies may establish dedicated packaging compliance teams, while smaller companies may rely on external service providers or consultants for packaging licensing and regulatory compliance. The key is to ensure nothing is overlooked. Maintain a PPWR compliance checklist and track which requirements have already been completed (e.g., registration in country X, reporting database established, etc.).

Consider industry-specific requirements:
If you operate in a specific sector, take into account the additional rules that apply. For example, a beverage manufacturer should examine early on how to integrate its distribution system into the future deposit-return scheme by 2029 (e.g., cooperation with retail partners, installation of reverse vending machines, labelling bottles with deposit marks, etc.). A hospitality business will need to adjust its processes so that reusable containers can be managed from 2030 onward (for example, logistics for cleaning reusable cups). E-commerce retailers should develop concepts to increase the share of reusable shipping packaging—such as participating in reusable shipping bag pools or return systems.

One final tip: start now. Although many deadlines are still several years away (2026, 2030, etc.), the required measures are extensive and in some cases involve fundamental changes in procurement, packaging design, and organisational processes. Early adjustments provide competitive advantages—you can already use sustainability as a selling point—and reduce the risk of time pressure or compliance issues later on. Do not hesitate to seek external support. There are specialised consultancies, industry associations, and service providers (such as compliance schemes or environmental consultants) that can assist with PPWR implementation. Given the complexity of the new regulation, this can be particularly helpful for smaller companies to ensure nothing is overlooked.

Conclusion

The new EU Packaging and Packaging Waste Regulation places all companies under pressure to make their packaging more sustainable. Businesses that begin preparing now—through internal analysis, supplier collaboration, and process adjustments—will not only comply with the upcoming obligations but can also turn them into an opportunity: more efficient packaging, cost savings through recycling, and a stronger sustainability profile. Make your company PPWR-ready to continue operating successfully and in full legal compliance in the future. The clock is ticking—start taking action now.