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

New PPWR requirements: What companies need to prepare for

Reusability of packaging (reuse quotas)

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 shipping packaging used in the B2C sector is expected to 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, sometimes lower, targets apply to specific packaging types, such as beverage packaging, where the target is, for example, 10% by 2030.

Companies using reusable packaging must integrate it into an organised reuse system from the start of application of the Regulation or establish their own system. This means that return and refill infrastructure must be available, such as deposit or return systems, and consumers should be incentivised to return empty reusable packaging.

In practice, certain single-use packaging formats will also be banned or replaced. Restaurants, cafés and takeaway businesses must allow customers to bring their own containers for food and beverages and avoid single-use packaging. In the hospitality sector, single-use portion packaging, such as mini shampoos or soaps, may no longer be provided from 2030; refill dispensers will be required instead.

Transport packaging within the EU is also expected to shift increasingly to reusable solutions. For example, 40% of goods shipped to end consumers must be delivered in reusable packaging by 2030. However, exceptions are foreseen, for example for traditional cardboard shipping boxes, which may affect the actual impact.

The key message is clear: Reusability will become the new standard. Companies should therefore assess which 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 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 onwards, the required recycling rate will increase further to 80%. Based on current recycling performance, some packaging types, such as certain beverage cartons or other 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 assess recyclability. Companies that fail to comply will no longer be able to sell this packaging from 2030 onwards. Therefore, existing packaging designs should be optimised for recyclability as early as possible.

Minimum recycled content

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 its application. Examples include:

• 30% recycled content for contact-sensitive PET packaging, such as food packaging made from PET

• 10% recycled content for other food-contact plastic packaging, except PET

• 30% recycled content on average for single-use plastic beverage bottles

• 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 food-contact plastic 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 certificates, must be included in the technical documentation for each packaging type.

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

Packaging design requirements: Minimisation and bans

The PPWR stipulates that packaging must be designed to minimise 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 minimisation will apply under 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 void-fill 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 minimised. In particular:

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

• PFAS chemicals in food-contact packaging will be restricted and, above certain concentrations, prohibited from 2026 onwards.

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. From 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:

• An identification element, for example a batch or serial number

• Contact details of the manufacturer or importer, including name, brand and address

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

• The materials it is made from

• Whether it is compostable

• The percentage of recycled content

• 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 objective is greater transparency: Consumers should be able to recognise at a glance, or through a scan, how to handle packaging correctly, while manufacturers become responsible for providing complete and accurate information.

Documentation and evidence requirements: EPR and conformity

In addition to the technical requirements, the PPWR also tightens administrative obligations for companies placing packaging on the market. In the future, companies will have to provide more comprehensive evidence that they comply with the rules.

This includes a conformity assessment for each packaging type. Manufacturers, meaning “producers” within the meaning of the Regulation, must prepare a technical file documenting that the packaging complies with Articles 5 to 12 of the PPWR. This includes, for example, compliance with relevant limit values, design for recycling and the recycled-content requirement.

This technical documentation must be made available to competent authorities upon request and includes evidence of recycled content and recyclability. Companies should therefore prepare to systematically collect the necessary data and certificates.

Another major area is extended producer responsibility (EPR). The PPWR harmonises EPR requirements across the EU and introduces producer registers. From 2027, any producer placing 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 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, such as Amazon and eBay, may only allow sellers that have fulfilled their EPR obligations. This means they must check 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. Reporting may be handled centrally via an EU portal or, at minimum, under harmonised standards in order to avoid duplicate reporting in 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. However, the fundamental obligations, such as recyclable design, will ultimately apply to all companies regardless of size.

Within the EPR framework, companies remain responsible for covering the costs of managing their packaging waste through licensing fees paid to compliance schemes or national recycling funds. However, these fees are expected to become eco-modulated: environmentally friendly packaging will be financially favoured, while problematic packaging will become significantly more expensive.

The aim is to create incentives to make packaging easier to recycle and increase the use of recycled plastic. In practice, companies placing hard-to-recycle packaging on the market, for example composite materials without a viable recycling pathway, could 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 three litres. When such beverages are sold, a deposit must be charged and refunded to consumers when the container is returned. Companies in the beverage sector 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 15% by 2040 compared with 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 using only a few packaging types. While very small companies placing packaging on the market – less than 10 tonnes per year – may face slightly less bureaucracy, the new design and environmental requirements will ultimately apply to every business.

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 early.

1. Conduct an internal packaging assessment

First, obtain a complete overview of all packaging that you use or place on the market. Record:

• Packaging types and materials, such as primary product packaging, secondary packaging, shipping cartons, cushioning or fill material and labels

• Annual quantity and weight for each packaging type

• Material composition, including plastic type, paper share and composite structures

• Whether the packaging is reusable or single-use

• Whether it already contains recycled content

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

Based on this inventory, you can carry out a targeted gap analysis: Which packaging formats already largely meet future requirements, and which do not? Identify critical packaging, for example packaging that is not recyclable, such as composite films, mixed materials or black plastics; contains no recycled content; or is unnecessarily complex, such as oversized or multiply sealed packaging.

Also note where product requirements create restrictions, for example in food packaging through hygiene and food-safety requirements or in dangerous-goods packaging. A thorough assessment provides the foundation for all subsequent steps.

2. Involve suppliers and packaging manufacturers

Implementing PPWR requirements can only succeed through close collaboration with partners and suppliers. Therefore, involve packaging manufacturers and suppliers early. Inform suppliers of cartons, films, bottles and similar materials about the upcoming requirements and actively ask what solutions they can offer.

Request supporting documentation and specifications, for example:

• Is the packaging demonstrably recyclable?

• What level of recycled content does it currently contain, and are increases planned?

• Are there certifications or tests verifying recyclability, for example according to the PTS standard for paper or RecyClass for plastics?

Work together with suppliers to identify improvements. Many packaging manufacturers are developing new materials, for example mono-material plastic films that replace conventional composites or reinforced thinner films that reduce material use. Make use of this expertise.

Clearly signal to suppliers early that, from a certain date, you will only procure PPWR-compliant packaging. This can encourage a faster transition.

Involve internal stakeholders and further suppliers as well. If you source products that already arrive packaged, such as imported goods, require suppliers to ensure that their packaging also meets the new requirements. Where necessary, clarify responsibility contractually. Consider workshops or information sessions with key packaging and material suppliers to develop joint solutions.

3. Assess and document recyclability

Review each identified packaging format and evaluate how recyclable it is. Use recognised criteria or assessment standards as guidance, such as design-for-recycling guidelines, recommendations from the Central Agency Packaging Register or CEFLEX standards for flexible packaging.

Ask questions such as:

• Material purity: Is the packaging made of one main material or multiple components? Mono-material packaging is usually easier to recycle than composite materials.

• Separability: Can different layers or components be separated easily, for example labels removed, lids separated from cups or layers in composite films separated?

• Colourants and additives: Does the plastic contain problematic dyes, such as carbon black, or additives that could interfere with recycling?

• Existing recycling streams: Is established recycling infrastructure already available for this packaging? Some plastics are widely collected and recovered, whereas others, such as certain multilayer formats, are not.

• Recycling yield: What proportion of the material can actually be recovered? This share is often low for complex packaging.

Document the results carefully. For packaging that is clearly not sufficiently recyclable, such as aluminium-plastic composites where less than 70% can be recycled, plan a redesign or replacement no later than 2030, when it 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, further optimisation may be possible, for example through alternative label adhesives that improve recovery of paper fibres.

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

Your technical documentation should clearly specify the intended recycling stream for the packaging, for example paper, glass or plastic, as well as the expected recycling rate. This will ensure that you are prepared when the mandatory recyclability requirement becomes fully enforceable from 2030 onwards.

4. Analyse and optimise recycled content in plastics

Review your use of recycled materials across packaging formats. The inventory from Step 1 will have already identified where recycled content is used. The next step is to compare these values with PPWR requirements.

Create an overview showing which packaging types already meet minimum recycled-content targets and which do not. Give particular priority to plastic packaging, as clear quotas will apply from 2030: 10%, 30% or 35%, depending on the category.

For each relevant packaging type, ask: How can the recycled-content share be increased? Possible approaches include:

• Increase the use of PCR in plastic packaging. Many films, bags and bottles can already be manufactured with a certain share of recycled material. Discuss available grades and qualities with plastic suppliers. Material testing may be necessary to ensure that functions, such as barrier properties for food packaging, are retained.

• Increase recycled fibre content in paper and cardboard packaging. Shipping cartons and cardboard product packaging can often be manufactured from almost 100% recycled material. Check whether a switch from virgin-fibre board to recycled board is possible without compromising appearance or feel.

• Consider recycled content in glass packaging. In Germany, glass packaging typically already contains a high share of cullet, around 60–90%. Use colour-sorted glass where possible; green glass, for example, permits higher recycled-content rates than clear glass.

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

Take sector-specific requirements into account. Food-contact packaging is subject to strict rules. For example, recycled plastic cannot simply be used for primary food packaging unless it comes from approved recycling processes, such as rPET for beverage bottles. In some cases, exemptions or lower quotas apply, such as the 10% target for non-PET food-contact plastic packaging.

Establish a monitoring system to track recycled content in your packaging regularly. Larger companies should monitor key figures by material type and product line to demonstrate progress to authorities and customers. This enables ongoing optimisation, especially because quotas will increase further by 2040 and stricter targets may follow.

5. Implement labelling and information requirements

Plan implementation of the new labelling requirements in good time. This requires both organisational preparation, particularly data management, and graphic adjustments to packaging.

Data and IT: Ensure that all necessary information is 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, compostability and reusability where applicable, and manufacturer information. Ideally, this data should be maintained centrally in a product database or dedicated packaging register. Remember that every design change also needs to be recorded.

Design and printing: Review where additional labelling can be added to packaging. From 2028 onward, several pieces of information must appear in a clearly readable format. This may include pictograms, such as material symbols similar to current recycling codes, and short text or numeric information, such as “30% recycled content”.

EU-wide standardised symbols may be introduced. Follow the delegated acts of the European Commission for further details. Prepare packaging designers for upcoming layout changes. Labels, film prints, carton layouts and other packaging components may need to be redesigned to accommodate the information without significantly compromising branding.

Introduce QR codes: By 2026 at the latest, every package must carry a machine-readable QR code or comparable digital marker. Consider how to implement this technically: Will the code be part of the packaging print or applied as a label? The code must be linked to internal data. One option is to use a URL leading to a product or company page where all required information is available.

Some companies may also consider enhancing existing QR codes, such as those used for marketing purposes, with mandatory information to avoid printing an additional code.

Train employees: Ensure that marketing and packaging-development teams understand the new labelling obligations, which information is required, when it is required and how the necessary specifications are determined. Create internal processes to coordinate approvals of new packaging text and symbols where necessary. Customer-service teams should also be informed, as consumers may begin asking questions about new codes and symbols from 2026 and 2028 onwards.

Inform consumers: Use the transition period to familiarise customers with new practices. For example, retailers can already communicate: “Our packaging contains 80% recycled material and is fully recyclable – please place it in the recycling collection.” Disposal guidance, such as “Please dispose of this in the paper recycling bin”, supports recycling and prepares consumers for upcoming mandatory labelling.

In the hospitality and food-service sector, businesses should already inform customers that they may bring their own containers. This builds acceptance and routine before it becomes compulsory under the Regulation.

6. Adapt processes for extended producer responsibility

New obligations for registration, reporting and extended producer responsibility (EPR) also require changes to internal processes.

Ensure registration: Review where 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 an authorised representative in France who can register and represent you. Start identifying representatives or service providers early, as sales restrictions could otherwise apply from 2027 onwards. Document registration numbers centrally so that they can be provided to online marketplaces or other parties when required.

Collect reporting data: Establish a system that enables efficient packaging-volume reporting. You will likely need to report quantities of each material type – plastic, paper, glass and metal, for example – annually, potentially separated by primary and secondary packaging. Coordinate with accounting and ERP teams to determine whether this data is already available. If necessary, introduce workflows to ensure that product management maintains material master data for each packaging type so it can be aggregated for reporting. The better the data base, the easier it will be to fulfil reporting obligations from 2027 onwards. Incorrect or missing reports may result in penalties.

Licensing and cost planning: Assess how eco-modulated fees may affect costs. Fee structures may change. Packaging that is difficult to recycle will likely become more expensive. Plan for potentially higher disposal costs for problematic materials, or preferably reduce these materials to save costs. Replacing difficult-to-recycle packaging can help meet legal requirements and avoid future high licensing fees. Conversely, investments in recyclable packaging may pay off through lower compliance-scheme fees.

Define internal responsibilities: Registration in multiple countries, regular reporting and compliance monitoring require clear responsibilities. Determine who within the organisation will manage these areas. Larger companies may establish packaging-compliance teams, while smaller companies can draw on external service providers or consultants. Keep a PPWR compliance checklist and track what has already been completed, for example registration in a particular country or creation of a reporting data base.

Consider industry-specific requirements: Businesses in specific sectors should also consider applicable additional rules. A beverage manufacturer should assess early how to integrate its distribution system into the future deposit-return scheme by 2029, for example through cooperation with retail partners, reverse-vending machines or deposit markings. A hospitality business will need to manage reusable containers from 2030, including logistics for cleaning reusable cups. E-commerce retailers should develop concepts to increase the share of reusable shipping packaging, for example by participating in reusable shipping-bag pools or return systems.

Conclusion

The new EU Packaging and Packaging Waste Regulation places all companies under pressure to make packaging more sustainable. Businesses that prepare now through internal analysis, supplier collaboration and process adjustments will not only comply with upcoming obligations but can 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. The clock is ticking – start taking action now.