PART 1 — The EU Packaging & Packaging Waste Regulation (PPWR) 2025/40: What It Means and Why It Matters

By John Elliott and Pegah Mohebbi

This regulation represents the most significant overhaul of packaging legislation in Europe for more than 30 years. Unlike the previous Packaging Waste Directive, the PPWR is a regulation, meaning it applies directly and uniformly across all EU Member States without national transposition. Its purpose is simple but ambitious: reduce packaging waste, increase recyclability, and accelerate the transition to a circular economy.

The Regulation comes into effect from August 2026 and will be implemented in phases through to 2040 At its core, PPWR aims to tackle three systemic issues: excessive packaging, low recycling rates, and inconsistent rules across Member States These are barriers preventing a low carbon circular economy. For businesses operating in or exporting to the EU, this means a new era of mandatory design requirements, reuse obligations, recyclability performance grades, and strict reporting duties. The regulation is 125 pages with 71 legally binding articles. What follows is a synopsis of sustainability requirements that the author considers to be salient points.

A Shift From “Encouragement” to “Enforcement”

This is not guidance — it is enforceable law. Non-compliance will result in penalties at Member State level, and enforcement is expected to be significantly tighter than under the previous Directive.

Why the Regulation Matters

The EU generates around 80 million tonnes of packaging waste annually, and this figure continues to rise. PPWR aims to reverse this trend by:

• Reducing packaging waste by 15% per capita by 2040
• Ensuring 100% of packaging is recyclable
• Increasing reuse across food service, e commerce, and transport packaging
• Cutting dependency on virgin materials
• Driving investment in recycling infrastructure and circular systems

For businesses, this means packaging decisions are no longer simply commercial or aesthetic — they are regulatory.

Who Is Affected?

Any organisation that places packaging on the EU market is in scope. This includes:

• Manufacturers
• Importers
• Distributors
• Online retailers
• Brand owners
• Fulfilment service providers – (businesses that store, package, label, dispatch or otherwise handle goods on behalf of another company)
• UK businesses exporting to the EU must comply in full.

Key Obligations Under PPWR Requirements for substances in Packaging

1. Requirements for substances in Packaging (Article 5) Implementation date12^th August 2026

Substances of concern – For food packaging limits are set on per and polyfluorinated alkyl substances (PFAS). Food and non-food packaging limits are depicted for maximum concentrations of lead, cadmium, mercury and hexavalent chromium resulting from

substances present in packaging. In this article it also details by 31^st December 2026 defining chemicals which negatively affect the reuse and recycling of materials.

2. Recyclability Requirements (Article 6) Implementation date – 1^st January 2030

All packaging must meet recyclability criteria based on:

• Material composition
• Ease of sorting
• Compatibility with existing recycling technologies
• Absence of problematic components (e.g., carbon black, PVC, certain adhesives)

All packaging will be graded A–C. From 2030

When a packaging unit’s recyclability performance grade is below 70 %, Grade C it is non-compliant. This packaging will not be placed on the market. There is sometime but planning needs to be in place to identify packaging substances at risk so a strategy can be developed to ensure minimum grade C. – If required Auditel can support with this activity.

3. Minimum Recycled Content in Plastic Packaging (Article 6) 1^st Jan 2030

As an example, plastic bottles must have 30 % recycled content and in 2040 this will increase to 65%

From 2030 single use plastic will be banned in below sectors (some very specific restricted uses will be permitted.)

1. At point of sale for collation films and shrink-wrap.
2. For unprocessed fresh fruit and vegetables, Nets, bags, trays, containers less than 1.5Kg
3. Hospitality trays, disposable plates, cups, bags and boxes
4. Hospitality sector for condiments, preserves, sauces, coffee creamer no sachets, tubs and trays.

4. Reuse and Refill Obligations (Article 11) 12^th Feb 2027

Sectors such as food service, takeaway, transport packaging, and e commerce face mandatory reuse quotas. For example:

• A percentage of takeaway beverage containers must be reusable
• E commerce packaging must meet reuse performance standards
• Transport packaging must shift to reusable systems where feasible

5. Packaging Minimisation (Article 10) 12^th Feb 2027

The PPWR restricts:

• Double walled packaging. – This makes the pack look larger or more premium than the actual product volume requires
• Excessive void space in e commerce, here Auditel can quantify and make proposals if required.
• Miniature packaging formats
• Single use hotel toiletries

6. Labelling of Packaging (Article 12) 12^th Aug 2028

All packaging must carry:

• A material identification label
• A sorting label
• A reuse label (where applicable)

These labels will be standardised across the EU.

7. Obligations of Manufacturers (Article 16)

The purpose is to demonstrate compliance with Articles 5–12 Documentation shall include design and manufacture of the packaging all relevant manufacturing drawings, specifications, and details of material components.

The documentation must explain how the packaging meets the requirements of:

• Article 6 — Recyclability, including evidence supporting the assigned recyclability performance grade.
• Article 10 — Packaging Minimisation, demonstrating that the packaging uses the minimum amount of material necessary while maintaining functionality.
• Article 11 — Reusable Packaging, where applicable, including the design features that enable reuse and the conditions under which reuse is ensured.

All documentation must be retained for five years from the date the packaging is placed on the market. A Declaration of Compliance shall be prepared as described in the regulation for each packaging type, supported by the technical evidence described above. This documentation must be made available to the relevant market surveillance authorities upon request. (Auditel can give support for documentation)

Why Businesses Must Act Now

The PPWR is already in force. Transition periods vary by requirement, but many obligations apply from 2026–2030. Businesses that delay risk:

• Non-compliance penalties
• Loss of EU market access
• Increased costs due to last minute redesigns
• Supply chain disruption
• Reputational damage

The PPWR is not simply a regulatory burden — it is a catalyst for innovation. Companies that adapt early will benefit from reduced costs, improved sustainability credentials, and stronger market positioning.