The Packaging and Packaging Waste Regulation

The Packaging and Packaging Waste Regulation

The PPWR already entered into force on 11 February 2025 but generally only applies since 12 August 2026, although several requirements, such as certain recyclability, recycled-content, reuse and packaging-ban provisions, will apply at later dates.

The Regulation covers the entire packaging life cycle, from product design and manufacturing to distribution, use and waste management. It applies broadly to packaging placed on the EU market, whether empty or filled, made from any material, manufactured within the EU or imported from a third country

Among other things, the PPWR introduces:

• packaging-waste reduction targets of 5% by 2030, 10% by 2035 and 15% by 2040, compared with 2018 levels;

• a requirement for all packaging to be recyclable in an economically viable manner by 2030;

• reuse targets for certain transport, e-commerce and beverage packaging;

• restrictions on certain single-use packaging formats from 1 January 2030;

• a maximum 50% empty-space ratio for grouped, transport and e-commerce packaging;

• restrictions on PFAS in food-contact packaging;

• mandatory deposit-return systems for certain plastic bottles and beverage cans; and

• harmonised labelling and strengthened extended producer responsibility obligations.

When can packaging labels and sustainability claims be misleading?

Labels, marks, symbols and inscriptions must not mislead consumers about matters such as recyclability, recycled content, reusability, compostability, bio-based content, hazardous substances or waste-management options. A claim may be misleading where it causes consumers to make a decision they would not otherwise have made.

This is linked to the notion of misleading claim included in the Directive (EU) 2024/82521‘Empowering Consumers for the Green Transition’

When can packaging labels and sustainability claims be misleading?

Not necessarily. Where a manufacturer claims that packaging contains a particular percentage of recycled material, the recycled content must exceed the applicable statutory minimum target. Those targets are calculated as an annual average for each manufacturing plant, not simply by reference to an individual packaging unit. The Commission is expected to establish the calculation and verification methodology by 31 December 2026 and to develop a voluntary recycled-content label.

*Source: European Commission: Directorate-General for Environment, Packaging and Packaging Waste Regulation (PPWR) – Frequently asked questions, Publications Office of the European Union, 2026

The PPWR is not only about redesigning packaging. Businesses must also review the environmental information communicated on packaging. Product design, compliance documentation and marketing claims will need to align.