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PPWR (EU) 2025/40: Packaging and Packaging Waste Regulation

EU rules on packaging design, labelling, recyclability and conformity, applying from 12 August 2026 in the EU and, in large part, Northern Ireland.

PPWR (EU) 2025/40 Applies from 12 Aug 2026 4 min read

Applies from
12 Aug 2026
In force 11 Feb 2025
Empty space ratio
50% max
Transport and e-commerce, 2030
Recyclability
Grades A to C
From 2030 at the earliest
Full titleRegulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC
PublishedOfficial Journal of the EU, 22 January 2025
Applies from12 August 2026 (Article 71). Many requirements apply later
Where it appliesEU Member States. Most provisions also apply in Northern Ireland under the Windsor Framework. Not England, Scotland or Wales

What it covers

The PPWR is a directly applicable regulation covering packaging from substances, design and labelling to conformity, extended producer responsibility and waste. It replaces the 1994 Packaging Directive.

‘Packaging’ means an item, of any material, intended to be used by an economic operator to contain, protect, handle, deliver or present products to another economic operator or to an end user. Business-to-business packaging is covered.

Who is responsible

RoleDefinition (Article 3)
ManufacturerAny person that manufactures packaging or a packaged product, or has it designed or manufactured under its own name or trade mark
ProducerA manufacturer, importer or distributor that makes packaging or packaged products available for the first time in a Member State, including by distance sales directly to end users in another Member State

Key requirements and dates

Where a fixed date and a period after a delegated or implementing act are both given, the later applies.

RequirementArticleApplies fromSummary
Heavy metals5(4)12 Aug 2026Sum of lead, cadmium, mercury and hexavalent chromium not above 100 mg/kg
Harmonised label12(1)12 Aug 2028 or 24 months after implementing actsPictogram label showing material composition
Packaging minimisation101 Jan 2030 (10(1))Weight and volume reduced to the minimum needed for function (10(1)). Article 10(2), which has no separate date in Article 10, also bars features that only increase perceived volume, such as double walls and false bottoms
Empty space ratio24(1)1 Jan 2030 or 3 years after implementing actsMaximum 50% for grouped, transport and e-commerce packaging. Filling materials count as empty space
Recyclability grades6(3)1 Jan 2030 or 24 months after delegated actsPackaging must be recyclable within grade A, B or C. From 1 Jan 2038, grade A or B only
Recycled content, plastic7(1)1 Jan 2030 or 3 years after implementing act35% for plastic packaging other than contact-sensitive packaging and single-use beverage bottles. 65% from 1 Jan 2040

Conformity, documentation and identification

  • Manufacturers may only place packaging on the market that conforms to Articles 5 to 12 (Article 15). First they carry out the conformity assessment procedure in Article 38, draw up the technical documentation in Annex VII and, where conformity is shown, draw up an EU declaration of conformity (Article 39) to the model in Annex VIII.
  • The technical documentation and declaration are kept for 5 years for single-use packaging and 10 years for reusable packaging.
  • Packaging must bear a type, batch or serial number or other identifier, or the information goes in a document accompanying the packaged product.
  • The manufacturer’s name, registered trade name or trade mark, postal address and, where available, electronic contact go on the packaging or on a QR code or other data carrier.
  • On request, economic operators must identify who supplied them with packaging and to whom they supplied it (Article 22). The supplier information must be available for 5 years (single-use) or 10 years (reusable).

Extended producer responsibility in the EU

Producers have extended producer responsibility for packaging they make available for the first time in a Member State (Article 45). They must register in each Member State where they do so (Article 44).

A producer selling directly to end users in a Member State where it is not established must appoint an authorised representative for extended producer responsibility there by written mandate (Article 45(3)). In December 2025 the Commission proposed suspending this obligation. The Parliament and Council are still examining the proposal.

Northern Ireland and Great Britain

A Commission Notice (C/2025/946, 4 February 2025) states that the Windsor Framework reference to the 1994 Packaging Directive (Annex 2, point 25) is now read as referring to the PPWR. Provisions that do not apply in Northern Ireland include Article 23 (information obligations of packaging waste management operators), Articles 29 to 33 (re-use targets, refill and re-use offer obligations for the take-away sector) and Articles 41 to 55 (waste management, extended producer responsibility, deposit return, recycling targets). The plastic carrier bag provisions do not apply unless the UK in respect of Northern Ireland takes measures under Article 34(1). Some other articles are also excluded.

Requirements on substances, recyclability, labelling, minimisation and conformity therefore apply in Northern Ireland. The PPWR does not apply in England, Scotland or Wales. DAERA states that no decision has been taken on UK-wide alignment.

UK packaging EPR

UK packaging extended producer responsibility is set by the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332). They apply across the UK.

ItemPosition
Obligated producerEstablished in the UK, supplied or imported more than 25 tonnes of packaging in the previous year, and worldwide turnover of £1 million or more
Large producerMore than 50 tonnes and more than £2 million turnover. Registers yearly, reports every 6 months, meets recycling obligations and pays household packaging waste disposal fees

What it means in practice

  • From 12 August 2026, packaging first placed on the EU or Northern Ireland market needs the identification, manufacturer details, documentation and declaration above.
  • Watch for the delegated and implementing acts. They set the actual start dates for labelling, recyclability grades and recycled content.
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