| Full title | Regulation (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 |
| Published | Official Journal of the EU, 22 January 2025 |
| Applies from | 12 August 2026 (Article 71). Many requirements apply later |
| Where it applies | EU 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
| Role | Definition (Article 3) |
|---|---|
| Manufacturer | Any person that manufactures packaging or a packaged product, or has it designed or manufactured under its own name or trade mark |
| Producer | A 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.
| Requirement | Article | Applies from | Summary |
|---|---|---|---|
| Heavy metals | 5(4) | 12 Aug 2026 | Sum of lead, cadmium, mercury and hexavalent chromium not above 100 mg/kg |
| Harmonised label | 12(1) | 12 Aug 2028 or 24 months after implementing acts | Pictogram label showing material composition |
| Packaging minimisation | 10 | 1 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 ratio | 24(1) | 1 Jan 2030 or 3 years after implementing acts | Maximum 50% for grouped, transport and e-commerce packaging. Filling materials count as empty space |
| Recyclability grades | 6(3) | 1 Jan 2030 or 24 months after delegated acts | Packaging must be recyclable within grade A, B or C. From 1 Jan 2038, grade A or B only |
| Recycled content, plastic | 7(1) | 1 Jan 2030 or 3 years after implementing act | 35% 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.
| Item | Position |
|---|---|
| Obligated producer | Established 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 producer | More 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.