PPWR: the EU Packaging Regulation (EU) 2025/40

Hugues Orgitelloupdated 7 Oct 202618 min read

Every physical product shipped into the European Union arrives in packaging: a box, an insert, a bag, void fill, a pallet of stretch film. Since 12 August 2026 all of it is governed by Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), which replaced Directive 94/62/EC. Several duties applied on day one (a technical file and an EU declaration of conformity for packaging, the heavy-metal limit, PFAS limits for food-contact packaging, name and address on the packaging, EPR registration), while the design rules arrive on dates written into each article, mostly 1 January 2030 or later. This guide sets out who is obligated, every dated obligation with its article number, the figures the text actually contains, the Commission acts adopted or still missing as of 7 October 2026, and the common misreadings.

From a directive to a regulation

Directive 94/62/EC was transposed into 27 national laws. The PPWR is a regulation that, under Article 71, entered into force on 11 February 2025 and applies from 12 August 2026. Article 4(2) bars member states from prohibiting, restricting or impeding packaging that complies with the sustainability, labelling and information requirements of Articles 5 to 12, and Article 4(3) lets them keep extra national requirements only if those do not conflict with the regulation and do not block compliant packaging.

Article 70(1) repealed Directive 94/62/EC with effect from 12 August 2026, with four exceptions that keep parts of it running:

Provision of 94/62/EC kept alive	Until	Article 70(1) point
Article 8(2) (marking)	30 months after the labelling implementing act under Article 12(6) enters into force	(a)
Article 9(1) and (2), for the essential requirement in Annex II point 1, first indent (minimisation)	31 December 2029	(b)
Article 5(2) and (3), Article 6(1)(d) and (e), Article 6a	31 December 2028	(c)
Article 12(3a) to (3c) and (4) (reporting)	31 December 2028 (data transmission to the Commission: 31 December 2029)	(d)

Article 70(2) repeals Decision 97/129/EC, the material identification numbering system, from 12 August 2028.

The PPWR sits beside the rest of the EU product-environment stack: the ESPR ecodesign regulation, the WEEE electronics-waste directive and the EU Battery Regulation.

Scope and the two roles that matter

Article 2(1) applies the regulation to all packaging, regardless of material, and to all packaging waste from industry, retail, offices, services or households. The PPWR does not use "primary, secondary, tertiary"; it defines three functional categories in Article 3(1):

PPWR category	Article 3(1)	Electronics example
Sales packaging	point (5): a sales unit of product and packaging for the end user at the point of sale	The retail box, the bag and insert inside it
Grouped packaging	point (6): groups a number of sales units	A carton holding several retail boxes
Transport packaging	point (7): facilitates handling and transport, excluding road, rail, ship and air containers	Shipping carton, pallet, stretch film, straps
E-commerce packaging	point (8): transport packaging used to deliver products sold online or at a distance to the end user	The mailer box sent to a web-shop customer

Two roles carry the obligations, and the Commission guidance of 10 June 2026 stresses that they are defined for different purposes:

• Manufacturer (Article 3(1)(13)): whoever manufactures the packaging or the packaged product, or has it designed or manufactured under its own name or trademark. The guidance says there is only one manufacturer in a supply chain, and for sales and grouped packaging it is normally the filler, often the brand owner. Where the brand owner is a micro-enterprise and its packaging supplier is in the same member state, the supplier is the manufacturer (point (13)(b)). The manufacturer answers for Articles 5 to 12.
• Producer (Article 3(1)(15)): the manufacturer, importer or distributor that first makes the packaging or packaged product available on a member state territory, or sells directly to end users in another member state, or unpacks packaged products without being an end user. The producer carries EPR, country by country.

Importers (Article 18), distributors (Article 19) and fulfilment service providers (Article 20) have their own duties, and Article 21 turns an importer or distributor that sells packaging under its own name or modifies it into a manufacturer.

What has applied since 12 August 2026

These obligations had no later date attached, so they applied from the general application date:

• Conformity assessment and declaration. Article 15(2) requires the manufacturer to carry out the Annex VII procedure (Module A, internal production control), draw up the technical documentation and an EU declaration of conformity (Article 39, model in Annex VIII). Article 39(3) allows a single declaration covering every Union act that requires one for the packaging or the packaged product. Documentation is kept 5 years for single-use packaging and 10 years for reusable packaging (Article 15(3)). The Commission guidance adds that no conformity assessment for recyclability is needed until the Article 6(4) delegated act enters into force; until Article 6(2)(a) applies, recyclability is judged against the old directive and EN 13430:2004.
• Identification and contact details. The manufacturer must give the packaging a type, batch or serial number or other identifying element (Article 15(5)) and indicate its name, trademark and postal address on the packaging or through a QR code or other data carrier (Article 15(6)). Importers must add their own name and address (Article 18(3)).
• Heavy metals. The sum of lead, cadmium, mercury and hexavalent chromium in packaging or any packaging component must not exceed 100 mg/kg (Article 5(4)).
• PFAS in food-contact packaging (Article 5(5)): limits of 25 ppb for any single PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymeric PFAS. The guidance confirms there is no stock exhaustion period: food-contact packaging placed on the market after 12 August 2026 must comply, while packaging placed before that date may stay on the market.
• Supplier information. Article 16 obliges suppliers of packaging and packaging materials to give the manufacturer everything needed to demonstrate conformity.
• Environmental claims. Article 14 allows claims about properties the PPWR regulates only where they exceed the legal minimum and state whether they cover the unit, part of it, or all packaging the operator places on the market.
• EPR. Articles 44 and 45 (below).

Dated obligations, article by article

Many dates are "X or N months after the Commission act enters into force, whichever is the latest". The table gives the date written in the article and the condition that can push it back; a late Commission act can only delay the obligation, never bring it forward.

Obligation	Article	Applies from	Can slip if
Heavy metals 100 mg/kg, PFAS limits for food-contact packaging, manufacturer and importer duties	5(4), 5(5), 15, 18	12 August 2026	No
Empty space in sales packaging reduced to the minimum necessary	24(4)	12 February 2028	No
Harmonised material-composition (sorting) label	12(1)	12 August 2028	Implementing acts under 12(6) or 12(7) enter into force after 12 August 2026 (24 months)
Recycled-content label, if a recycled-content claim is made	12(4)	12 August 2028	Implementing act under 12(6) late (24 months)
Reusable-packaging label plus QR code or data carrier	12(2)	12 February 2029	Implementing act under 12(6) late (30 months)
Recycled content calculated with the EU methodology	7(11)	1 January 2029	Implementing act under 7(8) late (24 months)
Minimisation: weight and volume to the minimum, Annex IV criteria	10(1)	1 January 2030	No
Design for recycling, grades A, B or C required	6(2)(a), 6(3)	1 January 2030	Delegated acts under 6(4) late (24 months)
Plastic recycled content, first step	7(1)	1 January 2030	Implementing act under 7(8) late (3 years)
Empty-space ratio of 50 % maximum in grouped, transport and e-commerce packaging	24(1)	1 January 2030	Implementing act under 24(2) late (3 years)
Banned formats listed in Annex V	25(1)	1 January 2030	No
Reuse targets	29	1 January 2030	No
Collected separately, sorted and recycled at scale	6(2)(b)	1 January 2035	Implementing acts under 6(5) late (5 years)
Only grades A or B allowed	6(3)	1 January 2038	No
Plastic recycled content, second step	7(2)	1 January 2040	No

The figures the text contains

Recyclability grades (Annex II, Table 3)

Recyclability is assessed per packaging unit against design-for-recycling criteria and expressed as a grade: A at 95 % or more, B at 80 % or more, C at 70 % or more. Annex II says a unit below 70 % is technically non-recyclable and its placing on the market is restricted. The design-for-recycling criteria themselves do not yet exist: Article 6(4) gives the Commission until 1 January 2028 to adopt them by delegated act, based on the parameters in Annex II Table 4 (additives, labels, sleeves, closures, adhesives and others, with separability and sorting efficiency). Under Article 6(9), integrated components are assessed with the unit and separate components are assessed separately, and no component may hinder recycling of the main body. Article 6(11) exempts some packaging, such as packaging for transport of dangerous goods under Directive 2008/68/EC.

Plastic recycled content (Article 7)

Minimum share of post-consumer recycled plastic in any plastic part of packaging, as an average per manufacturing plant and year:

Plastic packaging type	From 1 January 2030 (or later, Article 7(1))	From 1 January 2040 (Article 7(2))
Contact-sensitive, PET as major component (except single-use beverage bottles)	30 %	50 %
Contact-sensitive, other plastics (except single-use beverage bottles)	10 %	25 %
Single-use plastic beverage bottles	30 %	65 %
All other plastic packaging	35 %	65 %

Most electronics packaging (bags, trays, clamshells, foam) falls into "all other plastic packaging". Article 7(5)(b) exempts any plastic part representing less than 5 % of the total weight of the packaging unit, and Article 7(4)(e) exempts compostable plastic packaging. The calculation and verification methodology is due by implementing act by 31 December 2026 (Article 7(8)). Article 7(13) lets the Commission lower the percentages by delegated act in exceptional cases where specific recycled plastics are unavailable or excessively priced.

Minimisation and empty space (Articles 10 and 24)

From 1 January 2030, the manufacturer or importer must design packaging so that its weight and volume are reduced to the minimum necessary for functionality, and may not place on the market packaging that fails the Annex IV performance criteria or that only increases perceived volume (double walls, false bottoms, unnecessary layers). The guidance notes that marketing and consumer acceptance are no longer accepted as reasons for extra weight or volume, and that EN 13428:2004 can serve as guidance until an updated harmonised standard is available; Article 10(3) gives the Commission until 12 February 2027 to request it.

Article 24(1) caps the empty-space ratio at 50 % for economic operators who fill grouped, transport or e-commerce packaging. Article 24(3) defines empty space as the total volume of that outer packaging minus the volume of the sales packaging inside, and counts paper cuttings, air cushions, bubble wrap, foam fillers, wood wool and polystyrene chips as empty space. The calculation methodology is due by implementing act by 12 February 2028. Two points that matter for electronics shippers:

• Sales packaging used as e-commerce packaging (a retail box shipped as is) is exempt from the 50 % cap but must still meet Article 10 (Article 24(5)).
• Sales packaging itself has no numeric cap: from 12 February 2028 its empty space must be reduced to the minimum necessary (Article 24(4)). Article 24(6) asks the Commission to assess, by 12 February 2032, ratios for sales packaging, naming electronic products among the candidates.

Reuse targets (Article 29)

From 1 January 2030, economic operators that use transport packaging (or sales packaging used for transport) within the Union, in the form of pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums, canisters, pallet wrappings or straps, must ensure that at least 40 % of it is reusable within a re-use system, and endeavour to reach 70 % from 1 January 2040. Transport between their own sites or linked or partner enterprises, and deliveries to another economic operator in the same member state, must be 100 % reusable (Articles 29(2) and (3)). Grouped packaging in the form of boxes (excluding cardboard) carries a 10 % target from 2030 (Article 29(5)).

The exemptions decide most electronics cases:

• Cardboard boxes are outside Articles 29(1) to (3) (Article 29(4)(d)).
• Transport packaging custom-designed for large-scale machinery, equipment and commodities is exempt (Article 29(4)(b)); the guidance requires the custom design to be documented in the technical documentation.
• Micro-enterprises that made no more than 1 000 kg of packaging available in a member state during the year are exempt for that year (Article 29(13)).
• Delegated Decision (EU) 2026/429 (adopted 25 February 2026, published 6 May 2026) exempts pallet wrappings and straps from the 100 % requirements of Articles 29(2) and (3). They still count toward the 40 % target of Article 29(1).

The guidance places the targets on the user of the transport packaging, meaning the operator that places the product on the Union market in it, and for imports applies them from the first warehouse in the Union onward.

Banned formats (Article 25, Annex V, and Article 67(5))

From 1 January 2030, Article 25 bans the formats listed in Annex V: single-use plastic grouped packaging used to encourage multiple purchases, single-use plastic for fresh fruit and vegetables under 1.5 kg, several single-use plastic formats in the HORECA sector, single-use accommodation toiletry packaging and very lightweight plastic carrier bags. None targets electronics directly. The one that does is elsewhere: Article 67(5) adds "chips of polystyrene and other plastics that are used to protect packed goods during transport and handling" to Part B of the Annex to the Single-Use Plastics Directive (EU) 2019/904, the list whose placing on the market Article 5 of that directive prohibits, and Article 71 makes Article 67(5) apply from 12 February 2029. Plastic loose-fill chips in a shipping carton therefore have an end date.

Labelling

Article 12 fully harmonises packaging labelling; the guidance states that member states may not keep national sorting labels alongside the EU label once Article 12(1) applies.

• Sorting label (Article 12(1)): from 12 August 2028, or 24 months after the implementing acts under Article 12(6) or (7) enter into force if later, packaging must carry a pictogram-based harmonised label on its material composition. Transport packaging and deposit-return packaging are excluded, except e-commerce packaging, which must carry it.
• Reusable packaging (Article 12(2)): from 12 February 2029, or 30 months after the Article 12(6) act, a label saying it is reusable plus a QR code or other open digital data carrier for reuse information and trip counting.
• Recycled-content claims (Article 12(4)): voluntary, but if made from 12 August 2028 (or 24 months after the act) they must follow the harmonised specification.
• EPR symbol (Article 12(9)): packaging in an EPR scheme may be identified as such only through a symbol in a QR code or other digital marking, not a printed EPR logo.
• Misleading marks (Article 12(8)): no label or symbol likely to confuse users about the harmonised requirements.
• Stock: packaging made or imported before a labelling deadline may be made available for 3 years after that deadline (Article 12(12)).
• Placement (Article 12(5)): labels must be visible, legible and hard to erase, and the information must also be available before purchase in online sales.

Status on 7 October 2026. Article 12(6) and Article 12(7), first subparagraph, set 12 August 2026 as the deadline to adopt the label implementing acts. Our search of the Official Journal through EUR-Lex and Cellar found no implementing act under Article 12 published as of 7 October 2026; the only act adopted under the PPWR that we found is Delegated Decision (EU) 2026/429. The Commission guidance also states that it does not intend to prioritise the Article 12(7) act on digital identification of material composition. Because Article 12(1) runs from the later date, the sorting label cannot become mandatory before 24 months after the act enters into force: do not print against draft pictograms.

Extended producer responsibility

Article 45(1) gives producers EPR for the packaging they first make available on a member state territory. In practice:

• Registration in every member state where you are the producer (Article 44(2)), through the competent authority, or by a PRO on your behalf. Article 44(4) bars making packaging available where neither you nor your EPR authorised representative is registered. Registration is granted within twelve weeks of a complete application (Article 44(11)(b)).
• Reporting by 1 June for each preceding calendar year (Article 44(7)); producers below 10 tonnes a year in a member state report a lighter data set (Article 44(8)).
• Authorised representative for EPR (Article 45(3)): a producer selling directly to end users in a member state where it is not established (points (15)(c) and (d)), whether based in another member state or a third country, must appoint one by written mandate in each such member state. Member states may also require it of third-country producers generally. On 10 December 2025 the Commission proposed, in COM(2025) 982, to suspend Article 45(3) until 1 January 2035. As of 7 October 2026 that regulation had not been adopted, so the obligation stands.
• Online platforms must collect the producer registration number and a self-certification before letting the producer sell to consumers in the Union (Article 45(4)), and fulfilment service providers must check the same information (Articles 45(7) and (8)).
• Fee modulation by recyclability grade starts 18 months after the design-for-recycling delegated acts and recycled-at-scale implementing acts enter into force (Article 6(8)); fees may also be modulated by recycled content (Article 7(7)).
• National registers: Article 44(1) gives member states 18 months from the first implementing act on registration format (due by 12 February 2026 under Article 44(14)) to set up their registers. Existing national schemes continue meanwhile.
• Penalties: member states must set rules by 12 February 2027, and breaches of Articles 24 to 29 must include administrative fines (Article 68).

The roles of manufacturer and producer can split: the guidance gives the example of a filled box sold to a company in another member state, where the buyer becomes the producer there. A local subsidiary or distributor can therefore carry the EPR registration and fees in full. See also authorised representatives and importers and the economic operator entry in the glossary.

Commission acts and guidance: status on 7 October 2026

Act	Legal basis and deadline	Status found
Guidance document on the PPWR (C/2026/3084)	Interpretive notice	Published 10 June 2026
Delegated Decision (EU) 2026/429, pallet wrappings and straps	Article 29(18)(a)	Adopted 25 February 2026, OJ 6 May 2026
Registration and reporting format	Article 44(14), by 12 February 2026	Not found in the OJ
Sorting label, reusable label, recycled-content label	Article 12(6), by 12 August 2026	Not found in the OJ
Recycled-content calculation and verification	Article 7(8), by 31 December 2026	Pending
Minimum rotations for reusable packaging	Article 11(2), by 12 February 2027	Pending
Design-for-recycling criteria and grades	Article 6(4), by 1 January 2028	Pending
Empty-space calculation method	Article 24(2), by 12 February 2028	Pending
Suspension of Article 45(3)	COM(2025) 982, procedure 2025/0395(COD)	Proposal, not adopted

The English text of Regulation (EU) 2025/40 has no corrigendum; the corrigenda listed in Cellar between May 2025 and September 2026 concern other language versions, including the French one of 22 May 2025.

Claims the texts contradict

Common claim	What the text says
"Nothing applies until 2030."	Since 12 August 2026 the manufacturer needs Annex VII technical documentation and an EU declaration of conformity (Articles 15, 38, 39), name and address on the packaging (Article 15(6)), the 100 mg/kg heavy-metal limit (Article 5(4)) and, for food-contact packaging, the PFAS limits (Article 5(5)). EPR applies too.
"There is no de minimis: a single-box importer is treated like a large brand."	Several provisions scale: the micro-enterprise rule in Article 3(1)(13)(b) moves the manufacturer role to a domestic supplier, Article 29(13) exempts micro-enterprises under 1 000 kg from reuse targets, and Article 44(8) gives producers under 10 tonnes lighter reporting.
"The PPWR regulates primary, secondary and tertiary packaging."	The categories are sales, grouped, transport and e-commerce packaging (Article 3(1), points (5) to (8)).
"Chapter III sets the obligations of manufacturers, importers and distributors."	Chapter III is labelling (Articles 12 to 14). Operator obligations are in Chapter IV (Articles 15 to 23).
"PFAS limits await implementing acts."	The three limits are in Article 5(5) itself and apply from 12 August 2026.
"Grade C packaging is banned from 2030."	From 2030 (or 24 months after the delegated acts) packaging must reach at least grade C; only from 1 January 2038 must it reach A or B (Article 6(3)).
"The 50 % empty-space cap applies to retail boxes."	Article 24(1) covers grouped, transport and e-commerce packaging. Sales packaging has a qualitative duty from 12 February 2028 (Article 24(4)), and sales packaging shipped as e-commerce packaging is exempt from the 50 % cap (Article 24(5)).
"All shipping boxes must be 40 % reusable from 2030."	Cardboard boxes are excluded from the transport reuse targets (Article 29(4)(d)), and the grouped-packaging target excludes cardboard (Article 29(5)).
"Recycled-content targets apply to all packaging."	Article 7 covers plastic parts only; Article 7(15) merely asks the Commission to review other materials by 12 February 2032.
"The sorting label is mandatory from 12 August 2028."	That is the earliest date; it moves to 24 months after the implementing act if the act enters into force after 12 August 2026 (Article 12(1)).
"The December 2025 omnibus removed the EPR authorised-representative duty for packaging."	COM(2025) 982 only proposes suspending Article 45(3); it was not adopted on 7 October 2026.

What an electronics manufacturer should do now

1. Fix the roles. For each product and country, record who is the PPWR manufacturer (brand owner, normally) and who is the producer (first to make it available in that member state).
2. Build the packaging inventory. Each component, material, weight, plastic parts with their share of the unit weight, recycled content, supplier.
3. Open the technical documentation and declaration. Collect supplier information under Article 16, check the 100 mg/kg heavy-metal sum, draw up the Annex VII documentation and the EU declaration of conformity, and decide whether to combine it with the product declaration under Article 39(3). See the EU declaration of conformity guide.
4. Mark name, address and identification on the packaging or a data carrier (Articles 15(5), 15(6), 18(3)).
5. Register for EPR in every member state where you are the producer, and appoint EPR authorised representatives where Article 45(3) requires them.
6. Plan the 2030 changes: plastic parts at or above 5 % of unit weight against the 35 % recycled-content minimum, e-commerce and transport cartons against the 50 % empty-space ratio, plastic loose-fill chips out by 12 February 2029, and reusable transport packaging for intra-company and same-country B2B flows not shipped in cardboard.
7. Wait for the label act before redesigning artwork.

How the PPWR sits with the rest of EU product law

The PPWR does not replace product-level requirements. A connected sensor still needs CE marking under RED, EMC and LVD, still falls under RoHS and REACH SVHC for its own substances, still triggers WEEE take-back, and, if it contains a cell, the EU Battery Regulation. The PPWR adds a parallel regime for the packaging, with its own declaration of conformity. The ESPR and its Digital Product Passport cover the product; where Union law requires a data carrier for the product, Article 12(5) requires a single data carrier for product and packaging information, with the two kept distinguishable.

See also

• Environmental compliance: what it asks of a product
• Digital Product Passport (DPP) under the ESPR
• California Prop 65 warnings for electronics
• EU declaration of conformity

Working on PPWR packaging compliance for a specific product range for a real product? AESTECHNO can audit your design and certification plan. Get in touch

Sources & references

1. Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), OJ L, 22.1.2025, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202500040
2. Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40 (10 June 2026), EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C_202603084
3. Commission Delegated Decision (EU) 2026/429, pallet wrappings and straps exempted from 100 % reuse requirements, EUR-Lex eur-lex.europa.eu/eli/dec_del/2026/429/oj
4. COM(2025) 982, proposal suspending the EPR authorised-representative rules for batteries and packaging, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025PC0982
5. Directive 94/62/EC on packaging and packaging waste (repealed), EUR-Lex eur-lex.europa.eu/eli/dir/1994/62/oj
6. Packaging and packaging waste, European Commission, European Commission environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
7. Waste Framework Directive, extended producer responsibility, European Commission, European Commission environment.ec.europa.eu/topics/waste-and-recycling/waste-framework-directive_en