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PPWR – the new packaging regulation will impact most companies; 12 Key takeaways

The Packaging and Packaging Waste Regulation (PPWR) is the newly adopted EU regulation designed to strengthen the rules on packaging sustainability across its entire life-cycle. It supports the EU’s circular economy objectives by harmonising national measures, reducing environmental impact and promoting reuse and recycling. The regulation came into effect in February 2025 upon its publication in the EU’s Official Journal. This paper provides a high-level summary of 12 key takeaways introduced by the PPWR, based on insights compiled by Reloop, to help stakeholders understand the regulation’s main implications.

  1. New Responsibilities for Economic Operators

The new packaging and waste regulation introduces expanded obligations and targets for European economic operators, including packaging manufacturers, suppliers, importers, distributors, and final distributors. These actors must now meet stricter requirements for sustainability and waste management standards, reflecting the EU’s commitment to a circular economy. Economic operators must ensure that packaging complies with sustainability, recyclability, labelling, and waste minimisation requirements. Some of these new responsibilities and stricter suitability and waste management standards include, conformity assessments, technical documentation, and the application of harmonised labelling (such as material composition symbols and digital QR codes).

  1. Waste Prevention Targets

To support long-term waste reduction, the regulation introduces mandatory prevention targets for Member States. Packaging waste must be reduced by 5% by 2030, compared to 2018. To ensure that waste reduction continues, targets increase to 10% by 2035 and 15% by 2040.

  1. Deposit Return System (DRS) for Beverage Containers

In alignment with the Single-Use Plastic Directive (2019/904), the PPWR mandates that Member States implement a Deposit Return System (DRS) for single-use plastic bottles and metal beverage containers, such as beverage cans. These systems must be operational by 2029, and the target is a 90% collection rate for recycling. Member States that reach an 80% collection rate by 2026 may apply for a temporary exemption. However, if a Member State fails to achieve a 90% collection rate over three consecutive years, the exemption will be revoked.

(Article 50)

  1. Mandatory Recyclability of Packaging

By 2030 and 2035, all packaging placed on the EU market must be recyclable according to requirements as defined in the PPWR. The regulation defines recyclability as: the compatibility of packaging with the management and processing of waste by design, based on separate collection, sorting in separate streams, recycling at scale and the use of recycled materials to replace primary raw materials.

(Article 6)

  1. Minimum Recycled Content in Plastic Packaging

The PPWR introduces legally binding targets for (minimum) recycled plastic content in packaging, effective from 2030 and increasing further in 2040. Plastic packaging must include a minimum percentage of recycled content, with exceptions for compostable plastic packaging and packaging where the plastic component is less than 5% of total weight.

Minimum Recycled Content Type20302040
Single Use Plastic Beverage Bottles30%65%
Contact-Sensitive Plastic (PET as major component)30%50%
Contact-Sensitive Plastic (PET not as major component)10%25%
All other Plastic Packaging35%65%

(Article 7)

  1. Prohibition of Substances in packaging

To protect human health and the environment, the PPWR prohibits the use of certain hazardous substances in packaging by 2030. Of particular concern are per- and polyfluoroalkyl substances (PFAS), which are persistent in the environment and linked to serious health risks, including reproductive and developmental harm. Their use in food-contact packaging will be restricted, in line with the EU’s broader Chemicals Strategy for Sustainability.

(Article 5)

  1. Ban on Certain Packaging Formats

To reduce unnecessary packaging waste, the regulation bans the use of several single-use and excessive packaging formats. These restrictions apply particularly to plastics and target sectors such as retail, hospitality, and food service. The following packaging types will be prohibited:

  • Single-use plastic grouped packaging, like collation films and shrink wrap
  • Single-use plastic packaging for unprocessed fruits and vegetables; like nets, bags, trays, containers
  • Single-use plastic packaging; like trays, disposable plates and cups, bags, boxes
  • Single-use plastic packaging for condiments, preserves and beverage containers in the hospitality sector (hotel, restaurant and catering, HORECA), like sachets, tubes, trays, boxes
  • Single-use packaging for cosmetic and toiletries in HORECA and accommodation sectors, like shampoo bottles, hand and body lotion bottles, sachets around bar soap
  • Very lightweight (non-compostable) plastic bags provided for bulk groceries

The European Commission will issue guidance to clarify the scope of these bans, including examples of covered formats and possible exemptions.

(Article 22)

  1. Harmonised Standards for Compostable Packaging

To address any confusion over compostable plastics, the PPWR sets strict conditions under which packaging may be labelled or marketed as compostable. Compostability must be demonstrable through industrial composting standards (such as the EN 13432) and must meet specific timeframes and biodegradation thresholds. Compostable packaging must not contaminate other recycling streams. The European Commission will define technical standards for compostable packaging to ensure consistency and credibility. All compostable packaging must demonstrate biological decomposition under defined conditions, verified through standardised testing procedures.

(Article 9)

  1. Re-use Targets for Economic Operators

The PPWR sets binding re-use targets for several key packaging categories by 2030, with more ambitious targets for 2040. These requirements aim to reduce single-use packaging and promote circular business models. These apply primarily to:

Re-use Targets20302040
Transport packaging, including e-commerce (e.g. pallets, crates) (excluding cardboard and packaging for dangerous goods & large-scale machinery & flexible packaging in direct contact with food)40%70%
Grouped packaging to create a stock-keeping unit (excluding cardboard)10%25%
Alcoholic and non-alcoholic beverage packaging (excluding milk, spirits, and similar perishable liquids)10%40%

Economic operators must ensure that a share of their packaging is reusable, and Member States are encouraged to impose more ambitious targets where appropriate.

An economic operator may be exempt by a Member State if they can prove that their packaging category is recycled at rate of 5 percentage points better than the recycling rates also in the PPWR, which means, equal to or better than:

Material20252030
Plastic55%60%
Wood30%35%
Ferrous metal75%85%
Aluminium55%65%
Glass75%80%
Paper and Cardboard80%90%

In addition, the exempting Member State must be on track to meet prevention targets of 3% by 2028, measured against 2018 levels.

  1. Limits on Unnecessary Packaging

To reduce packaging waste and promote more efficient use of materials, the PPWR introduces a maximum empty space ratio of 50%. This requirement applies to grouped, transport, and e-commerce packaging, meaning that no more than half of the total packaging volume may be unoccupied by product.

  1. Take-away Re-use Obligations

The PPWR introduces new obligations for the take-away sector. Businesses are obligated to:

  • Allow customers to use their own containers for hot or cold beverages or ready-prepared food.
  • Ensure that by 2030, 10% of their products are available in reusable packaging formats.
  1. Continuity of Recycling Targets

The PPWR maintains and strengthens the existing recycling targets set under the previous directive on packaging waste. These targets ensure consistency and a stable regulatory environment while encouraging continued progress toward higher recycling rates.

Material20252030
Plastic50 % 55%
Wood25%30%
Ferrous metal70%80%
Aluminium50%60%
Glass70%75%
Paper and Cardboard75%85%

Conclusion

This comprehensive update to the EU Packaging and Packaging Waste Regulation (PPWR) places significant increased obligations on businesses and Member States. By focusing on recyclability, re-use, reduction of hazardous substances, and consumer participation (via DRS and reusable containers), the regulation drives the EU toward a sustainable and circular packaging economy.

Economic operators must prepare for enhanced responsibilities, while Member States are tasked with achieving clear, ambitious targets for prevention, collection, and recycling. Uniform standards for compostable materials and prohibitions on problematic packaging formats further reinforce the regulatory framework’s emphasis on environmental protection and resource efficiency.

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