Regulation (EU) 2025/40 published in the Official Journal of the EU.
PPWR
EU Packaging and Packaging Waste Regulation (PPWR)
The EU Packaging and Packaging Waste Regulation applies to every company placing packaged products on the EU market. The first obligations take effect on August 12, 2026.
Next deadline
12 August 2026: PFAS limitation in food contact packaging enters force, alongside packaging minimization requirements and mandatory labelling obligations for all new packaging placed on the EU market.
Products being designed and sourced today will be on shelf by August 2026. The PFAS ban is a hard product restriction, not a reporting obligation: food contact packaging containing PFAS above permitted thresholds for non-stick, waterproof and heat-resistant applications will no longer be permitted on the EU market from that date. Packaging decisions made in current procurement cycles must already account for PPWR's substance, labelling and material requirements.
Regulation timeline
What the regulation requires
The EU Packaging and Packaging Waste Regulation (Regulation EU 2025/40) applies to any company that manufactures, imports, or places packaged goods on the EU market, and sets binding requirements across recyclability by design, mandatory recycled content targets, reuse obligations, and substance restrictions. PFAS restrictions in food contact packaging and heavy metal limits will apply from August 12, 2026, with mandatory recyclability grades, recycled content targets, and reuse requirements for beverages and food service packaging taking effect from 2030.
Common PPWR implementation challenges
Recycled content targets require documented evidence at SKU level, not supplier declarations alone
Recycled content targets require documented, verifiable evidence of recycled material percentages at SKU level. Standard procurement and ERP systems were not built to capture, validate, or version this information across a packaging catalog.
PFAS, heavy metals, and substance restrictions require verified product-level data before August 12, 2026
PPWR Art. 5 obligations apply from August 12, 2026 and cover the PFAS ban and heavy metal restrictions in food contact packaging. Substance-level data is required for all affected packaging in scope. Packaging sourced from third parties frequently has no structured substance declaration on file, and collecting it at scale requires a structured supplier engagement process.
PPWR requirements differ by packaging category, material, and use case
Applying the correct recyclability grade, recycled content target, and reuse requirement to each packaging format requires systematic assignment across every SKU. The obligation applies regardless of packaging catalog size and compounds across product lines and national markets.
osapiens HUB for Product Compliance
PPWR compliance from substance data to Declaration of Conformity
The osapiens HUB manages substance data collection, technical documentation, and Declaration of Conformity outputs for PPWR across every SKU in your packaging portfolio.
Assign legally validated PPWR templates to every packaging category by supply chain role.
Packaging categories are assigned to templates via CN code, product category, or tag. The HUB provides legally validated templates mapped to distinct supply chain roles: manufacturers access Art. 5 data request templates covering PFAS and heavy metal obligations from August 2026, while traders and distributors collect the Declarations of Conformity and Annex VII technical documentation directly from supplier responses.
Automatically generate Declaration of Conformity and technical documentation from collected supplier data.
Once substance and material data has been collected and evaluated, the HUB generates the Declaration of Conformity and technical documentation as a ready-to-sign PDF. For substance obligations extending beyond PPWR to REACH or RoHS, SCIP Simplified Notifications can be generated and submitted to the ECHA SCIP database via the Chemicals add-on.
Stay compliant as PPWR obligations expand in 2030 and 2035.
PPWR obligations will expand in terms of scope and stringency in 2030 and again in 2035. Templates and evaluation logic in the osapiens HUB are updated as delegated acts are published and thresholds change, therefore no new implementation is required each time the regulation evolves. The same product data layer supports Digital Product Passport obligations when DPP requirements for PPWR-covered packaging take effect under ESPR.
PPWR GUIDES, WHITEPAPER AND RESOURCES
Frequently asked questions (FAQs)
PPWR applies to any company that places packaged products on the EU market: manufacturers, brand owners, importers, and distributors. The regulation is directly applicable across all 27 member states and covers packaging produced inside and outside the EU. There is no exemption for company size, though certain packaging categories and use cases carry lighter or deferred obligations.
PPWR Art. 5 obligations enter into force on August 12, 2026 and cover two categories in food contact packaging. First, the PFAS ban prohibits packaging containing per- and polyfluoroalkyl substances above permitted thresholds; PFAS have been widely used for non-stick, waterproof, and heat-resistant properties. Second, restrictions on heavy metals in food contact packaging apply from the same date. Both restrictions apply regardless of where the packaging is manufactured.
Mandatory recycled content requirements apply to plastic packaging from January 1, 2030. Single-use plastic bottles carry a specific target of 30% by 2030, rising to 65% by 2040. Evidence of compliance must be documented at SKU level. Supplier declarations are not sufficient without underlying, verifiable data.
The 1994 Directive required member states to transpose its requirements into national law, producing 27 different frameworks with inconsistent definitions and enforcement. PPWR replaces this with a single directly applicable regulation, whereby the same text is enforced in the same way in every member state. It also brings additional obligations that did not exist under the previous directive: mandatory recycled content targets, reuse requirements, packaging minimization rules, and Deposit Return Systems.
Yes. PPWR sets distinct obligations by supply chain role. Manufacturers bear the primary obligation; they must prepare technical documentation, demonstrate conformity, and issue a Declaration of Conformity. Traders and distributors who place packaging on the EU market must hold the DoC and Annex VII technical documentation and make them available to authorities on request. The osapiens HUB provides separate template tracks for each role.
PPWR and ESPR are complementary EU frameworks. The Commission has confirmed that ESPR will not regulate packaging as a product group, since PPWR already does. However, for products that require a Digital Product Passport under ESPR, the data carrier may be placed on the packaging. Material composition, recycled content, substance declarations, and recyclability data collected for PPWR compliance can be reused for those DPP obligations, making early investment in structured data management strategically valuable.
