PPWR packaging regulation (EU) 2025/40: what changes from 12 August 2026
From 12 August 2026 the PPWR replaces the old packaging directive. What already applies today, who must sign the declaration of conformity and which obligations are coming up to 2040.
From 12 August 2026 Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) applies. It replaces Directive 94/62/EC and is directly applicable throughout the EU. The limits on PFAS and heavy metals, technical documentation and the EU declaration of conformity apply straight away to every package placed on the market. Recyclability, minimum recycled content, bans on certain single-use formats and reuse targets, on the other hand, arrive from 2030.
What the PPWR is
The PPWR (Packaging and Packaging Waste Regulation) is Regulation (EU) 2025/40 of 19 December 2024, published in the Official Journal of the EU on 22 January 2025 and in force since 11 February 2025. It applies from 12 August 2026, the date from which Directive 94/62/EC is repealed, subject to certain transitional provisions.
The difference from the past is substantial: the directive had to be transposed by each Member State with its own rules, whereas the regulation is identical and directly applicable in all countries. The aim is twofold: to harmonise the packaging market and to reduce waste, applying the principles of the circular economy and ecodesign.
The regulation covers all packaging placed on the EU market, empty or filled, single-use or reusable, of any material, and involves the entire supply chain: packaging producers, those who fill packaging under their own brand, importers, distributors, e-commerce and food service operators.
What changes from 12 August 2026
Many obligations have later dates, but some already apply to packaging placed on the market from this date:
- PFAS in food packaging: food contact packaging may not contain PFAS above 25 ppb for any single substance measured by targeted analysis, 250 ppb for the sum of PFAS measured by targeted analysis and 50 ppm for total PFAS, including polymeric PFAS;
- heavy metals: the sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg, as already required by the old directive;
- conformity assessment: before placing packaging on the market, the manufacturer draws up the technical documentation and the EU declaration of conformity;
- identification: a type, batch or serial number and the manufacturer’s contact details must appear on the packaging, or via a QR code or accompanying document;
- new roles and responsibilities: importers, distributors and fulfilment service providers have their own verification obligations, and producers must comply with extended producer responsibility in every Member State where they sell.
What counts is the date on which the individual packaging unit is placed on the market, not the production date. The regulation also prohibits labels, marks or symbols that could mislead consumers about the sustainability characteristics of packaging, a topic linked to the new anti-greenwashing rules in force since 27 September 2026.
Declaration of conformity and technical documentation
Under the PPWR, the manufacturer is not only whoever physically produces the packaging: it is also whoever has packaging or packaged products designed or manufactured under their own name or trademark. A food company selling under its own brand is therefore a manufacturer even if it buys its trays from a supplier. The exception is a micro-enterprise that buys packaging from a supplier established in the EU: in that case the supplier is the manufacturer for the purposes of the conformity obligations.
The technical documentation, set out in Annex VII, describes the packaging and its use and gathers the evidence of conformity with the applicable requirements: PFAS and heavy metal analyses, material data and, as they come into force, evidence on recyclability, recycled content and minimisation. The EU declaration of conformity follows the model in Annex VIII and must be kept up to date and retained together with the documentation for five years for single-use packaging and ten years for reusable packaging.
In practice the longest task is gathering reliable information from suppliers of materials and semi-finished products. CONAI, the Italian packaging consortium, has published an information note with the structure, content and a template of the declaration, as well as a handbook on packaging design requirements.
The timeline of upcoming obligations
The PPWR comes into force in stages. Some dates are “moving”: they apply from the date indicated or, if later, a certain time after the Commission adopts the implementing acts.
| Date | Obligation | Who it concerns |
|---|---|---|
| 12 August 2026 | General application: limits on PFAS and heavy metals, technical documentation, EU declaration of conformity | Manufacturers, importers, distributors |
| 12 February 2027 | Option for customers to bring their own container for takeaway drinks and food, at no extra cost | Bars, restaurants, catering with takeaway |
| 12 February 2028 | Offering a reusable packaging alternative for takeaway; minimising empty space in sales packaging | Takeaway food service (excluding micro-enterprises); those who fill packaging |
| 12 August 2028 | Harmonised material label to make separate collection easier | All packaging |
| 1 January 2029 | Separate collection of at least 90% of single-use plastic bottles and cans up to 3 litres, normally through deposit return schemes | Member States, beverage producers |
| 1 January 2030 | Recyclable packaging (grades A, B or C), minimum recycled content in plastic, minimised weight and volume, maximum empty space of 50%, bans on certain single-use formats, first reuse targets | Manufacturers, importers, retail, logistics, e-commerce |
| 2035-2040 | Recyclability “at scale” from 2035, grades A or B only from 2038, higher recycled content from 2040 | Manufacturers and importers |
The 2030 targets in detail
- recycled content in plastic parts: 30% for contact-sensitive PET packaging, 10% for other contact-sensitive plastic packaging, 30% for single-use plastic beverage bottles, 35% for other plastic packaging; from 2040 the thresholds rise to 50%, 25%, 65% and 65%;
- banned single-use formats (Annex V): among others, plastic packaging for less than 1.5 kg of fresh fruit and vegetables, single-portion condiments and sauces in food service, single-use containers for on-site consumption and very lightweight plastic carrier bags;
- reuse: at least 40% of transport packaging (pallets, crates, containers) in reuse systems, with exceptions such as cardboard boxes, and at least 10% of beverages sold by the final distributor in reusable packaging, with exclusions such as milk, wine and spirits.
Member States must also reduce packaging waste per capita by 5% by 2030, 10% by 2035 and 15% by 2040, compared with 2018.
What is happening in Italy: CONAI, penalties and simplifications
Being a regulation, the PPWR does not need transposition. National rules are needed, however, for competent authorities, enforcement and penalties: as of October 2026 the Italian penalty framework is still being defined. This does not suspend the European obligations, which apply in any case from 12 August 2026.
For Italian companies the CONAI system for extended producer responsibility remains central; the regulation provides for it in all Member States through national producer registers.
In December 2025 the Commission presented an environmental simplification “Omnibus” package which proposes, among other things, suspending the obligation to appoint an authorised representative for extended producer responsibility in other Member States where a company sells directly. As of October 2026 the proposal is still being examined by the European Parliament and the Council: until it is approved, the obligation remains.
How to prepare: a practical checklist
- Map your packaging: types, formats, materials, weights, suppliers and sales markets, distinguishing between primary, secondary and transport packaging.
- Clarify your role for each package: manufacturer, importer, distributor or producer for extended producer responsibility purposes.
- Ask your suppliers for declarations and analyses on PFAS and heavy metals and for the material information you need for the technical documentation.
- Prepare the EU declaration of conformity and an orderly archive, with the five- and ten-year retention periods.
- Check the recyclability of your current packaging and plan changes for 2030: materials, recycled content, weight, empty space.
- Review labels and claims on packaging, removing environmental symbols or wording that could be misleading.
Packaging data is useful beyond compliance too: weights by material and recycled content share are typical circular economy indicators and feed the sustainability report under the VSME standard. If you are designing new products, the PPWR should be read together with the ESPR ecodesign regulation.
From 12 August 2026 Regulation (EU) 2025/40 applies directly throughout the EU: limits on PFAS and heavy metals, technical documentation and the EU declaration of conformity are already mandatory. Most of the design requirements arrive from 2030. Map your packaging and clarify your role now, because supplier data takes time.
