The EU’s Packaging and Packaging Waste Regulation: What It Means for Manufacturers and Supply Chains

On February 11, 2025, the Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40 officially entered into force, setting the stage for a significant transformation in how packaging is designed, used, and recycled across the EU. Enforcement begins on August 12, 2026, but businesses need to act now to assess compliance risks and plan for the new requirements.

The PPWR replaces the 1994 Packaging and Packaging Waste Directive (94/62/EC) with a directly applicable regulation, eliminating inconsistencies between Member States and introducing stricter sustainability targets. While the regulation promises environmental benefits, its practical implementation presents challenges for manufacturers, packaging suppliers, and downstream users.

Recyclability and the New Design-for-Recycling (DfR) Framework

At the heart of the PPWR is a recyclability mandate:
By 2030, all packaging must be recyclable based on new Design-for-Recycling (DfR) criteria, which will classify packaging into performance grades. Packaging that falls below 70% recyclability will be subject to higher Extended Producer Responsibility (EPR) fees, making non-compliant packaging financially unviable.

Action Plan: Companies must evaluate their packaging materials now to determine if they will meet the 2030 recyclability threshold. A failure to do so could result in significant cost increases.

Recycled Content: New Targets That Will Reshape the Market

The PPWR sets binding recycled content targets for plastic packaging, ensuring that post-consumer recycled material (PCR) is incorporated into new packaging. The targets increase progressively between 2030 and 2040:

By 2030:

• 30% recycled content for PET-based contact-sensitive packaging
• 10% recycled content for non-PET contact-sensitive plastic packaging
• 30% recycled content for single-use plastic beverage bottles
• 35% recycled content for all other plastic packaging

By 2040:

• 50% recycled content for PET-based contact-sensitive packaging
• 25% recycled content for non-PET contact-sensitive packaging
• 65% recycled content for single-use plastic beverage bottles
• 65% recycled content for all other plastic packaging

Action Plan: The availability of high-quality recycled plastics will be critical to meeting these targets. Supply chain readiness is essential—manufacturers should secure reliable sources of PCR material now to avoid last-minute compliance challenges.

Restrictions on Single-Use Plastic Packaging

One of the most controversial aspects of the PPWR is its ban on specific single-use plastic packaging by 2030. The regulation targets packaging that contributes heavily to waste, including:

Banned by 2030:

• Pre-packed fruit and vegetable packaging (for items under 1.5 kg)
• Food and beverage packaging used for on-site consumption in hotels, restaurants, and bars
• Individual condiment packets (e.g., sugar, sauces, and milk creamers)
• Very lightweight plastic bags (often used in grocery stores)
• Small single-use toiletry and cosmetic packaging in the hospitality sector

Action Plan: Companies that rely on these packaging formats must begin transitioning to reusable or alternative materials immediately to ensure continuity in operations by 2030.

PFAS Restrictions in Food-Contact Packaging

The PPWR includes strict limits on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging. Packaging materials exceeding the following PFAS thresholds will be banned 18 months after the regulation enters into force (by August 2026):

• 25 parts per billion (ppb) for any single non-polymeric PFAS
• 250 ppb for a group of PFAS detected through targeted analysis
• 50 parts per million (ppm) for all PFAS, including polymeric PFAS

While this aligns with growing global restrictions on PFAS, the industry remains concerned about testing standards, enforcement mechanisms, and viable alternatives.

Action Plan: Companies must identify and eliminate PFAS-containing materials in their packaging supply chain before the August 2026 deadline.

New Reuse and Refill Targets for Takeaway and Retail

The PPWR introduces mandatory reuse and refill targets to reduce reliance on single-use packaging:

By 2030:

• 10% of beverages must be available in reusable packaging.
• Takeaway businesses must allow customers to bring their own containers without an extra charge.
• Retailers larger than 400 m² must allocate 10% of their floor space to refill stations.

By 2040:

• 40% of beverage packaging must be reusable.

While these targets are less aggressive than earlier drafts, they still require significant changes in packaging supply chains.

Action Plan: Businesses that operate in food service, retail, and beverage distribution need to assess infrastructure investments required for reuse and refill systems.

Challenges Ahead: Implementation, Compliance, and Industry Response

Despite its ambitious goals, the PPWR has been one of the most lobbied regulations in EU history, with concerns that corporate interests have diluted the final version. However, compliance will still pose major challenges, including:

Compliance Complexity: Meeting recyclability, recycled content, and reuse targets requires supply chain restructuring and significant investments.
Technology Readiness: The industry needs scalable solutions to ensure cost-effective recycled plastic supply and viable alternatives to banned materials.
Harmonization Challenges: While the PPWR replaces the Directive, differences in national implementation may still create barriers for companies operating across multiple Member States.

Action Plan: Businesses should stay engaged with EU regulatory updates, participate in stakeholder consultations, and begin implementing sustainability-focused supply chain strategies now.

Final Thoughts: Time to Act

With August 2026 as the compliance deadline, the window for action is closing fast. Companies across the packaging, retail, food service, and consumer goods industries must assess their risk exposure, rethink their packaging strategies, and collaborate with supply chain partners to ensure compliance.

The European Commission will continue to issue Delegated and Implementing Acts, refining certain aspects of the PPWR. Businesses should monitor these developments closely to avoid compliance pitfalls.

Action Items for Businesses:

• Conduct a packaging compliance audit based on recyclability and material composition.
• Establish partnerships with recycled material suppliers to secure post-consumer plastic.
• Identify alternative materials to replace PFAS-containing and single-use plastic packaging.
• Prepare for labeling updates to meet new environmental transparency requirements.
• Engage with EU regulators and industry groups to stay ahead of compliance changes.

The PPWR represents a significant shift in packaging sustainability, but companies that act proactively will avoid disruption and gain a competitive advantage in the evolving EU market.