On January 22, 2025, the European Union officially issued a new packaging regulation--(EU) 2025/40 on Packaging and Packaging Waste (PPWR). The regulation entered into force on February 11, 2025, and will apply in full from August 12, 2026, replacing the long-standing Packaging and Packaging Waste Directive 94/62/EC.
The new rules are widely regarded by leading institutions and industry experts as among the strictest packaging regulations in the world. Owing to their unprecedented scope and depth, the PPWR is seen as a game-changer that will fundamentally reshape product packaging.
Key Dates
• 50 ppm fluorine triggers proof
2029-02: Reusability labels required
Implementation of calculation methods
• Min recycled content
• Single-use plastic bans
• Reuse targets: 40%/10%/10%
What are the main points of new PPWR regulation？
| Requirement Category | Details |
|---|---|
| Recyclability Grades | By 2030 packaging not allowed unless within grades A, B or C (≥70%); by 2038 only A or B (≥80%) |
| Minimum Recycled Content (Plastics) | Targets for plastic packaging (e.g., beverage bottles, other plastics), increasing by 2040 |
| Recycled at Scale | Waste is collected, sorted and recycled in installed infrastructure using established processes; annual quantity ≥30% (wood), ≥55% (others) |
| Reuse & Systems | Sectoral reuse targets and systems for reusable packaging (transport, grouped, beverages, etc.) |
| Single-use Bans | Annex V lists prohibited single-use packaging formats in specific uses (e.g., dine-in cups/boxes, <1.5 kg fresh produce, hotel toiletries) |
| Minimisation & Over-packaging | Rules on packaging minimisation and void-space limits for e-commerce/transport/combined packs |
| Harmonised Labelling & Information | Material identification, reusable labelling, DRS labelling, and digital info on substances of concern |
| PFAS in Food Contact Packaging | From 12 Aug 2026--25 ppb (any PFAS), 250 ppb (sum), 50 ppm (PFAS incl. polymers); if total fluorine >50 mg/kg, provide proof |
| Compliance & Market Access | "Recyclability is a market access condition"; demonstrate compliance in technical documentation set out in Annex VII |
Key Points of Attention
♻️ What are the laws and regulations on food packaging?
Time Line
Market access & technical documentation
- "Recyclability is a market access condition," to be demonstrated in technical documentation set out in Annex VII.
Minimum recycled content for plastics (2030/2040)
- Single-use plastic beverage bottles: 30% / 65%
- Other plastic packaging: 35% / 65%
- Contact-sensitive PET (except SUP bottles): 30% / 50%
- Contact-sensitive plastics other than PET (except SUP bottles): 10% / 25%
- Targets are calculated as an average per manufacturing plant and year; the methodology will be adopted by 31 December 2026 with compliance by 1 January 2029 or two years after adoption.
PFAS (food-contact packaging only)
- From 12 August 2026: placing on the market is banned if PFAS are present ≥25 ppb (any PFAS), ≥250 ppb (sum), or ≥50 ppm (including polymers).
- If total fluorine > 50 mg/kg, provide proof of the quantity of fluorine (PFAS or non-PFAS based).
Minimisation & over-packaging
- Design must avoid false bottoms, double walls, unnecessary layers.
- A maximum 50% empty-space ratio applies to grouped, transport or e-commerce packaging (methodology to specify measurement).
Reuse & single-use restrictions
- Sectoral reuse targets and systems for reusable packaging are introduced.
- Annex V lists prohibited single-use packaging formats in specific uses (e.g., dine-in cups/boxes, fresh produce <1.5 kg, hotel toiletries).
Labelling & information
- Harmonised labelling/marking for material identification, reusable/DRS; digital information for substances of concern.
♻️ What is the minimum recycled content in plastic packaging for PPWR？
Targets for 2030 / 2040 (plastics)
| Category | 2030 | 2040 | Description |
|---|---|---|---|
| Single-use plastic beverage bottles (SUP) | 30% | 65% | Dedicated target for beverage bottles |
| Other plastic packaging (non-contact sensitive) | 35% | 65% | Other plastic packaging except contact-sensitive and SUP |
| Contact-sensitive PET (excluding SUP bottles) | 30% | 50% | PET packaging in direct contact with sensitive products |
| Contact-sensitive non-PET (excluding SUP bottles) | 10% | 25% | Other plastic materials in direct contact with sensitive products |
♻️ What about ERP?
1.What is ERP?
Producers bear financial and operational responsibility for the collection, sorting and recycling of packaging, working in tandem with Deposit Return Schemes (DRS) to drive prevention and reduction.
2. Cost coverage & use of funds
- EPR fees shall cover:
- Labelling costs of waste/collection receptacles;
- Compositional surveys of mixed municipal waste;
- Possibility for Member States to include litter clean-up costs.
- EPR and DRS must allocate a minimum share of their budget to reduction and prevention actions.
3. Implementation timeline (EPR-related)
- - By 1 January 2028: delegated acts on D4R / recyclability assessment / EPR fee modulation adopted.
- - +18 months after delegated acts’ EiF: fee modulation by recyclability grade applies.
- - +18 months after implementing acts’ EiF: producer registers operational.
- - 1 June each year: annual Annex IX reporting.
♻️ What are the PFAS limits for PPWR?
Effective Date
From 12 August 2026, food-contact packaging may not be placed on the market if any of the following limits is met or exceeded.
| Assessment Item | Limit | Basis |
|---|---|---|
| Any single PFAS | ≥ 25 ppb |
Concentration of one specific PFAS (ppb = μg/kg) |
| Sum of PFASs | ≥ 250 ppb |
Total concentration of all PFASs (ppb = μg/kg) |
| PFASs (incl. polymers) | ≥ 50 ppm |
Total PFAS content including polymers (ppm = mg/kg) |
⚠️ Trigger (Total Fluorine)
If Total Fluorine > 50 mg/kg (50 ppm), the operator must provide proof of the quantity of fluorine, specifying whether it derives from PFAS or non-PFAS sources, to substantiate compliance with the limits above.
What are the targets for PPWR?
Reuse Targets (from 1 Jan 2030)
Transport Packaging
Economic operators that use transport packaging or sales packaging used for transporting shall ensure that at least 40% of such packaging is reusable within a re-use system.
Grouped Packaging
Economic operators that use grouped packaging shall ensure that at least 10% is reusable within a re-use system.
Beverages
Operators making alcoholic and non-alcoholic beverages available to consumers shall ensure that at least 10% are made available in reusable packaging.
2040 Targets
By 1 Jan 2040, endeavour to reach: 70% (transport), 25% (grouped), 40% (beverages)
Note: Packaging used within/between sites shall be reusable within a re-use system.
Prevention Targets
Packaging Waste Reduction per Capita (compared to 2018)
- 5% reduction by 2030
- 10% reduction by 2035
- 15% reduction by 2040
Each Member State shall reduce the packaging waste generated per capita according to these targets.
Recycling Targets (by 31 Dec 2030)
Overall Target
A minimum of 70% by weight of all packaging waste
Material-specific targets
- Plastic: 55%
- Wood: 30%
- Ferrous metals: 80%
- Aluminium: 60%
- Glass: 75%
- Paper and cardboard: 85%
DRS / Separate Collection (by 1 Jan 2029)
Target
Ensure separate collection of at least 90% per year by weight of:
- Single-use plastic beverage bottles ≤3L
- Single-use metal beverage containers ≤3L
Requirement
Set up deposit and return systems with a deposit charged at the point of sale.
What is the future of packaging?
