PPWR stands for the European Union Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It establishes requirements intended to improve packaging sustainability, reduce packaging waste, increase recycling, and support the circular economy across the EU.

PPWR entered into force on February 11, 2025 and became generally applicable on August 12, 2026. However, many requirements will be phased in over time, and additional Delegated and Implementing Acts and guidance will define certain methodologies and compliance requirements.

PPWR applies broadly to packaging placed on the EU market. Companies that manufacture, import, distribute, or place packaging or packaged products on the EU market may have obligations depending on their role in the packaging supply chain, regardless of where the company is headquartered.

Today, organizations should focus on collecting data needed to support current applicable PPWR requirements and prepare for upcoming obligations. Depending on the packaging, this may include packaging material and composition information, heavy metal compliance data, and supplier documentation needed to support conformity. Additional data needs will continue to develop as PPWR methodologies and implementing measures are finalized.

Under Article 5(4), the combined total concentration of lead, cadmium, mercury, and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg (100 ppm) by weight.

As of August 12, 2026, PPWR restricts PFAS in food-contact packaging. Food-contact packaging may not be placed on the EU market if PFAS concentrations exceed the limits specified in Article 5(5).

Yes. Article 6 establishes the general requirement that packaging placed on the EU market must be recyclable. However, the detailed Design for Recycling criteria and assessment methodologies are being established through additional Delegated Acts and will apply according to the timelines established under PPWR.

During the transition to the future PPWR Design for Recycling criteria, European Commission guidance points manufacturers to the existing requirements under the former Packaging and Packaging Waste Directive and related harmonized standards, including EN 13430:2004. The PPWR conformity assessment requirements for recyclability will apply once the applicable Article 6(4) Delegated Act enters into force.

A Declaration of Conformity is a formal document in which the manufacturer declares that the packaging complies with applicable PPWR requirements. The declaration must follow the structure outlined in PPWR Annex VIII.

The manufacturer is responsible for preparing and maintaining the PPWR Declaration of Conformity and ensuring that it is supported by appropriate technical documentation.

The PPWR Technical File contains the records and evidence supporting compliance with applicable PPWR requirements. Depending on the packaging and requirements involved, it may include packaging specifications, descriptions, assessments, calculations, supplier documentation, declarations, and test reports. Annex VII establishes the applicable technical documentation requirements.

Under Article 16, suppliers of packaging or packaging materials are required to provide the information and documentation necessary to demonstrate that packaging and packaging materials comply with PPWR requirements, including applicable technical documentation required under or pursuant to Articles 5 through 11.

Yes. While the PPWR establishes the overall regulatory framework, many technical details, methodologies, reporting requirements, and compliance procedures will continue to be defined through future Delegated Acts and Implementing Acts over the next several years.