Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR), enters into force on 12 August 2026. If your business places packaged products on the EU market, the clock is already running.
The regulation covers every type of packaging: primary, secondary, and transport. It applies to every economic operator in the supply chain, including manufacturers, importers, brand owners, distributors, and e-commerce sellers, with no size threshold. A small German manufacturer exporting to France falls under PPWR the same as a multinational placing products across all 27 member states.
Most businesses know PPWR is coming. Fewer have actually mapped out what it requires from their operations.
What PPWR Actually Requires
Recyclability.
From August 2026, all packaging must meet minimum recyclability standards. The regulation assigns graded performance classes defined in Annex II based on the weight percentage that can be recycled into secondary raw materials: Grade A covers 95% or more recyclable by weight, Grade B covers 80% or more, and Grade C covers 70% or more. The European Commission will adopt delegated acts establishing design for recycling criteria and recyclability assessment methodology by January 2028. From 2030, only grades A, B, and C may reach the market. From 2035, packaging must also be recycled at scale, meaning the collection, sorting, and recycling infrastructure must exist in practice. From 2038, only grades A and B qualify. Manufacturers need to document the recyclability grade of every packaging unit from day one.
Extended Producer Responsibility (EPR).
EPR is not new, but PPWR harmonises and expands it across the EU. Producers must register in every member state where they place packaging on the market. Each national producer register has its own reporting format and submission schedule. A company selling in eight EU countries faces eight separate EPR registration obligations, one per national scheme, each requiring structured packaging data.
Substance restrictions.
Packaging cannot contain certain hazardous substances above the defined thresholds. PPWR introduces new restrictions on substances of concern, with specific limits on per- and polyfluoroalkyl substances (PFAS) in food contact packaging and other materials. Compliance requires verified supplier declarations and material composition data alongside technical documentation showing how the thresholds were assessed.
Packaging minimisation.
From 2030, all packaging must be designed to reduce weight and volume to the minimum necessary for its function. The empty space ratio in grouped, transport, and e-commerce packaging must not exceed 50%. Packaging must meet five specific performance criteria covering product protection, manufacturing processes, logistics, information requirements, and legal obligations.
Recycled content targets.
Plastic packaging must contain a minimum percentage of recycled content recovered from post-consumer plastic waste. By January 2030: 30% for contact-sensitive PET packaging, 10% for contact-sensitive plastic packaging made from materials other than PET, and 35% for single-use plastic beverage bottles and all other plastic packaging. Higher targets activate from January 2040: 50% for contact-sensitive PET, 25% for other contact-sensitive plastics, and 65% for single-use beverage bottles and all other plastic packaging.
Reusable packaging.
Packaging designed for reuse must complete a minimum number of rotations within a certified reuse system. PPWR sets reuse targets for transport packaging: 40% by January 2030 and 70% by January 2040. Reusable packaging must meet specific design requirements covering durability, cleanability, and repairability.
Digital labelling and the QR code requirement.
From August 2028, all packaging must carry harmonised material composition labels to support consumer sorting. From February 2029, reusable packaging must also carry QR codes linking to reuse system information, collection points, and deposit scheme details. The underlying data must be machine-readable, structured to a defined format, and kept current.
There are also compostable packaging rules:
from February 2028, specific packaging types, including permeable tea and coffee bags, single-serve coffee and tea pods, sticky labels placed directly on fruit and vegetables, and very lightweight plastic carrier bags, must be industrially compostable. The waste hierarchy principle runs through the whole regulation: reduction and reuse sit above recycling in terms of priority.
The Real Challenge: Scattered Packaging Data
Most manufacturers and distributors do not have clean, centralised packaging data. Packaging specifications sit in ERP systems. Material composition records live in PLM tools or with procurement teams. Supplier declarations are in email threads or shared drives. Recycled content ratios, if tracked at all, are often in spreadsheets that no one fully trusts.
Compliance under PPWR is essentially a data problem. The regulation does not just require you to use compliant packaging. It requires you to prove it, document it, report it, and make parts of it publicly accessible via digital identifiers.
That changes the workload significantly. A declaration of conformity (DoC) under PPWR requires a full conformity assessment: specific packaging components, material compositions, recyclability grades, and substance checks are all documented. Importers are legally required to verify that manufacturers have completed this assessment, keep copies of the DoC for five years for single-use packaging or ten years for reusable packaging, and respond to national authority requests within ten days. If that data is fragmented across five systems, producing and maintaining accurate documentation becomes a manual, error-prone exercise. Multiply that by several hundred SKUs and a handful of EU markets, and the scope of the problem becomes clear.
In projects we have implemented for manufacturers preparing for PPWR, the first thing we encounter is the same issue: no single system holds a complete picture of a product's packaging. ERP has weight and dimensions. PLM has material specs. The packaging supplier holds the recyclability data. Pulling it together for a compliance report means someone manually reconciling three or four sources for every product line.
What You Need to Have in Place
There is no single path to PPWR compliance, but the preparation steps follow a consistent pattern. The companies that struggle most are not the ones that started late on packaging redesign. They are the ones who underestimated how long data collection takes.
Mapping the packaging portfolio is the first step, and it routinely takes longer than expected. You need a complete inventory of every packaging type in use: primary, secondary, and transport. For each type, you need material composition, weight, recyclability status, recyclability grade assessment, and any relevant substance data. Companies with hundreds of SKUs and multiple contract manufacturers often find that no one person actually holds the full picture.
EPR obligations need to be mapped by the market at the same time. Where are you placing packaging on the EU market? Each country requires separate producer registration. Germany's national register operates differently from France's or Spain's, and the data formats each EPR scheme requires are not identical. Several member states opened their PPWR-aligned registers ahead of the August 2026 enforcement date, so some registration windows are already open. If you are an importer selling under your own brand, Article 21 of PPWR assigns you full manufacturer obligations, including issuing the DoC yourself, not just verifying someone else's.
Supplier declarations are where timelines tend to slip. Substance restriction compliance depends on suppliers providing accurate material data: formal declarations, not verbal confirmation. Collecting, versioning, and chasing these across a supply base of any real size takes weeks. Importers who discover non-compliant packaging after it has been placed on the market face market surveillance actions, mandatory market withdrawal, and potential fines. Finding the gaps before August is significantly better than finding them afterward.
The 2028 and 2029 labelling requirements look far enough away that companies deprioritise them. But the underlying data infrastructure needs to be in place before labels go live. That means structured product and packaging records, a system that generates and manages the required identifiers, and a process for keeping the linked data current as packaging changes. Building that in parallel with everything else in 2026 is feasible. Building it under pressure in 2028 is not.
PPWR Compliance Deadlines: Phase by Phase
The regulation rolls out in defined waves through 2040. Each phase adds new obligations on top of the previous ones.
12 August 2026. Core obligations enter into force. EPR registration in each member state where packaging is placed on the market. EU Declaration of Conformity and supporting technical documentation are required for all packaging. Substance restrictions on hazardous substances and PFAS apply. Recyclability grading must be assessed and documented.
12 February 2028. Compostable packaging rules apply to tea and coffee bags, single-serve pods, sticky labels on fruit and vegetables, and very lightweight plastic carrier bags.
1 January 2028. European Commission adopts delegated acts establishing the design for recycling criteria and recyclability assessment methodology under Annex II.
12 August 2028. Harmonised material composition labelling is required on all packaging to support consumer sorting.
12 February 2029. Reusable packaging must carry QR codes with reuse system information, collection points, and deposit scheme details.
1 January 2030. Packaging minimisation rules apply: weight and volume must be reduced to the minimum necessary, and void space in grouped, transport, and e-commerce packaging must not exceed 50%. Recyclability grades D, E, and F are prohibited; only grades A, B, and C may reach the market. Minimum recycled content targets for plastic packaging are activated. Reuse targets for transport packaging are set at 40%.
1 January 2035. Packaging must be recycled at scale, meaning verified collection, sorting, and recycling infrastructure must exist in practice.
1 January 2038. Only recyclability grades A and B permitted.
1 January 2040. Higher recycled content targets for plastic packaging are activated. Reuse targets for transport packaging rise to 70%.
Centralising Packaging Data for PPWR
Handling these obligations with disconnected systems is technically possible but practically very hard. Most companies at scale need a centralised place to hold packaging compliance data, link it to products, manage supplier inputs, and generate documentation.
What that looks like in practice depends on the tools you already run. Some companies extend their ERP. Others build lightweight custom solutions. A third option is a dedicated PIM platform with PPWR support built in. AtroPIM, for example, ships a native PPWR compliance module that covers declaration of conformity documentation, recyclability grade tracking, EPR registration data formatted for national producer registers, substance checks, and QR code generation for digital labelling. Because the platform uses an EAV-based data model, packaging attributes are fully configurable without custom development, which matters when different countries require different data fields in their producer registers.
The practical advantage of this approach is that packaging compliance data lives alongside product data. When a packaging component changes, the linked compliance records update in the same system rather than requiring manual reconciliation across tools. For companies managing hundreds or thousands of SKUs across multiple EU markets, this reduces the per-product overhead considerably. The module is also updated as PPWR's phased deadlines move through 2028, 2030, and beyond, so the data structure does not need to be rebuilt each time new obligations activate.
Who Actually Holds the EPR Obligation
PPWR compliance is also a supply chain question, and the answer to who is responsible is not always obvious.
If you are a distributor placing manufacturer-branded products on the EU market, you may carry producer responsibilities even if you did not design the packaging. Under PPWR, the economic operator introducing packaged products into a member state bears the EPR obligation for that market unless the manufacturer has explicitly assumed it via a contract registered with the national authority. The regulation defines the responsible person clearly, but many distributor agreements were written before these definitions existed.
Check your supplier contracts. If your agreements do not clearly assign EPR responsibility, you are likely holding it by default. Get clarity on who holds the producer role in each market before assuming it is someone else's problem. For distributors operating across several EU countries, this review alone can surface significant unplanned compliance obligations.