Recyclable Packaging

Under the new law, all packaging must be recyclable by 2030. By Jan. 1, 2028, the European Commission (EC) must adopt delegated acts on design for recycling criteria and recyclability performance grades. Only packaging with A through C performance grades (A equals ≥95%, B equals ≥80%, and C equals ≥70%) will be allowed on the market by 2030. In 2038, packaging classified below grade B will be banned from sales.

Additionally, the EC must adopt implementing acts by 2030 for the recycled-at-scale assessment. By 2035, all packaging must be recycled at scale, with a 55% recycling rate for nearly all packaging materials.

The PPWR contains a framework to create extended producer responsibility (EPR) programs for packaging with eco-modulation. By 2030, EPR eco-modulated fees will correlate with recyclability performance grades. However, individual EU countries will set their fees.

Recycled Content in Plastic Packaging

The EU regulation establishes mandatory minimum percentages of recycled content for any part of plastic packaging. By 2030, "contact-sensitive" PET packaging (other than PET single-use beverage bottles) must have a minimum 30% PCR content (as compared to no minimum requirement). The minimum percentage will increase to 50% by 2040.

Contact-sensitive plastic packaging other than PET must contain a minimum of 10% PCR by 2030 and 25% by 2040. Contact-sensitive packaging refers to packaging materials that come in contact with food, dietary supplements, animal feed, veterinary medicinal products, medical devices, cosmetics, dangerous goods, and other products.

Single-use plastic beverage bottles must include a minimum of 30% PCR by 2030 and 65% by 2040. Other plastic packaging must contain 35% PCR by 2030 and 65% by 2040.

Single-Use Plastic Packaging

The legislation bans certain single-use plastic packaging by 2030, such as secondary packaging (e.g., shrink wrap) that bundles multiple products for retail purchase (e.g., two-packs), food & drink cups, containers, disposable plates, filled and consumed in hotels, restaurants, and cafes (HORECA), small personal care products (e.g., shampoo, lotions) in the hotel and hospitality industry, fresh fruit & vegetable products under 1.5 kg, and small packets, sachets, cups, etc. for condiments, sugar, creamers, preserves, etc. consumed in HORECA settings.

To improve package sorting and reduce contamination in waste streams, 90% of single-use plastic and metal beverage containers (up to three liters) must be collected separately via deposit-return systems or other solutions by 2029.

Reusable Packaging

The PPWR sets targets for reusable packaging, including transport and logistics containers. Some beverage categories will require a minimum of 10% reusable packaging by 2030 and 40% by 2040.

By 2030, 40% of packaging for transporting products within the EU must be reusable. By 2040, economic operators must use at least 70% of transport packaging and sales packaging used for transport in a reusable format within a reuse system. For grouped packaging in the form of boxes, 10% of packaging must be reusable within a reuse system by 2030. This reuse requirement increases to 25% by 2040.

Packaging Materials and Space Minimization

The regulation mandates that packaging be designed with minimal materials and dimensions for functionality by 2030. Packaging structures like double walls, false bottoms, and unnecessary layers that increase the perception of volume will be banned. Package designers should look closely at light-weighting and refill packaging opportunities to meet these requirements.

For e-commerce, transport, and grouped packaging, the empty space ratio must not exceed 50% by 2030.

Additionally, the PPWR calls for packaging waste reduction targets compared to a 2018 baseline. Each EU member state must reduce the packaging waste generated per capita by 5% by 2030, 10% by 2035, and 15% by 2040.

On-Pack Labeling

To avoid cluttering packaging with too many labels, the EU wants all required digital information to be combined into a single data carrier (such as a QR code).

If another EU law already requires digital information for the packaged product, that same code should also include the information required under the PPWR. The data carrier must meet the requirements of the PPWR and any other applicable EU laws. For example, if the packaged product already has a Digital Product Passport (DPP) under Regulation (EU) 2024/1781 or other laws, that same DPP should also provide the packaging-related information required by the PPWR.

An on-pack environmental claim must specify whether the claim is for the entire package or specific components. Furthermore, brands can only make claims that exceed minimum PPWR requirements. For example, a brand can make a claim for 20% PCR content when the minimum requirement is 10% PCR.

By Aug. 2028, packaging must include a harmonized label containing information on its material composition to facilitate consumer sorting. The label shall be based on pictograms and be easily understandable, including for persons with disabilities.

Reusable packaging must bear a label informing users that the packaging is reusable by Feb. 2029.

PFAS Restrictions in Food Packaging

The PPWR bans PFAS concentrations above certain levels in food packaging and addresses substances of concern (SOCs) in packaging. By Aug. 12, 2026, food-contact packaging containing PFAS levels above certain limits cannot be placed on the EU market.

By Dec. 31, 2026, the EC is directed to prepare a report on the presence of SOCs in packaging and packaging components to determine the extent to which they negatively affect the reuse and recycling of materials or impact chemical safety.

On Dec. 19, 2024, the EC adopted a ban on Bisphenol A (BPA) in food-contact materials. The regulation includes an 18-month phase-out period to allow industries time to find suitable replacements or to adjust their processes and supply chains.