The PPWR, Regulation (EU) 2025/40, has been in effect throughout the European Union since August 12, 2026. It requires that, for each package placed on the market, the following information be documented: its composition by material, its recycled content percentage, its recyclability class, substances of concern, and its suitability for food contact.
What the PPWR Has Changed Since August 12, 2026
Regulation (EU) 2025/40 on packaging and packaging waste was adopted on December 19, 2024, and published in the Official Journal of the European Union on January 22, 2025 [1]. There are two dates to distinguish between, and they are often confused. The regulation entered into force on February 11, 2025. It has been generally applicable since August 12, 2026 [2].
On that same date, August 12, 2026, Directive 94/62/EC on packaging and packaging waste was repealed. However, some of its provisions continue to apply [2].
Two documents published by the European Commission in 2026 outline the practical arrangements. Implementation guidelines for economic operators and Member States were published in March 2026 [3]. An official list of frequently asked questions was published on August 3, 2026, nine days before the regulation took effect [4]. This second document addresses practical questions raised by stakeholders since the regulation was adopted. It is currently available only in English.
Who is involved in the agrifood sector?
The scope is broad. The regulation covers all packaging placed on the market in the European Union, whether empty or filled, regardless of the material, and whether produced within the Union or imported from third countries. It also covers all packaging waste generated within the Union [4].
The definition of packaging is also broad: any item intended to contain, protect, handle, deliver, or display a product, including its components. However, items that are an integral part of a product and are disposed of along with it are excluded [4].
In practice, for an agri-food company, this applies to primary packaging that comes into contact with the food product, secondary packaging, and shipping packaging. Manufacturers, importers, and distributors are subject to these requirements, including when the product is manufactured on behalf of a retailer under a private label.
One point is worth noting: the regulation provides for targeted exemptions for certain types of packaging for drugs and medical devices, but no general exemption for the agri-food sector [5].
What packaging data does the PPWR require?
This is the operational issue, and it is what determines the actual workload. Each requirement of the regulation translates into a piece of data that must be maintained, kept up to date, and provided upon request.
| Data to be retained | Why the regulation requires it | Reference |
|---|---|---|
| Composition, material by material, layer by layer | Recyclability is assessed on a per-packaging-unit basis | Appendix II, Table 3 |
| Weight and mass distribution of each component | Recyclability is assessed based on weight | Appendix II, Table 3 |
| Packaging Type and Format | The thresholds apply by packaging type and format | Article 7, paragraph 1, and Annex II, Table 1 |
| Percentage of recycled content, by plastic part | Minimum thresholds to be met by 2030 and then by 2040 | Article 7, paragraphs 1 and 2 |
| Affiliated manufacturing plant | The amount of recycled content is calculated as an average per manufacturing plant per year | Article 7, paragraph 1 |
| Recyclability performance class: A, B, or C | Makes the ability to place the product on the market contingent upon | Article 6, paragraph 3, and Annex II, Table 3 |
| PFAS Concentration | Prohibition on placing products on the market that exceed the thresholds for food contact | Article 5, paragraph 5 |
| Concentrations of lead, cadmium, mercury, and hexavalent chromium | The sum of the four must not exceed a certain threshold | Article 5, paragraph 4 |
| Suitability for contact with food | Determines the application of PFAS thresholds | Article 5, paragraph 5 |
| Reusability and integration into a reuse system | Target for the minimum share of reusable packaging | Article 29, paragraph 1 |
| Void ratio for consolidated, shipping, and e-commerce packaging | Maximum limit to be observed | Article 24, paragraph 1 |
Two practical consequences often go unnoticed.
- The first concerns the calculation of recycled content. The regulation specifies that it is calculated “as an average per manufacturing plant and per year” [6]. It is therefore not a characteristic of a single piece of packaging, but a consolidated figure. This requires knowing, for each packaging SKU, which plant it comes from, and being able to aggregate the information over a full fiscal year.
- The second concerns recyclability. The assessment is conducted on a per-unit basis and in terms of weight [7]. A “rough” idea of the composition is not enough: a layer-by-layer breakdown and the weight of each layer are required.
Key Dates to Watch After 2026
Only one quantified target is currently in effect. The others apply to 2030 and beyond.
Effective August 12, 2026
Packaging intended to come into contact with food may not be placed on the market if it contains concentrations of per- and polyfluoroalkyl substances ( PFAS) that are equal to or greater than the following values [8]:
| Threshold | Measurement Scope | Reference |
|---|---|---|
| 25 ppb | for any PFAS measured by targeted analysis, excluding polymeric PFAS from the quantification | Article 5, paragraph 5, subparagraph (a) |
| 250 ppb | for the total PFAS measured as the sum of targeted analyses, with prior degradation of precursors where applicable, excluding polymeric PFAS from the quantification | Article 5, paragraph 5, subparagraph (b) |
| 50 ppm | for PFAS, including polymeric PFAS | Article 5, paragraph 5, subparagraph (c) |
In addition, the total concentration of lead, cadmium, mercury, and hexavalent chromium in packaging or its components must not exceed 100 mg/kg [9].
Recycled content in plastic packaging
The thresholds shall apply no later than January 1, 2030, or three years after the entry into force of the implementing act provided for in the regulation, if that date is later [6].
| Packaging Category | 2030 | 2040 | Reference |
|---|---|---|---|
| Products that come into contact with food, with PET as the main component, excluding single-use plastic beverage bottles | 30 % | 50 % | Article 7, paragraphs 1(a) and 2(a) |
| Products sensitive to contact, plastics other than PET, excluding single-use plastic beverage bottles | 10 % | 25 % | Article 7, paragraphs 1(b) and 2(b) |
| Single-use plastic beverage bottles | 30 % | 65 % | Article 7, paragraphs 1(c) and 2(c) |
| Other plastic packaging | 35 % | 65 % | Article 7, paragraphs 1(d) and 2(d) |
Recyclability
Recyclability is classified into performance classes A, B, or C [7]:
| Class | Threshold | Reference |
|---|---|---|
| Class A | 95% or higher | Appendix II, Table 3 |
| Class B | 80% or more | Appendix II, Table 3 |
| Class C | 70% or more | Appendix II, Table 3 |
The schedule consists of three stages [10]:
- Effective January 1, 2030, or 24 months after the delegated acts take effect, whichever is later, packaging that does not fall under Classes A, B, or C may no longer be placed on the market.
- Starting January 1, 2035, an additional criterion will be added: recycling on a large scale [11].
- Effective January 1, 2038, packaging that does not fall under Class A or B may no longer be placed on the market.
These dates are not set in stone for the first deadline. The Commission must specify the design criteria for recyclability no later than January 1, 2028 [12], and the 2030 deadline may be extended by 24 months if the criteria are adopted late.
Reuse
Effective January 1, 2030, economic operators that use transport or sales packaging to transport products must ensure thatat least 40% of such packaging is reusable and is part of a reuse system [13].
The list of targeted formats speaks for itself in the agri-food supply chain: pallets, collapsible plastic boxes, boxes, trays, plastic crates, large bulk containers, buckets, drums, and cans—regardless of their size or material—including flexible packaging, pallet wrappings, and straps used to stabilize and protect products during transport [13].
Starting January 1, 2040, these same operators must strive to reach at least 70 percent [13]. The difference in wording is significant: 40 percent by 2030 is a result-based obligation, while 70 percent by 2040 is an obligation of means.
Empty space
No later than January 1, 2030, or three years after the entry into force of the corresponding implementing acts if that date is later, the void space ratio for grouped packaging, transport packaging, and e-commerce packaging must not exceed 50% [14]. The Commission must establish the calculation method by February 12, 2028 [14].
Reducing Packaging Waste
These targets apply to Member States, not directly to companies. Each Member State must reduce the amount of packaging waste generated per capita, compared to 2018, by 5% by 2030, 10% by 2035, and 15% by 2040 [15].
The impact on manufacturers is indirect but real: it is through the tightening of national regulations, in both France and Belgium, that these objectives will be implemented in practice.
Measures that particularly affect the agri-food sector
- Format restrictions: The regulation restricts certain types of single-use plastic packaging, including individual-serving packages and sachets of condiments and sauces [2].
- Takeout: Takeout businesses must allow customers to use their own containers at no additional cost [2].
- PET Bottles: On June 30, 2026, the Commission clarified the rules for calculating the recycled content of single-use polyethylene terephthalate (PET ) bottles, with the aim of ensuring transparency [16]. This issue directly affects beverage producers.
- Geographical Indications and Trademarks: The requirements to minimize packaging allow for exceptions, particularly when the product or beverage bears a geographical indication protected under Union law, or when such reduction would prevent a trademark from distinguishing the product or a design from retaining its characteristics [17]. Harmonized calculation standards must be prepared at the Commission’s request no later than February 12, 2027 [17].
- Pallet wrap and straps: A Commission delegated decision exempts certain economic operators that use pallet wrap and straps from the reuse requirements [18]. How this aligns with the 40% target should be assessed on a case-by-case basis.
How can you demonstrate compliance?
The PPWR sets European requirements. The declarations, however, remain national. A manufacturer with operations in France and Belgium therefore finds itself having to submit the same packaging data to multiple systems.
In France, the annual eco-contribution declaration filed with Citeo or Leko is based on the type and weight of materials per unit of sale [19]. Recyclability is assessed using the TREE tool. The decree on environmental qualification, known as the QCE decree, adds its own reporting requirements.
In Belgium, reporting for household packaging is done through Fost Plus [20], which has its own reporting formats and deadlines.
What all these systems have in common is the underlying data: composition, weight, material, recycled content, and recyclability. Accurate data supports all the claims. Inaccurate data undermines them all at once.
From Regulations to Data
The challenge faced by the Quality and R&D teams is not understanding the regulations. Rather, it is finding—for several hundred product lines—information scattered across suppliers’ technical data sheets, spreadsheets, the ERP system, and file servers.
As long as packaging data is scattered, each report is a data collection campaign. When it is consolidated into a single location and linked to the consumer sales unit, the report becomes an export. This is the principle behind a packaging data repository, whose purpose is to make proof available on demand rather than having to be reconstructed in a rush. This repository is not a standalone tool. It is one of the data domains managed by food industry PLM software, alongside recipes, technical data sheets, and regulatory labeling.
Wondering where you stand with your own packaging data? Our food and beverage teams can help you take stock of the situation.
Frequently Asked Questions About PPWR Compliance
The PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It replaces Directive 94/62/EC and covers the entire life cycle of packaging, from design to waste management. It applies to all packaging placed on the market in the European Union, regardless of the material.
There are two dates to note. Regulation (EU) 2025/40 entered into force on February 11, 2025. It has been generally applicable since August 12, 2026, the date on which Directive 94/62/EC was repealed, although certain provisions of that directive continue to apply.
As of August 12, 2026, food-contact packaging may no longer be placed on the market if its PFAS concentration reaches 25 ppb for a single PFAS measured by targeted analysis, 250 ppb for the sum of PFAS, or 50 ppm including polymeric PFAS, in accordance with Article 5, paragraph 5. The thresholds for recycled content and recyclability, on the other hand, will apply starting in 2030.
All operators who place packaging on the market in the European Union: manufacturers, importers, and distributors, including those for private-label products. The regulation provides for targeted exclusions for certain types of packaging for medicines and medical devices, but no general exemption for the agri-food sector, according to Article 7, paragraph 4.
The declaration is based on the technical documentation for each package: material composition by material, weight of each layer, recycled content rate by manufacturing plant and by year in accordance with Article 7, recyclability class in accordance with Annex II, Table 3, and substances of concern in accordance with Article 5. Compliance must be demonstrable upon request by the authorities.
The PPWR sets European requirements, while declarations remain a national matter. In France, the eco-contribution is reported to Citeo or Leko, and recyclability is assessed using the TREE tool, in accordance with the requirements of the QCE decree. In Belgium, declarations are submitted through Fost Plus. These systems are based on the same packaging data.
Sources
- [1] Regulation (EU) 2025/40 of the European Parliament and of the Council of December 19, 2024, on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. EUR-Lex: https://eur-lex.europa.eu/eli/reg/2025/40/oj/fra
- [2] European Commission, Directorate-General for the Environment, “Packaging Waste” page: dates of entry into force and application, repeal of Directive 94/62/EC, size restrictions, and takeout sales. https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_fr
- [3] European Commission, Guidelines on the Implementation of the Regulation for Economic Operators and Member States, March 2026. https://environment.ec.europa.eu/publications/guidance-document-packaging-and-packaging-waste-regulation-ppwr_en
- [4] European Commission, Frequently Asked Questions on the Regulation on Packaging and Packaging Waste, published on August 3, 2026. https://environment.ec.europa.eu/publications/faq-packaging-and-packaging-waste-regulation-ppwr_en
- [5] Regulation (EU) 2025/40, Article 7, paragraph 4, exclusions.
- [6] Regulation (EU) 2025/40, Article 7, paragraphs 1 and 2, minimum recycled content in plastic packaging.
- [7] Regulation (EU) 2025/40, Annex II, Table 3, recyclability performance classes.
- [8] Regulation (EU) 2025/40, Article 5, paragraph 5, PFAS limits in food-contact packaging.
- [9] Regulation (EU) 2025/40, Article 5, paragraph 4: lead, cadmium, mercury, and hexavalent chromium.
- [10] Regulation (EU) 2025/40, Article 6, paragraph 3, conditions for placing products on the market based on their recyclability class.
- [11] Regulation (EU) 2025/40, Article 6, paragraph 2, subparagraph (b), scale-based recycling criterion.
- [12] Regulation (EU) 2025/40, Article 6(4), delegated acts establishing design criteria for recycling.
- [13] Regulation (EU) 2025/40, Article 29, paragraph 1, reuse targets.
- [14] Regulation (EU) 2025/40, Article 24, paragraphs 1 and 2, requirement regarding excessive packaging.
- [15] Regulation (EU) 2025/40, Article 43(1), prevention of packaging waste.
- [16] European Commission, press release dated June 30, 2026, clarification of the rules for recycling plastic bottles. https://ec.europa.eu/commission/presscorner/detail/en/ip_26_1467
- [17] Regulation (EU) 2025/40, Article 10, Minimizing Packaging.
- [18] European Commission, Delegated Decision exempting certain economic operators that use plastic film and pallet straps from the reuse requirements. https://environment.ec.europa.eu/publications/commission-delegated-decision-exempting-certain-economic-operators-use-pallet-wrappings-and-straps_en
- [19] Citeo, an accredited eco-organization for household packaging in France. https://www.citeo.com
- [20] Fost Plus, the organization responsible for household packaging in Belgium. https://www.fostplus.be/fr
