If you are placing packaging on the EU market, you will be faced with the EU Packaging and Packaging Waste Regulations (PPWR)
The PPWR took effect on February 11, 2025, and calls for a significant shift towards more sustainable packaging options and operating models.
The PPWR aims to establish a common framework to reduce the environmental impact of packaging placed on EU markets and highlights the need to rethink existing packaging approaches and choices.
The PPWR sets minimum targets for packaging recyclability, reuse, recycled content, and the reduction of unnecessary packaging. Meeting these targets is mandatory for all packaging (primary, secondary, and tertiary) placed on EU markets, whether produced in the EU or imported from outside.
This means that at certain points in time, according to the regulation’s milestones, if your packaging doesn’t comply with the requirements, you won’t be able to place it on the market in the EU.
Key PPWR deadlines you need to know
The PPWR does not require everything at once. Instead, requirements are phased in over the coming years. Understanding this timeline is essential for planning your compliance roadmap.
Here are the milestones that matter most:
- August 12, 2026: First major application date. Restrictions on PFAS and other substances of concern in food-contact packaging take effect. Recyclability design criteria and labeling obligations begin to apply. This is the first moment your packaging could be non-compliant.
- 2030: All packaging on the EU market must be designed to be recyclable. Minimum recycled content targets for plastic packaging kick in: 10% for contact-sensitive plastic packaging, 35% for PET beverage bottles, and 35% for other plastic packaging. First reuse targets apply for transport packaging and grouped packaging.
- 2035: All packaging must not only be designed for recyclability but must be recycled at scale through established collection and recycling infrastructure.
- 2040: Higher recycled content targets: 50% for contact-sensitive plastic packaging, 65% for PET beverage bottles, and 65% for other plastic packaging. Stricter reuse targets across additional categories.
With the first application date less than two months away, companies that haven’t started assessing their packaging portfolio are already behind.
What happens if your packaging doesn’t comply
The consequences of non-compliance go beyond regulatory fines. Under the PPWR, packaging that does not meet the applicable requirements at each milestone simply cannot be placed on the EU market. For companies that depend on EU distribution, this means potential product withdrawal, supply chain disruptions, and lost revenue.
Additionally, the regulation strengthens Extended Producer Responsibility (EPR) schemes across member states. Companies will face differentiated EPR fees based on the environmental performance of their packaging. Non-recyclable or hard-to-recycle packaging formats will carry significantly higher costs.
Reputation plays into this too. With sustainability reporting expanding under the CSRD, your packaging decisions become visible to investors, customers, and regulators. Companies that move early on the PPWR build credibility across all three audiences.
How to choose the best packaging option
In this context, you are probably thinking about which packaging options you have and how to choose the best one from both regulatory and business perspectives.
Comparing packaging options is simpler than it looks when you break it down. A structured approach helps you narrow down your choices and make decisions based on facts.
So, if your company is facing that question right now, here is a flow that can help you choose between different packaging options:
- Identify your packaging options:
- At this stage, be open and think unconstrained. What packaging is feasible for your type of product?
- Consider various materials (glass, paper/cardboard, metal, plastic, etc.) and formats (bottles, boxes, pouches, etc.).
- Also list existing reusable, refillable, biodegradable, and compostable alternatives.
- Evaluate functional requirements:
- Review all the options to ensure the packaging adequately protects the product, ensures shelf-life requirements, meets logistical needs, and satisfies consumer expectations.
- This allows you to significantly narrow down your choices.
- The main role of packaging is to protect the product; otherwise, all the efforts to improve packaging sustainability while compromising the integrity of the product inside are pointless.
- Assess against PPWR criteria:
- To further filter your options, map each option against the PPWR requirements and understand whether they allow you to meet the requirements in terms of recyclability, reuse, recycled content for plastics, and packaging minimization.
- Consider life-cycle impacts:
- If after the above assessments you still have more than one option, and they significantly differ in terms of material, concept, or operating model, a Life Cycle Assessment (LCA) can help you make a further differentiation.
- Assess the environmental impact throughout the value chain, including the consumer usage stage and likely end-of-life management scenarios for each packaging option.
- Go with the option that shows the clearest environmental improvement.
- Assess implementation feasibility:
- Evaluate the operational feasibility and costs associated with each remaining packaging option. The cost goes beyond the price of the material; it includes investments, roll-out complexity, associated extended producer responsibility (EPR) fees, and plastic taxes.
- The final packaging choice needs to be executable and affordable, otherwise, it won’t be sustainable for your business.
Always take a data-driven approach
It is always best to base your packaging decisions on reputable data, as opposed to just going for some innovation that you saw on your LinkedIn feed, or one that your current supplier offers you.
All the data collected during the exercise discussed above will then be useful to demonstrate compliance, certify your choices, communicate with your stakeholders and consumers, and demonstrate regulatory compliance to the authorities.
This is especially important now that the first PPWR application date is approaching. Starting in August 2026, companies need to demonstrate that their packaging meets the new design-for-recyclability criteria and complies with substance restrictions. Having a documented, data-driven decision process is the foundation for that evidence.
If you haven’t started yet, begin with a portfolio screening: map your current packaging formats against the PPWR requirements and identify the gaps. This gives you a clear picture of what needs to change and allows you to prioritize the packaging lines with the highest compliance risk or the largest market volume.
About the author
Anna Perlina is a Sustainable Packaging Consultant who helps packaged goods companies develop and implement cost-effective sustainable packaging strategies.
Need help navigating the PPWR?
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