Packaging and Packaging Waste Regulation (PPWR)
The Packaging and Packaging Waste Regulation (PPWR) entered into force in the European Union on 11 February 2025. Its full title is Regulation (EU) 2025/40 of the European Parliament and of the Council. The Regulation aims to harmonise packaging and packaging waste requirements across the EU internal market.
The new Regulation ensures that the presence and concentration of substances of concern in packaging materials and packaging components are reduced to the minimum possible level. It also introduces measures to reduce excessive packaging, improve the recyclability of packaging, minimise unnecessary packaging complexity, increase the use of recycled content, and promote reuse.
The Regulation will generally apply from 12 August 2026 (with the exception of Article 67(5), which applies from 12 February 2029). From that date, the current Packaging and Packaging Waste Directive 94/62/EC will largely be repealed in accordance with Article 70 of the Regulation.
Changes to extended producer responsibility principles
Under the previous system, a packaging undertaking was a person who, in the course of its economic or professional activities, packaged goods, imported packaged goods, or sold packaged goods. Packaging producer responsibility obligations have therefore traditionally been fulfilled by persons placing packaged products on the market.
Under the PPWR, the term producer is used to designate the economic operator responsible for financing the collection and treatment of packaging waste. The new definition of producer became applicable on 12 August 2026.
The objective of the PPWR is to ensure that there is one producer for each packaging unit. A producer is the economic operator that makes packaging or packaged products available for the first time in the Member State where the packaging is expected to become waste. A producer may be a manufacturer, importer or distributor, and this applies irrespective of the sales technique used, including e-commerce and distance selling. The definition covers both packaged products and empty packaging placed on the market.
The purpose of this change is to harmonise the definition of producer across all EU Member States and to ensure that responsibility for packaging waste is clearly assigned to an identified economic operator in the Member State where the packaging becomes waste.
An economic operator is considered a producer if it:
- makes transport packaging, service packaging or primary production packaging available for the first time in a Member State (whether single-use or reusable);
- makes packaged products available for the first time in a Member State (for example, products packed in sales or grouped packaging);
- sells packaging or packaged products directly to an end user in another Member State (for example through an online store); or
- unpacks or repacks packaged products in the course of business, where no other responsible producer has already been identified.
For the definition of producer and the obligations applicable to producers, reference should be made to the PPWR, the guidance issued by the European Commission, and the Commission’s Frequently Asked Questions (FAQs):
Frequently Asked Questions
The following principles should be taken into account when determining the producer of transport packaging.
- The item must fulfil a packaging function
Where packaging consists of several components and becomes packaging only once assembled, the producer is the economic operator that assembles the packaging into its final form. - The producer is generally the economic operator that supplies the transport packaging in its final form
If a company manufactures or assembles transport packaging and supplies it for use, it is generally considered the producer. - The place where the packaging is first put into use is important
If the packaging is transferred to another Member State and is made available on the market there for the first time, the producer is the economic operator established in that Member State. - If the packaging is exported outside the EU, EU extended producer responsibility requirements do not apply (although requirements in the destination country may apply).
- Packaging material is not yet packaging
If a company sells, for example, carton blanks or stretch film in rolls that still need to be assembled or converted into packaging, this is not yet considered the placing of packaging on the market. - If a company receives packaged goods, unpacks them, or repacks them (for example into smaller quantities), it may become the producer of the transport packaging, even if it does not own the goods.
For sales and grouped packaging, the producer is the economic operator that packages the product and makes the packaged product available for the first time in the country where the product is placed on the market.
Examples:
- If an Estonian company packages a product in Estonia and sells it in Estonia, the producer is the Estonian company that packaged the product.
- If an Estonian company sells a packaged product to an economic operator in another Member State, and that operator places the product on the market in that Member State (i.e. it is not the end user), the producer is the economic operator established in that other Member State.
- If a company sells a packaged product through an online store directly to a consumer or to an economic operator in another Member State that does not further supply the product in the same form, the online seller is the producer, and the extended producer responsibility obligations must be fulfilled in the Member State to which the product is sold.
What is service packaging? Service packaging is an item that is designed and intended to be filled at the point of sale for the purpose of supplying a product. Take-away packaging is a type of service packaging that is filled at points of sale frequented by consumers with beverages or prepared food that is packaged for transportation and immediate consumption elsewhere without requiring any further preparation, and is typically consumed directly from the packaging.
For service packaging, the extended producer responsibility obligation generally rests with the manufacturer of the packaging.
As an exception, the user of the packaging (e.g. a food service operator) is considered the producer where the packaging is clearly marked with its name or trademark. In such cases, the economic operator placing the packaging on the market under its own name or trademark is responsible for ensuring the packaging complies with the applicable requirements.
In certain cases, importers or distributors may also be considered producers, for example where they place the packaging on the market under their own name or trademark or modify the packaging in a way that may affect its compliance with applicable requirements.
The producer is responsible for ensuring that the packaging complies with all applicable requirements, including sustainability and labelling requirements, regardless of who prepared the EU declaration of conformity or any part thereof.
Where packaging is manufactured under the name or trademark of a microenterprise and the supplier of that packaging is established in the same Member State, the supplier of the packaging is considered the producer.
If a company established in another EU Member State or in a third country makes a packaged product available for the first time directly to an end user located in Estonia, that foreign company is generally considered the producer in Estonia for the purposes of extended producer responsibility.
This applies irrespective of the sales channel used, including sales to private consumers through an online store, other forms of distance selling, and direct sales to professional end users established in Estonia.
A professional end user is an economic operator that uses a purchased product in its own activities or production process and does not make that product available on the market in the form in which it was supplied.
For example, where an Estonian manufacturing company purchases packaged raw materials from a supplier established in another EU Member State, uses those raw materials in its own production process and does not resell the packaged raw materials, the Estonian company is considered a professional end user.
Where the supplier sells and delivers the goods directly to that Estonian end user, the supplier is generally regarded as the producer of the packaging in Estonia for the purposes of extended producer responsibility.
If a company established in another Member State sells packaged products to a professional distributor established in Estonia, who then makes those products available on the Estonian market, the Estonian distributor is generally considered the producer of the packaging in Estonia for the purposes of extended producer responsibility.
In such business model, the foreign supplier is generally not regarded as a producer in Estonia, as it does not supply the products directly to end users in Estonia.
No. There is no minimum threshold for extended producer responsibility obligations based on sales volume or the quantity of packaging placed on the market. Extended producer responsibility obligations apply regardless of a company's sales volume or the amount of packaging it places on the market.
The PPWR provides for simplified reporting requirements for producers placing less than 10 tonnes of packaging per year on the market of a Member State. However, this does not exempt producers from registration or any other extended producer responsibility obligations.
The simplified reporting regime will apply together with the PPWR's harmonised registration and reporting system. That system will become operational following the adoption of the relevant European Commission implementing act and the expiry of the transition period provided for in the Regulation.
Producer Registration and Other Obligations
Registration in the producer register as provided for in Article 44 of the PPWR is not yet applicable in Estonia.
Under the PPWR, the European Commission will adopt an implementing act establishing the format for registration in the producer register, the information to be included in the register, and the reporting format.
Following the adoption of that implementing act, Member States will have 18 months to establish their national producer registers.
According to the European Commission’s published Frequently Asked Questions (FAQs), under the new harmonised system producers will submit data to the national producer register for the first time by 1 June 2029, covering the preceding full calendar year. This timeline is based on the assumption that the implementing act is adopted within the deadline provided for in the PPWR.
Until a producer register has been established in Estonia and the registration obligation has entered into force, economic operators are neither able nor required to register pursuant to Article 44 of the PPWR.
Frequently Asked Questions
Although the producer register provided for in Article 44 of the PPWR has not yet been established in Estonia, obligations arising from the Packaging Act already apply in Estonia.
It is important to note that the Packaging Act does not provide for any minimum packaging threshold below which obligations would not apply. Consequently, the obligations arising from the Packaging Act must be fulfilled regardless of whether an economic operator places only a few kilograms of packaging or significantly larger quantities of packaging on the Estonian market each year.
Where an economic operator places packaging or packaged products on the Estonian market, it must comply with the producer responsibility obligations arising from the applicable legislation.
In particular, this means that the economic operator must:
- Submit data on packaging placed on the Estonian market to the Packaging Registry (PAKIS).
Pursuant to the Packaging Act, packaging undertakings are required to report data on packaging placed on the Estonian market.
The Packaging Registry is administered by the Estonian Environment Agency. For questions regarding registration as a user in PAKIS, submission of data, use of the registry, or technical aspects of reporting, please contact the Estonian Environment Agency at klienditugi@envir.ee.
The Estonian Environment Agency also provides user guides, supporting materials and up-to-date information on data submission on the PAKIS website.
- Foreign packaging undertakings must appoint an authorised representative in Estonia.
Pursuant to Section 12¹(7) of the Estonian Packaging Act, a packaging undertaking that is not established in Estonia but, irrespective of the sales method used, places packaging on the Estonian market in the course of its economic or professional activities must appoint an authorised representative that is a natural or legal person established in Estonia.
For the purposes of Section 10² of the Packaging Act, an authorised representative is a person who fulfils, on behalf of the packaging undertaking, the extended producer responsibility obligations arising from the Packaging Act in Estonia. An authorised representative may perform only those tasks that have been expressly specified in the written mandate granted by the packaging undertaking. The mandate is valid only if it has been accepted by the authorised representative in writing.
Subject to the scope of the mandate granted, the authorised representative may, among other things, fulfil registration, reporting and other extended producer responsibility obligations on behalf of the packaging undertaking.
The Packaging Act does not require a separate licence, registration or other qualification for acting as an authorised representative. A single authorised representative may represent multiple foreign packaging undertakings, provided that each undertaking has granted a separate written mandate.
A producer responsibility organisation (PRO) may also act as the authorised representative, provided that this service and the associated responsibilities are covered by the agreement between the parties.
The producer placing sales packaging on the market must conclude an agreement with a producer responsibility organisation (PRO).
The following producer responsibility organisations operate in Estonia:
Eesti Pandipakend OÜ - for deposit packaging
For other types of packaging, extended producer responsibility obligations may also be fulfilled individually.
Where a packaging undertaking is not established in Estonia, these obligations may be fulfilled on its behalf by an authorised representative within the scope of the mandate granted to that representative.
The registration obligation under Article 44 of the PPWR will be added to the existing requirements once the relevant European Commission implementing act has been adopted and Estonia has established its producer register.
According to the European Commission’s Frequently Asked Questions (FAQs), the first reporting under the harmonised system is expected to take place by 1 June 2029, covering the preceding full calendar year.
Before placing packaging on the market, the manufacturer must carry out the conformity assessment procedure set out in Article 38 and Annex VII of the PPWR and prepare the technical documentation and the EU declaration of conformity in accordance with the requirements of Annex VIII. Through the EU declaration of conformity, the manufacturer declares that the packaging complies with the PPWR requirements applicable at the time the packaging is placed on the market.
The EU declaration of conformity is a self-declaration by the manufacturer. Packaging is not subject to approval by a public authority before being placed on the market. The manufacturer is responsible for the compliance of the packaging and must, upon request by a market surveillance authority, be able to demonstrate that the packaging complies with the applicable requirements.
The conformity assessment procedure and the EU declaration of conformity need only cover those requirements that are applicable at the time the packaging is placed on the market. Requirements that will become applicable at a later date (for example, requirements applying from 2030 onwards) do not need to be included in the declaration of conformity for packaging that was placed on the market earlier.
The supplier of the packaging or packaging material must provide the manufacturer with all information and documentation necessary to demonstrate compliance with the PPWR requirements.
Before placing packaging on the market, importers and distributors must verify that the manufacturer has fulfilled its obligations under the PPWR, including carrying out the conformity assessment procedure and drawing up the EU declaration of conformity. Upon request by a market surveillance authority, they must be able to demonstrate that these obligations have been fulfilled. We recommend that contractual arrangements address the availability of compliance documentation and the allocation of responsibilities between the parties.
In summary:
- The conformity assessment procedure is the process by which the manufacturer assesses whether the packaging complies with the applicable requirements.
- The technical documentation contains the basis for the assessment, the supporting evidence, and the assessment results.
- The EU declaration of conformity is the manufacturer's formal declaration that the packaging complies with the applicable requirements, based on the conformity assessment and the technical documentation.
These elements form a single system: first, the conformity assessment is carried out; second, the evidence and results are compiled in the technical documentation; and finally, the outcome of the assessment is formally confirmed through the EU declaration of conformity.
Further information on the conformity assessment procedure and the EU declaration of conformity can be found in Articles 38 and 39 and Annexes VII and VIII of the PPWR.
Frequently Asked Questions
When determining the manufacturer, the key consideration is who has the decisive influence over the design and technical characteristics of the packaging. The manufacturer does not necessarily have to physically produce the packaging. For any given packaging item, there is one manufacturer in the supply chain who is responsible for ensuring compliance with the applicable requirements.
According to Article 3(1)(13) of the PPWR, a manufacturer is:
- A natural or legal person that manufactures packaging or packaged products.
- Where a person has packaging or packaged products designed or manufactured under its own name or trademark, that person is considered the manufacturer, regardless of whether another trademark also appears on the packaging or packaged product.
- In the case of the microenterprise exemption, the supplier of the packaging is considered the manufacturer. Where packaging or a packaged product is ordered under a microenterprise’s name or trademark and the packaging supplier is established in the same Member State, the supplier of the packaging is regarded as the manufacturer. A microenterprise is an undertaking with fewer than ten employees and an annual turnover or annual balance sheet total not exceeding EUR 2 million. It is important to note that this exemption does not apply merely because small quantities of packaging are involved. The conditions for microenterprise status and the location of the supplier must be assessed.
Where packaging or a packaged product is placed on the market under an undertaking's own name or trademark, that undertaking will generally be considered the manufacturer. However, where the name or trademark appearing on the packaging does not correspond to the person exercising decisive control over the packaging design and technical characteristics, the manufacturer must be identified on the basis of the specific circumstances of the case and the actual decision-making authority of the parties involved.
An importer is an economic operator established in the European Union that places packaging or packaged products originating from a third country on the Union market.
For example, where an Estonian company imports packaged products from China, it will generally act as the importer.
Packaging imported into the European Union must comply with the requirements of the PPWR regardless of where the packaging or the packaged product was manufactured.
A distributor is an economic operator in the supply chain that makes packaging or a packaged product available on the market but is neither the manufacturer nor the importer.
For example, an Estonian company may act as a distributor where it resells, without modification, a product marketed under the trademark of another European Union company.
In such cases, the distributor is generally not required to draw up a new EU declaration of conformity. However, the distributor must act with due care and verify that the manufacturer, and where applicable the importer, has fulfilled their obligations under the PPWR.
A supplier is a person that supplies packaging or packaging materials to a manufacturer.
The supplier must provide the manufacturer with all information and documentation necessary for the manufacturer to demonstrate compliance of the packaging with the requirements of the PPWR. This may include, for example, information on material composition, technical specifications, and test reports.
The documentation provided by the supplier forms the basis for the manufacturer's conformity assessment.
The conformity assessment procedure is the process by which the manufacturer of the packaging assesses and demonstrates, before placing the packaging on the market, that the packaging complies with the applicable requirements of the PPWR.
As part of the conformity assessment procedure, the manufacturer must:
- identify which PPWR requirements apply to the packaging;
- assess the packaging, including all of its components and materials;
- collect the data and documentation necessary to demonstrate compliance;
- evaluate whether the available evidence is sufficient;
- carry out calculations, testing, or risk assessments where necessary;
- prepare the technical documentation; and
- draw up the EU declaration of conformity on the basis of the assessment results.
The conformity assessment must be carried out in accordance with Article 38 and Annex VII of the PPWR, and responsibility for conducting the assessment rests with the manufacturer of the packaging.
Technical documentation is the collection of documents and information that enables an assessment of whether packaging complies with the applicable requirements of the PPWR.
Technical documentation is not limited to the EU declaration of conformity or a supplier’s statement. It must contain sufficient information to demonstrate:
- which packaging was assessed;
- which requirements apply to that packaging;
- which data were used in the assessment;
- how compliance was verified; and
- what conclusions were reached by the manufacturer.
The manufacturer of the packaging is responsible for preparing and maintaining the technical documentation.
An EU declaration of conformity is the manufacturer's formal declaration that the packaging or packaging type identified in the declaration complies with the applicable requirements of the PPWR.
The declaration is drawn up after the conformity assessment has been carried out and the technical documentation has been prepared. The declaration is not a document that replaces the conformity assessment; rather, it represents the manufacturer's conclusion based on the assessment performed.
The EU declaration of conformity is a self-declaration by the manufacturer. Packaging is not subject to approval by a public authority before it is placed on the market.
In Estonia, the Estonian Environmental Board (Keskkonnaamet) is responsible for market surveillance and enforcement of the requirements arising from the Packaging Act. Outside the context of a supervisory or official control procedure, the Environmental Board does not carry out prior or substantive assessments of EU declarations of conformity and does not issue approvals for such declarations.
The compliance of declarations of conformity and other supporting documentation can only be assessed within the framework of a supervisory procedure, taking into account the specific packaging and the circumstances existing at the time of inspection. Responsibility for ensuring that the documentation complies with the applicable requirements rests with the manufacturer.
No. The conformity assessment, technical documentation and EU declaration of conformity must cover only those requirements that are applicable at the time the specific packaging is placed on the market. Requirements that will become applicable at a later date do not need to be proactively declared as complied with for packaging placed on the market before those requirements take effect.
However, when developing future packaging solutions, economic operators should take into account upcoming requirements relating to:
- labelling;
- recyclability;
- recycled plastic content;
- packaging minimisation;
- empty space reduction; and
- reuse and reusable packaging systems.
Considering these future requirements at an early stage can help avoid the need for significant redesigns once the relevant provisions of the PPWR become applicable.
A general statement that packaging or a material “complies with the PPWR” may not be sufficient. At a minimum, such a statement should clearly indicate:
- which packaging, packaging component or material it relates to;
- which specific requirements compliance is being declared for;
- the data, calculations or test results on which the statement is based;
- whether the assessment covers the entire packaging unit, including printing inks, adhesives and other coatings, where relevant; and
- whether the information provided is current, traceable and sufficiently documented.
A supplier’s statement may form part of the technical documentation, but it does not replace the manufacturer's conformity assessment procedure or the manufacturer's EU declaration of conformity.
No. A declaration, specification, or test report provided by the packaging material supplier may be used as part of the manufacturer's conformity assessment and technical documentation. However, the final EU Declaration of Conformity must be drawn up by the packaging manufacturer in its own name.
If a company resells, without modification, a packaged product marketed under another company's name or trademark, the distributor is not required to draw up a new EU declaration of conformity. In such cases, the distributor may rely on the manufacturer's EU declaration of conformity.
However, where a company markets a packaged product under its own name or trademark, it will generally be considered the manufacturer and must draw up the EU declaration of conformity in its own name.
No separate mandatory template has been prescribed for the EU declaration of conformity. However, the declaration must contain all information required under Annex VIII of the PPWR.
The declaration must clearly and unambiguously identify:
- the manufacturer;
- the packaging or packaging type covered by the declaration;
- the specific requirements with which compliance is being declared;
- the person who has signed the declaration on behalf of the manufacturer; and
- the date on which the declaration was issued.
Where relevant, the declaration should also refer to the standards applied and any technical specifications used to demonstrate compliance.
No. The EU declaration of conformity is drawn up for the packaging unit as a whole, not for each individual packaging component separately.
Declarations and technical documentation provided by suppliers of individual packaging components may be used as part of the manufacturer's technical documentation. The manufacturer must assess the compliance of the entire packaging unit on the basis of that information.
Accordingly, the manufacturer remains responsible for evaluating how the individual components function together and for ensuring that the packaging unit as a whole complies with the applicable requirements of the PPWR.
The declaration must be reviewed and updated whenever there is a change to the packaging, its intended use, or the applicable requirements that may affect the accuracy of the declaration.
An update may be required, for example, where there is a change to:
- the packaging material or composition;
- a significant packaging component;
- the supplier and, consequently, the characteristics of the material supplied;
- the packaging design, structure or dimensions;
- the intended use of the packaging;
- the packaged product;
- an applicable legal requirement; or
- the outcome of the conformity assessment.
If the relevant characteristics of the packaging remain unchanged, the declaration does not need to be reissued merely because time has passed.
No. The PPWR does not automatically require a separate laboratory analysis for every item of packaging or every packaging batch.
Laboratory testing may be necessary in particular where:
- the full composition of the packaging is not known;
- the supplier’s statement is too general or lacks sufficient detail;
- recycled material is used;
- functional coatings, printing inks, adhesives, or other substances are used and insufficient information is available regarding their composition;
- the available data are incomplete or contradictory; or
- the risk assessment indicates that reliance on documentation alone is not sufficient.
Where no laboratory testing is carried out, the technical documentation should describe the alternative evidence used and explain why that evidence is considered sufficient to demonstrate compliance.
The European Commission is preparing guidance on the implementation of the PFAS requirements laid down in the PPWR, including guidance on demonstrating compliance. The type of evidence required depends on whether PFAS substances have been intentionally added to the packaging or its material.
- If PFAS substances have not been intentionally added, this should be stated in the compliance documentation, and compliance with the applicable limit values should be assessed and documented based on the information available.
- If PFAS substances have been intentionally added, compliance must be demonstrated through calculations or laboratory analyses. Laboratory testing is not required where compliance can be reliably demonstrated through calculations based on sufficient and trustworthy data.
- If reliable information on the presence or intentional addition of PFAS substances is not available, laboratory analysis must be carried out to verify compliance.
Not always. A substance may be present in the packaging due to the raw materials used, recycled content, printing inks, adhesives, varnishes, coatings, or contamination arising from the manufacturing process. The manufacturer must assess the packaging as a whole.
Where the supplier has sufficient, reliable and verifiable information on the composition of the packaging, the raw materials used and the manufacturing process, and that information is adequate to demonstrate compliance with the applicable requirements, a supplier’s declaration may constitute sufficient supporting evidence.
However, the ultimate responsibility for demonstrating compliance remains with the manufacturer, who must be able to justify and substantiate compliance with appropriate documentation if requested to do so.
The decisive factor is not only the date on which the packaging was manufactured, but also the date on which the packaging or packaged product was first made available on the European Union market.
If the packaging or packaged product had already been supplied to a legally independent distributor or retailer before 12 August 2026, it may be considered to have been placed on the market before the general application date of the PPWR.
By contrast, where the goods were merely stored in the manufacturer's own warehouse or held by a logistics service provider, this does not in itself mean that the goods had been placed on the market.
Companies are advised to retain contracts, invoices, delivery documents and batch records that can demonstrate when the packaging or packaged product was placed on the market.
Each case must be assessed on the basis of its specific facts and circumstances.
The requirements of the PPWR do not replace other legislation applicable to packaging. Packaging intended to come into contact with food must comply simultaneously with both the PPWR and the rules governing food contact materials.
Where compliance documentation is required under more than one piece of European Union legislation for the same packaging, an economic operator may use a single document or several documents, provided that compliance with each applicable legal act and the relationship between the documents are clearly and unambiguously identifiable.
For information on food contact material requirements and the related declarations and compliance documentation, companies should contact the Agriculture and Food Board (Põllumajandus- ja Toiduamet).
The manufacturer is responsible for ensuring that the packaging complies with the requirements of the PPWR, including requirements relating to packaging design, labelling, sustainability, and the preparation of the EU Declaration of Conformity.
The producer, on the other hand, is responsible for financing the collection and management of packaging waste in the Member State where the packaging becomes waste under the extended producer responsibility (EPR) scheme.
Therefore, the roles of manufacturer and producer may be fulfilled by different economic operators.
Packaging Requirements
The PPWR establishes requirements for packaging aimed at reducing the environmental impact of packaging and packaging waste throughout their entire life cycle. The Regulation promotes the prevention of excessive packaging, the reuse of packaging, and high-quality recycling, while also increasing the use of recycled materials in new packaging.
In addition, the PPWR introduces measures to reduce both the use and concentration of substances of concern in packaging materials and packaging components. In doing so, it seeks to reduce risks to human health and the environment and to support a safer circular economy.
Frequently Asked Questions
Packaging placed on the market shall be manufactured in such a way that the presence and concentration of substances of concern in packaging material or packaging components is minimised, including their presence in emissions and waste management residues such as secondary raw materials, ash or other material destined for final disposal. The adverse environmental impact of microplastics should also be minimised.
By 31 December 2026, the Commission, with the assistance of the European Chemicals Agency (ECHA), shall prepare a report on the presence of substances of concern in packaging and packaging components in order to determine the extent to which they negatively affect the re-use and recycling of materials or impact chemical safety.
From 12 August 2026, food-contact packaging shall not be placed on the market if it contains per- and polyfluorinated alkyl substances (PFAS) in a concentration equal to or above the following limit values, to the extent that the placing on the market of packaging containing such a concentration of PFAS is not prohibited pursuant to another Union legal act:
- 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded from quantification);
- 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors (polymeric PFAS excluded from quantification); and
- 50 ppm for PFASs (including polymeric PFAS); if total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user as defined respectively in Article 3, points (9), (11) and (13) of Regulation (EC) No 1907/2006 shall, upon request, provide to the manufacturer or the importer as defined respectively in Article 3(1), points (13) and (17), of this Regulation proof of the quantity of fluorine measured as content of either PFAS or non-PFAS in order for them to draw up the technical documentation referred to in Annex VII to this Regulation.
From 1 January 2030, all packaging placed on the market shall be recyclable. Packaging is considered recyclable if it fulfils the following conditions:
- The packaging is designed for material recycling, enabling the use of resulting secondary raw materials of sufficient quality to substitute primary raw materials. Only packaging that complies with these design-for-recycling requirements may be placed on the market from 1 January 2030.
- When it becomes waste, the packaging can be separately collected, sorted into specific waste streams without affecting the recyclability of other waste streams, and recycled at scale in accordance with the methodology established under Article 6(5). Only packaging meeting these conditions may be placed on the market from 1 January 2035.
By 1 January 2028, the European Commission will adopt a delegated act establishing design-for-recycling criteria and recyclability performance grades (A, B and C) for different packaging categories.
From 1 January 2030, only packaging achieving at least performance grade A, B or C may be placed on the market. From 1 January 2038, only packaging achieving at least performance grade A or B may be placed on the market. Packaging falling below these thresholds may no longer be placed on the market.
By 1 January 2030, any plastic part of packaging placed on the market shall contain the following minimum percentage of recycled content recovered from post-consumer plastic waste, calculated as an annual average per manufacturing plant for each packaging format and category referred to in Annex II, Table 1:
- 30% for contact-sensitive packaging whose main component is polyethylene terephthalate (PET), except single-use plastic beverage bottles;
- 10% for contact-sensitive packaging made from plastic materials other than PET, except single-use plastic beverage bottles;
- 30% for single-use plastic beverage bottles;
- 35% for plastic packaging other than the packaging referred to in points 1, 2 and 3.
By 1 January 2040, any plastic part of packaging placed on the market shall contain the following minimum percentage of recycled content recovered from post-consumer plastic waste, calculated as an annual average per manufacturing plant for each packaging format and category referred to in Annex II, Table 1:
- 50% for contact-sensitive packaging whose main component is PET, except single-use plastic beverage bottles;
- 25% for contact-sensitive packaging made from plastic materials other than PET, except single-use plastic beverage bottles;
- 65% for single-use plastic beverage bottles;
- 65% for plastic packaging other than the packaging referred to in points 1, 2 and 3.
The requirements set out above do not apply:
a) to plastic packaging intended for contact with food where the use of recycled content would pose a risk to human health or result in non-compliance of the packaged product with Regulation (EC) No 1935/2004;
b) to plastic parts representing less than 5% of the total weight of the packaging unit.
From 12 February 2028, fruit and vegetable stickers and permeable tea bags, coffee pods or other beverage sachets shall be compostable. These products shall comply with the standard for composting under industrially controlled conditions in bio-waste treatment facilities and, where required by Member States, also comply with home-composting standards referred to in paragraph 6 of this Article.
By 12 February 2028, packaging other than that referred to above and permitted to be composted together with bio-waste, including non-permeable single-serve tea, coffee or other beverage units used in machines, very lightweight plastic carrier bags, lightweight plastic carrier bags, and other packaging for which a Member State has required compostability, including packaging made from biodegradable plastic polymers and other biodegradable materials, shall be designed for recycling in accordance with Article 6 and without adversely affecting the recyclability of other waste streams.
By 1 January 2030, the manufacturer or importer shall ensure that packaging placed on the market is designed so that its weight and volume are reduced to the minimum necessary to ensure its functionality, taking into account the packaging's shape and the material from which it is made.
The manufacturer or importer shall ensure that packaging that does not comply with the assessment criteria set out in Annex IV of the Regulation is not placed on the market. The same applies to packaging features designed solely to increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers.
These restrictions do not apply where the packaging design is protected under the relevant Union legislation on industrial property rights or where the packaging is associated with a protected geographical indication.
From 12 August 2028, packaging placed on the market shall bear a harmonised label containing information on its material composition in order to facilitate consumer sorting and disposal.
The same label, or a corresponding label, shall also be affixed to waste collection containers, enabling consumers to match packaging with the appropriate collection stream.
The European Commission shall adopt an implementing act specifying the requirements and criteria for the harmonised labelling system.
The harmonised label shall also be applied to reusable packaging, enabling consumers and end users to identify the packaging and comply with the relevant reuse, return or disposal requirements.
Environmental claims relating to packaging placed on the market may be made only where they meet the following requirements:
The claims shall relate only to packaging characteristics that exceed the applicable minimum requirements laid down in the PPWR, in accordance with the criteria, methodologies and calculation rules established in the Regulation.
- The claims shall clearly specify whether they relate to:
- the entire packaging unit;
- a part of the packaging unit; or
- all packaging placed on the market by the economic operator.
By 1 January 2030, economic operators filling grouped packaging, transport packaging or e-commerce packaging shall ensure that the empty space ratio does not exceed 50%.
The empty space ratio is calculated as the proportion of empty space within the packaging, expressed as a percentage of the total package volume.
Empty space includes space filled with packaging materials such as paper shreds, air cushions, bubble wrap, foam, polyurethane foam, wood wool, polystyrene and expanded polystyrene (EPS) chips.
The purpose of this requirement is to prevent excessive packaging and ensure that packaging volume is limited to what is necessary for the protection, handling and transport of the packaged products.
From 1 January 2030, certain plastic packaging formats listed in Annex V of the PPWR may no longer be placed on the market:
- Single-use plastic grouped packaging, including shrink wrap and stretch wrap used to group products.
- Pre-packaged fresh fruit and vegetables weighing less than 1.5 kg, including packaging such as nets, bags, trays and containers.
- Single-use plastic packaging for food and beverages filled and consumed on the premises in the HORECA sector, including retail settings, such as trays, disposable plates, cups, bags and boxes.
- Single-use plastic packaging for condiments, preserves, sauces, coffee creamer, sugar and similar products provided for on-site consumption in the HORECA sector, including sachets, cups, trays and containers.
- Single-use packaging provided for individual use by guests in the accommodation sector, including shampoo bottles, hand and body lotion bottles and soap wrappers.
- Very lightweight plastic carrier bags for loose food, except where their use is necessary for hygiene purposes or to prevent food waste.
These restrictions are intended to prevent avoidable packaging waste and promote more sustainable packaging solutions and reuse systems.
From 12 February 2027, final distributors in the HORECA sector shall enable consumers to bring their own containers for the refill of cold or hot beverages and prepared food intended for takeaway. Consumers shall be informed of this possibility at the point of sale.
From 12 February 2028, final distributors in the HORECA sector shall offer consumers the possibility to purchase cold or hot beverages and prepared food in reusable packaging that forms part of a reuse system. Consumers shall likewise be informed of this option at the point of sale.
In both cases, products shall not be sold at a higher price or under less favourable conditions than the same products sold in single-use packaging.
From 1 January 2030, final distributors shall endeavour to offer at least 10% of their products in reusable packaging within reuse systems.
Member States may set more ambitious targets where this is necessary to achieve the waste prevention objectives set out in Article 43 of the PPWR.
Economic operators offering products through refill systems shall provide end users with up-to-date and easily accessible information on:
- the types of containers that may be used for refill;
- the hygiene requirements applicable to refill operations; and
- the end user’s responsibility for health and safety when using their own containers.
Single-use packaging shall not be provided free of charge for refilling.
From 1 January 2030, final distributors with a sales area exceeding 400 m² shall endeavour to allocate 10% of that sales area to refill stations, for both food and non-food products.
Member States shall take measures to achieve a sustained reduction in the consumption of lightweight plastic carrier bags within their territory.
The reduction shall be considered sustained where the annual consumption does not exceed 40 lightweight plastic carrier bags per person, or an equivalent target expressed by weight, by 31 December 2025 and by 31 December of each subsequent year.
To achieve this objective, Member States may introduce measures such as:
- restrictions on placing lightweight plastic carrier bags on the market; and
- economic instruments, including charges or fees applied to such bags.
The aim of these measures is to reduce resource consumption, littering and packaging waste generated by lightweight plastic carrier bags.
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Last updated: 12.10.2026
