Regulation (EU) 2025/40, known as the PPWR (Packaging and Packaging Waste Regulation), entered into force on 11 February 2025 and will be fully applicable from 12 August 2026. It replaces the previous Directive 94/62/EC and introduces a harmonised regulatory framework for all Member States, with clear objectives: reducing the environmental impact of packaging, increasing recyclability, promoting reuse, and harmonising rules within the internal market.
The novelty and complexity of its provisions immediately raised many questions from economic operators, manufacturers, importers, and national authorities. The Commission responded with a guidance document covering 33 interpretative clarifications on some of the most debated aspects of the Regulation.
Key Points of the Regulation
- Definition of Packaging
The definition of packaging set out in Article 3 of the PPWR is the starting point. The guidance provides practical examples such as: flower pots, dust covers, pre-filled syringes and intravenous infusion bags, candle containers, and more.
The distinction is not always straightforward, and the document clarifies that Annex I to the Regulation is merely indicative: classification must always be verified against the regulatory definition.
- Manufacturer and Producer
The PPWR precisely distinguishes two roles with different responsibilities:
The manufacturer is the party who designs or has packaging produced under their own name or brand. They are responsible for technical compliance and declarations of conformity (sustainability requirements and labelling). There is one single manufacturer per packaging item at EU level.
The producer is the party who places the packaging on the market of a Member State for the first time. They are responsible for Extended Producer Responsibility (EPR) obligations: registration, reporting, and payment of contributions for waste management in the country where the packaging becomes waste.
For micro-enterprises that have packaging produced under their own brand, the manufacturer’s responsibility falls on the packaging supplier, provided that the supplier is located in the same Member State.
- PFAS Restrictions in Food-Contact Packaging
From 12 August 2026, food-contact packaging may not be placed on the market if it contains PFAS substances in concentrations exceeding the limits set by Article 5(5) of the PPWR. No transitional period is provided for the disposal of stock produced before that date.
The guidance recommends a cascaded approach for compliance testing:
- Quantification of Total Fluorine (TF): if below 50 mg/kg, the sample may be considered compliant.
- If above, analysis to distinguish organic fluorine (PFAS) from inorganic fluorine.
- Direct TOP analysis to verify specific concentration limits.
- Key Deadlines
| Deadline | Obligation |
|---|---|
| 12 August 2026 | General PPWR application; PFAS ban in food-contact packaging; recyclability obligation |
| 12 August 2028 | Harmonised EU labelling |
| 1 January 2029 | Establishment of DRS and 90% collection target |
| 1 January 2030 | Packaging minimisation; reuse targets; ban on single-use plastic packaging in HORECA; design for recycling (if delegated act adopted by 2028) |
| 1 January 2035 | Recyclability “at scale” |
What Does This Mean for Companies?
PPWR compliance is a structured process that requires cross-disciplinary expertise: regulatory, analytical, and certification.
Analytical supports companies at every stage of this journey: in verifying PFAS limits on food-contact packaging, in recyclability assessments, in providing guidance on international standards and regulations, and in testing procedures for the supply chain.
Our Team is available to support you throughout this process.