EU PPWR Compliance Services - European Union - Chemicals

On January 22, 2025, the European Union officially published the Packaging and Packaging Waste Regulation (EU) 2025/40, also known as PPWR. This regulation was published in the official journal of the European Union on January 22, 2025, entered into force on February 11, 2025 and generally applies from August 12, 2026. It establishes the EU's new legal framework for packaging and packaging waste and will replace Directive 94/62/EC.

PPWR introduces requirements across the packaging life cycle, including substances of concern, recyclability, recycled plastic content, packaging minimisation, labeling, reuse, and waste management. It also makes post-consumer recycled plastic content a mandatory requirement for certain packaging categories, with phased targets applying from 2030 and increasing again from 2040.

Who Needs to Comply with PPWR?

1. Relevant Economic Operators

Any entity placing packaging or packaged products on the EU market—via either online or offline channels—must assess its PPWR compliance obligations based on its role in the supply chain and the applicable national implementation rules. This applies to:

Manufacturers
Importers
Distributors and Retailers
- Brand owners
- Online retailers and cross-border exporters

2. Covered Products

The PPWR applies to packaging and packaging waste of all material types (including plastics, paper, metal, glass, and composite materials) across all applications (such as industrial, commercial, consumer, and logistics/transport packaging).

Key PPWR Compliance Requirements

1. Extended Producer Responsibility (EPR)

Enterprises may need to complete the registration, reporting, and fee-payment process and obtain a valid EPR registration number in each EU member state where their products are sold, depending on their role, product flow, and local country requirements. Packaging EPR specifically targets packaging materials like paper, plastic, metal, and glass.

From August 12, 2026, PPWR generally applies across the EU, while packaging EPR obligations continue to be implemented through member state systems (e.g., DSD/LUCID in Germany, ADEME in France). For companies placing packaged goods on EU markets, non-compliance can create serious commercial and market-access risks, including sales restrictions, take-down requests, enforcement action, and disruption of market entry.

2. Hazardous Substance Restrictions: Heavy Metals & PFAS

Heavy Metals: The total concentration of Lead, Cadmium, Mercury, and Hexavalent Chromium must not exceed 100 mg/kg. This limit remains a core packaging requirement under the PPWR.

PFAS Controls (Effective from August 12, 2026, for food-contact packaging):

Non-polymeric (measured monomeric) PFAS: ≤ 25 parts per billion (ppb)
Total non-polymeric PFAS (sum of monomers): ≤ 250 ppb
Total fluorine content in polymeric PFAS: ≤ 50 ppm (If total fluorine exceeds this threshold, technical documentation and proof of compliance must be provided).

3. Recyclability Requirements: From Design to Market Access

By January 1, 2030: All packaging placed on the EU market must be recyclable and achieve a Recyclability Performance Grade of A, B, or C (higher or equal to 95%, 80%, or 70% recyclability per unit, respectively).
By January 1, 2038: Only Grade A and Grade B recyclable packaging will be permitted to enter the EU market.

In addition, from January 1, 2035, recyclability assessment will also incorporate whether packaging is effectively recycled at scale.

4. Recycled Content Mandates for Plastics

To drive a circular economy, the PPWR introduces strict, legally binding targets for post-consumer recycled (PCR) plastic content:

Single-use plastic beverage bottles: ≥ 30% PCR content by 2030; ≥ 65% by 2040.
Contact-sensitive packaging made from PET (excluding single-use bottles): ≥ 30% by 2030; ≥ 50% by 2040.
Contact-sensitive packaging made from plastic materials other than PET (excluding single-use bottles): ≥ 10% by 2030; ≥ 25% by 2040.
Other plastic packaging: ≥ 35% by 2030; ≥ 65% by 2040.

Additionally, the EU will review the technical performance of bio-based plastic packaging and establish sustainability requirements for bio-based feedstocks by February 12, 2028.

5. Compostability Requirements

PPWR also introduces a more harmonised framework for compostable packaging and related technical specifications:

By February 12, 2026: The EU will establish harmonized technical specifications for compostable packaging.
By February 12, 2028: Compostable packaging (including biodegradable plastics) must prioritize material recycling designs and must not negatively impact the recyclability of other waste streams.

6. Packaging Minimization Requirements

By February 12, 2027: The EU will establish methodologies and standards to minimize packaging (limiting maximum weight, volume, wall thickness, and empty space).
By January 1, 2030: Manufacturers and importers must ensure packaging weight and volume are reduced to the absolute minimum required for functionality. Deceptive designs, such as false bottoms or redundant double-layering, will be strictly prohibited.

For grouped packaging, transport packaging, and e-commerce packaging, the maximum empty space ratio will be 50% from 1 January 2030.

7. Labeling Requirements

Packaging will be subject to harmonised labeling requirements under PPWR, including rules intended to support sorting, reuse, and consumer information. Furthermore, starting from February 2, 2029, reusable packaging must feature a QR code label for tracking and reuse instructions.

Compliance Timeline

PPWR is a long-term shift in EU packaging regulation and a major market-access issue for businesses placing packaged goods on the EU market. For affected businesses, non-compliance can result in enforcement risk, restricted market access, corrective actions, and commercial disruption.

For global companies exporting to the European Union, compliance is a matter of market access and business continuity. With the enforcement deadline approaching rapidly, CIRS Group recommends that enterprises immediately audit their product lines against these requirements, optimize packaging designs, and secure supply chain transparency ahead of time to safeguard their EU market access.

How CIRS Group Supports Your PPWR Compliance

CIRS Group provides end-to-end, full-lifecycle compliance services for the EU PPWR to support businesses working through these requirements, including:

✅ Heavy metal & PFAS testing for packaging materials (backed by CNAS and CMA accreditations);

✅ Conformity assessment support & Declaration of Conformity (DoC) documentation assistance;

✅ EU packaging EPR registration across member states;

✅ Packaging recyclability assessments and optimization recommendations;

✅ Recycled content verification;

✅ Technical compliance Analysis for compostable packaging requirements;

✅ Tailored PPWR consulting and in-house regulatory Training services.

If you need support with EU PPWR compliance, please get in touch with us via service@cirs-group.com.

About CIRS

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

PPWR Compliance: Frequently Asked Questions for Industry

Q1: Do adhesives, coatings, and inks fall within the scope of recycled content requirements for plastic packaging?

A: Adhesives, coatings, and inks are not considered plastics under the PPWR and are therefore not subject to recycled content targets.

Q2: Is it available for packaging placed on the market prior to the application date of this Regulation or specific provisions continue to circulate?

A: In principle, packaging lawfully placed on the market prior to August 12, 2026, or before the application date of specific provisions (including existing inventory), may remain in circulation without requiring regulatory retrofit, withdrawal, or recall.

Q3: Manufacturers shall only place packaging on the market that complies with the requirements of Chapters V to XII. Does this obligation apply solely to packaging manufacturers?

A: (1) The legal obligation to place only compliant packaging on the market is not limited to manufacturers as defined in the Regulation; it equally applies to importers and distributors.

(2) The EU Declaration of Conformity (DoC) must be drawn up by the manufacturer—based on documents provided by packaging suppliers—or by an authorized representative duly designated via a written mandate.

(3) Irrespective of who actually drafts the EU DoC or any part thereof, the manufacturer remains solely and legally responsible for ensuring full compliance regarding the packaging's sustainability and labeling requirements.

Q4: Are suppliers required to affix serial numbers to simple packaging, such as plastic carrier bags?

A: The Regulation does not mandate suppliers to mark packaging with model, batch, or serial numbers; this obligation rests with the manufacturer. However, in practice, traceability markings are typically integrated during the manufacturing stage, meaning suppliers are often tasked with implementing these traceability requirements on the factory floor.

Q5: Are importers and distributors supplying packaging materials required to comply with the relevant requirements of this Regulation?

A: Material suppliers do not bear direct legal liability for compliance under this Regulation. However, downstream customers (manufacturers and importers) who place packaging and packaged products on the EU market must ensure that all packaging and packaging materials used comply with the regulatory requirements.

Q6: From when must economic operators fulfill the conformity assessment procedures specified under the PPWR?

A: (1) The Regulation generally applies from August 12, 2026. However, specific core provisions carry distinct application dates. The entry into force of several obligations depends on set periods following the adoption of relevant implementing or delegated acts, allowing adequate transition time for economic operators and Member States.

(2) Where no specific application date is otherwise stipulated for a provision, the general date of application applies—meaning enterprises must complete the required conformity assessment procedures before August 12, 2026.

Q7: What is the exact meaning of the "unique identification of the packaging" referred to in Annex VIII? Do standard product traceability details fulfill this requirement?

A: The Regulation does not explicitly define "unique identification of the packaging." As used in Annex VIII, the term refers to the requirement to individually identify the packaging itself by type, production batch, or serial number.

Q8: If packaging uses identical materials but comes in different sizes, is a separate Declaration of Conformity required for each size, or can a single Declaration cover all sizes?

A: (1) In accordance with Annex VII, manufacturers must draw up a written Declaration of Conformity for each packaging model, explicitly defining the covered scope. Technical documentation must demonstrate that the packaging satisfies the sustainability requirements in Chapters V to XII and be made available for conformity assessment purposes.

(2) The scope of a Declaration of Conformity is determined by whether the packaging shares uniform characteristics regarding applicable compliance mandates and its fit for the intended contained product. Consequently, if the contained products differ, manufacturers cannot use a single Declaration of Conformity to cover all packaged products placed on the market.

Q9: Does transport packaging also require a conformity assessment and a Declaration of Conformity?

A: Transport packaging enjoys no exemptions. Distinct categories of transport packaging—such as pallets, crate extensions (pallet collars), stretch wraps, and strapping—must each undergo an independent conformity assessment and be covered by separate Declarations of Conformity.

Q10: Are micro-enterprises exempt from Extended Producer Responsibility (EPR) obligations?

A: Neither the Packaging and Packaging Waste Regulation (PPWR) nor the Waste Framework Directive (Directive 2008/98/EC) provides no EPR exemption for micro-enterprises. Any producer placing packaged products on the market of a Member State for the first time is responsible for managing the corresponding packaging waste.