EU PPWR Compliance Services

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.