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Packaging and Packaging Waste Regulation (PPWR) 2025/40 Timeline

Phase Deadline Requirements Priority Actions
Phase 1
General Application 		12-Aug-2026 General application date across all EU member states:
  • Only compliant packaging can be placed on the EU market.
  • Producers must carry out conformity assessment procedures, prepare technical documentation, and issue EU declarations of conformity (Article 15).
  • Substances of Concern minimisation requirements apply.
  • Substance restrictions (Article 5) and compliance with limit values for substances of concern (e.g. lead, cadmium, mercury, chromium VI ≤100 mg/kg).
  • PFAS restrictions (Article 5) for food-contact packaging take effect.
  • Economic operators must comply with producer registration and Extended Producer Responsibility (EPR) obligations where applicable (Article 45).
 Ensure compliance documentation, PFAS restrictions, minimisation, and EPR obligations are in place.
Phase 2
Labelling and Information Requirements 		12-Aug-2028 Harmonised packaging labelling requirements take effect:
  • Packaging must be labelled with harmonised pictograms indicating material composition (sorting guidance). Where applicable, labelling of recycled content may also be required (Article 12).
 Update packaging artwork and labelling systems.
Phase 3
Circular Economy Requirements 		01-Jan-2029 Deposit Return Systems (DRS) (Article 50) must be established by Member States for:
  • Single-use plastic beverage bottles
  • Metal beverage containers up to 3 litres
 Prepare for DRS participation and collection obligations.
Phase 3
Circular Economy Requirements 		01-Jan-2030 Recyclability Requirements (Article 6):
  • Packaging must achieve at least a specified recyclability performance level.
  • Only packaging achieving recyclability grades A, B, or C may be placed on the market.
Recycled Content Targets (Article 7):
  • Mandatory minimum recycled-content requirements begin for various categories of plastic packaging. Higher targets will follow in 2040.
Packaging Minimisation (Articles 10 & 24):
  • Packaging designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality
  • Empty space in grouped, transport, and e-commerce packaging generally limited to a maximum of 50%.
Reuse Targets (Article 29):

Mandatory reuse and refill targets commence for specific sectors including:

  • Transport packaging.
  • Beverage packaging.
  • Certain commercial packaging formats.
 Meet recyclability, recycled-content, empty-space, and reuse-target requirements.
Phase 4
Recycling Infrastructure 		01-Jan-2035 Packaging must be shown to be “recyclable at scale”, meaning:
  • It is actually collected.
  • It is sorted.
  • It is recycled through established infrastructure at commercial scale across the EU.
 Demonstrate packaging is recyclable at scale.
Phase 5
Tightened Recyclability Standards 		2038
  • Only packaging achieving the higher Recyclability Grades A or B may be placed on the market.
  • Packaging meeting only Grade C standards will no longer be permitted.
 Achieve A or B recyclability grades only.
Phase 6
Long Term Targets 		2040
  • Enhanced recycled-content targets apply to plastic packaging, increasing the requirements first introduced in 2030.
 Meet final recycled-content targets.

Further resources on the Packaging and Packaging Waste Regulation:

EU Packaging and Packaging Waste Regulation (PPWR) 2025/40 Guidance

FAQs EU Packaging and Packaging Waste Regulation (PPWR) 2025/40

You can also purchase PPWR templates and checklists from our shop at Product Compliance Support.