What's Changing in Packaging Reporting
The EU's approach to packaging waste is undergoing its most significant transformation in three decades. The original Directive 94/62/EC[1] is being replaced by a new Regulation that fundamentally changes how businesses report on and manage their packaging obligations.
From Directive to Regulation
One harmonised framework replaces 27 national interpretations
More Data Points
Report recyclability grades, recycled content %, and conformity per packaging type
Standardised Formats
Uniform EPR registration and documentation across all Member States
When Do These Changes Apply?
The PPWR entered into force on 11 February 2025, but reporting requirements phase in over several years. Here are the key dates:
- 11 Feb 2025PPWR enters into force
- 12 Aug 2026General application begins; PFAS limits in food packaging
- 1 Jan 2028Commission adopts recyclability performance grades
- 1 Jan 2030Recyclability grades required; recycled content targets begin
- 1 Jan 2035All packaging must be recyclable at scale
- 1 Jan 2040Higher recycled content targets apply
The Fundamental Shift: What You Report
Under the old Directive, reporting was relatively simple: declare packaging volumes and materials for EPR fee calculation. The PPWR expands this significantly. You now report on the performance characteristics of each packaging type.
What You Reported
Aggregate totals at company level — e.g. '120 kg cardboard, 85 kg plastic placed on market this year'
- •Total packaging weight by material type
- •Aggregate volumes for EPR fee calculation
- •Basic producer registration (varied by country)
What You Report
Per packaging article — e.g. 'SKU-1234 cereal box: Grade B recyclability, 35% recycled content'
- Total packaging weight by material type (unchanged)
- Aggregate volumes for EPR fee calculation (unchanged)
- Recyclability performance grade (A/B/C) per packaging article
- Recycled content percentage per plastic packaging article
- PFAS concentration levels (food-contact packaging)
- Conformity declaration per packaging article
- Technical documentation proving compliance
- Standardised producer registration (EU-wide format)
The shift is clear: from reporting what you put on the market to proving each packaging type meets specific performance criteria.
The New Reporting Requirements in Detail
1. Recyclability Performance Grades
From 1 January 2030, you must report a recyclability grade for each packaging type. Packaging below Grade C (70% recyclability) cannot be placed on the market.[2]
Packaging recyclability shall be expressed in recyclability performance grades A, B or C... Grade A = higher or equal to 95%, Grade B = higher or equal to 80%, Grade C = higher or equal to 70%.
| Grade | Threshold | Meaning |
|---|---|---|
| Grade A | ≥95% | Fully recyclable, produces high-quality recyclate |
| Grade B | ≥80% | High recyclability, minor pre-treatment needed |
| Grade C | ≥70% | Minimum threshold to be considered recyclable |
Why this matters for reporting: EPR fees will be modulated based on your packaging's grade. Better recyclability = lower fees. You'll need documentation proving each packaging type's grade.
2. Recycled Content Percentage
For plastic packaging, you must report the percentage of recycled content from post-consumer waste. This requires tracking through mass balance accounting methods.[2]
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, per packaging type and format... calculated as an average per manufacturing plant and year.
| Plastic Packaging Type | Min. by 2030 | Min. by 2040 | Reference |
|---|---|---|---|
| Contact-sensitive PET packaging (excl. bottles) | 30% | 50% | Art. 7(1)(a), 7(2)(a) |
| Contact-sensitive other plastic (excl. bottles) | 10% | 25% | Art. 7(1)(b), 7(2)(b) |
| Single-use plastic beverage bottles | 30% | 65% | Art. 7(1)(c), 7(2)(c) |
| Other plastic packaging | 35% | 65% | Art. 7(1)(d), 7(2)(d) |
Why this matters for reporting: You need supplier documentation and chain-of-custody records proving recycled content percentages. This is a new data collection requirement for most businesses.
3. PFAS and Substances of Concern
From 12 August 2026, food-contact packaging must not exceed PFAS concentration limits. You must document and verify compliance.[2]
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...
Why this matters for reporting: You need test results or supplier declarations proving PFAS levels are below thresholds. This applies immediately when general application begins.
4. Standardised EPR Registration
The PPWR introduces standardised registration formats across all Member States. Before, each country had different registration requirements. Now, the Commission will establish uniform data requirements through implementing acts.[2]
Producers shall register in the register referred to in Article 44(1) in each Member State where they make packaging available on the market for the first time... The Commission shall adopt implementing acts establishing the format for registration and reporting.
Why this matters for reporting: If you sell in multiple EU countries, you'll use consistent registration formats instead of navigating 27 different systems. However, you still register in each Member State where you place packaging on the market.
Documentation You Must Maintain
The PPWR requires you to create and retain documentation proving compliance. This is a significant change from the old Directive, which had minimal documentation requirements for individual producers.[2]
The manufacturer shall keep the EU declaration of conformity and the technical documentation for 10 years after the reusable packaging has been placed on the market, or for 5 years after the single-use packaging has been placed on the market.
- EU Declaration of Conformity — a formal statement that your packaging meets PPWR requirements
- Technical documentation — evidence supporting recyclability grades, recycled content claims, and design compliance
- Supplier documentation — chain-of-custody records for recycled content, PFAS test results or declarations
- Retention periods: 10 years for reusable packaging, 5 years for single-use packaging
These documents must be available to enforcement authorities upon request. The practical implication: you need systems to collect, organize, and retain this data for each packaging type in your portfolio.
What This Means for Your Business
The PPWR fundamentally changes packaging reporting from a simple volume declaration to a comprehensive performance documentation system. You're no longer just reporting what you put on the market — you're proving how well each packaging type performs.
The upside: one harmonised framework across 27 Member States instead of navigating different national interpretations. The challenge: significantly more data to collect, document, and retain.
Start now: August 2026 is closer than it seems. Audit your packaging portfolio, identify gaps in recyclability and recycled content data, and establish documentation processes before the deadlines hit.
References
Last updated: March 2026. This page provides general guidance and should not be considered legal advice.