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Compliance GuideUpdated Feb 2026

PPWR & EPR Guide: EU Packaging Compliance Explained

Everything you need to know about the EU Packaging and Packaging Waste Regulation (PPWR) and Extended Producer Responsibility (EPR). Understand the requirements, key dates, and how to prepare your business.

Quick Summary

What is PPWR?

The Packaging and Packaging Waste Regulation is EU legislation that sets requirements for all packaging placed on the EU market. It covers recyclability, recycled content, labelling, and waste reduction.

What is EPR?

Extended Producer Responsibility makes producers financially responsible for the end-of-life management of their packaging. Fees are modulated based on packaging sustainability.

Key Compliance Dates

PPWR requirements phase in over 12 years. Here are the milestones you need to know.

2026

PPWR Applies

Aug 12, 2026
  • Regulation enters into force
  • EPR reporting begins
  • PFAS limits in food contact packaging
  • Heavy metals concentration limits
2028

Design for Recycling

Jan 1, 2028
  • DfR criteria published
  • Recyclability assessment methodology
  • Labelling requirements apply
2030

Full Enforcement

Jan 1, 2030
  • Grade C+ recyclability required
  • Recycled content targets (30% PET, 10% other)
  • Packaging bans take effect
  • Reuse targets begin
  • 5% waste reduction vs 2018
2035

Recycled at Scale

Jan 1, 2035
  • 55% recycling rate threshold
  • 10% waste reduction vs 2018
  • Higher recycled content targets
2038

Grade B Required

Jan 1, 2038
  • 80%+ recyclability mandatory
  • Grade D packaging phased out

Start preparing now

While some detailed rules won't be finalised until 2028, the core requirements are clear. Companies that start now will have time to test alternatives and optimise their packaging portfolio.

PPWR Requirements Explained

The regulation covers six main areas. Here's what each means for your packaging.

Recyclability

All packaging must be designed for recycling with performance grades A-D

  • Grade A: Fully recyclable, high-quality output
  • Grade B: Recyclable with minor limitations
  • Grade C: Recyclable with significant limitations
  • Grade D: Not recyclable (phased out by 2038)
  • EPR fees modulated based on recyclability grade
Recycled Content

Minimum recycled plastic content targets for different packaging types

  • 30% for PET contact-sensitive packaging (2030)
  • 10% for other contact-sensitive packaging (2030)
  • 30% for single-use plastic beverage bottles (2030)
  • 35% for other plastic packaging (2030)
  • Higher targets from 2040
Packaging Minimisation

Packaging must be minimal in weight and volume for its function

  • No misleading packaging (double walls, false bottoms)
  • Maximum 50% empty space for transport/e-commerce
  • Standards for common packaging types
  • Exemptions for protected geographical indications
Labelling

Harmonised EU-wide labelling for consumer sorting

  • Material composition pictograms
  • Reusable packaging identification
  • Digital labels via QR codes allowed
  • DRS packaging labels
  • Recycled content claims (voluntary)
Packaging Bans

Certain single-use plastic packaging formats banned from 2030

  • Single-use plastic grouped packaging
  • SUP for unprocessed fresh fruit/vegetables
  • SUP for HORECA food and beverages consumed in situ
  • SUP condiment sachets in HORECA
  • SUP hotel miniatures
  • Very lightweight plastic carrier bags
Reuse & Refill

Targets for reusable packaging in specific sectors

  • Transport packaging: 40% reuse by 2030 (B2B within EU)
  • Beverage packaging: 10% reuse by 2030 (final distributors)
  • HORECA: Reusable options required from 2029
  • Refill stations encouraged (10% of sales area >400m²)

Extended Producer Responsibility (EPR)

EPR makes producers financially responsible for packaging waste management. Here's what you need to know.

Who is responsible?

The 'producer' under PPWR is any manufacturer, importer, or distributor who first makes packaging available on an EU Member State market. This includes online marketplaces.

Registration requirements

Producers must register with EPR schemes in each EU market where they place packaging. An authorised representative is required for non-EU producers.

Fee modulation

EPR fees will be modulated based on recyclability grade, recycled content, and other sustainability criteria. Better packaging = lower fees.

Reporting obligations

Detailed reporting on packaging volumes, materials, and types. Greater granularity required unless placing <10 tonnes on market.

EPR Fee Modulation Factors

Recyclability Grade

Higher grades = lower fees

Recycled Content

More recycled = lower fees

Reusability

Reusable = potential discounts

Your Compliance Checklist

Use this interactive checklist to track your PPWR preparation progress.

PPWR Readiness Checklist

Track your compliance preparation

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