EU PPWR Compliance: Packaging Testing, Recyclability and Documentation

The EU PPWR (Regulation (EU) 2025/40) governs packaging across its entire lifecycle. It covers all packaging and packaging waste, whatever the material or origin, and sets requirements for the manufacturing, composition and reusable or recoverable nature of packaging placed on the EU market. It replaces Directive 94/62/EC, the Packaging and Packaging Waste Directive.

As a Regulation, the PPWR applies in all Member States without transposition, harmonizes product rules and adds recycled content quotas, recyclability grading and mandatory Declarations of Conformity.

All packaging and packaging waste is covered, regardless of material or origin – sales, grouped, transport, service and e-commerce packaging, plus packaging components. Exclusions include packaging that is integral to the product and certain industrial packaging. Scope extends to manufacturers, importers, distributors, retailers, online marketplaces and fulfillment service providers, whether packaging is EU-made or imported, B2B or B2C, empty or filled – including businesses that fill, brand, import or place packaging sourced from a third-party supplier.

The PPWR entered into force on February 11, 2025 and generally applies from August 12, 2026. From that date, obligations include a mandatory Declaration of Conformity (DoC) plus technical documentation per packaging type, limits on PFAS in food contact materials and on heavy metals, packaging minimization, basic recyclability, and verification of producer compliance data via an online platform. Labeling, recyclability grades, recycled content quotas, minimization, reuse targets and empty space requirements phase in from 2027 onwards.

From August 12, 2026, manufacturers must prepare a written EU DoC for all packaging and packaging materials placed on the EU market, supported by a technical file per packaging type covering, at minimum: packaging description and design information, standards and specifications, compliance assessments and substance evidence, the EU DoC, and EPR registration and labeling proofs. Documentation must be retained for at least five years for single-use packaging, or ten years for reusable packaging, and made available to regulators on request.

The sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg. For food contact packaging, from August 12, 2026, individual target PFAS cannot exceed 25 ppb, the sum of targeted PFAS cannot exceed 250 ppb, and total PFAS cannot exceed 50 ppm. Existing EU food contact and food safety laws continue to apply alongside these limits.

Recyclability is graded from A (≥95%) to E, based on the proportion of the packaging unit, by weight, that can be effectively recycled. From January 1, 2030, packaging needs to be at least grade C (≥70%) to be placed on the EU market; from 2038, grade B (≥80%). Minimum recycled content targets apply to most plastic packaging from 2030, with traceability and verifiable documentation required.

From January 1, 2030, packaging weight and volume must be reduced to the minimum necessary for protection, hygiene and safety, with features designed to increase perceived product volume prohibited. From the same date, e-commerce packaging is limited to a maximum empty space ratio of 50%. From August 12, 2028, packaging must carry a harmonized, pictograph-based label showing its composition, and from February 12, 2029, reusable packaging must be labeled as reusable and carry a QR code providing collection point information.

The manufacturer of the packaging or packaged product carries the main responsibility – assessing conformity, preparing technical documentation and drawing up the EU DoC. Importers and distributors must verify these, and count as manufacturers if they sell under their own brand or modify packaging in a way that affects compliance. Under extended producer responsibility (EPR), producers bear financial responsibility for their packaging's entire lifecycle, including collection, storage, recycling and disposal, with fees modulated by recyclability, recycled content, reusability and substances of concern.

Our PPWR gap analysis and readiness assessment reviews your products, identifies gaps and advises on corrective actions – typically a few weeks for a small, single-market range, and longer for multi-brand or multi-country portfolios, or where testing, supplier data or redesigns are needed. We provide compliance evidence through PFAS and heavy metal testing, recyclability and design assessment, reusability and durability testing, minimization studies and compostability testing, and we verify recycled content and recyclability claims via recycled content, EN 15343 and RecyClass certification. To get started, take a packaging inventory, identify your business's role, request supplier evidence for each packaging type, prioritize high-risk packaging for PFAS and heavy metals, and prepare a compliance pack per packaging type.