The European Union has taken an important step towards a circular economy with the adoption of Regulation (EU) 2025/40 on packaging and packaging waste (“PPWR”). This legislation, which repeals the long-standing Directive 94/62/CE, establishes a harmonized legal framework aimed at introducing new obligations that will reshape how packaging is designed, used, and managed across its entire lifecycle.

By moving from a Directive to a Regulation, the EU ensures that the new rules are directly applicable across all Member States, eliminating the legislative fragmentation that previously hindered the internal market and the achievement of environmental targets. The first measures provided for in the PPWR will be mandatory from August 2026.

The Core Pillars of PPWR

PPWR is built on several key pillars designed to prevent waste, promote circularity, and enhance the sustainability of packaging materials.

1. Waste Prevention and Reduction: At its core, PPWR introduces binding targets for the progressive reduction of packaging waste generated per capita in each Member State. In this regard, a significant measure is the restriction on placing certain formats of single-use packaging on the market, effective from January 1, 2030. This includes, among others, single-use plastic packaging for fresh fruits and vegetables, packaging for food and beverages consumed in restaurants, and miniature packaging for toiletries commonly found in hotels.
2. Promotion of Reuse and Refill: The legislation sets specific targets for reusable packaging in various sectors, trying to move away from a single-use culture. For instance, the takeaway food and beverage industry will be required to ensure that a growing percentage of their sales are provided in reusable packaging, with targets set at 10% by 2030 and increasing to 40% by 2040.
3. Boosting Recyclability and Recycled Content: To ensure that packaging waste is a valuable resource, PPWR mandates that all packaging placed on the EU market must be recyclable by 2030, according to specific design-for-recycling criteria. Furthermore, it establishes mandatory minimum targets for recycled content in new plastic packaging. For example, single-use plastic beverage bottles must contain at least 30% recycled content by 2030; such a figure rises to 65% by 2040. These measures are designed to drive demand for secondary raw materials, improve the quality of recycling processes, and reduce the EU’s reliance on virgin resources.
4. Extended Producer Responsibility (EPR) and Data Transparency: PPWR strengthens the principle of Extended Producer Responsibility (EPR), requiring producers to bear the financial and operational costs of collecting, recycling, and managing packaging waste. Each company must register with a national or transnational waste management system and provide detailed data on the volume of packaging placed on the market, its composition, and how it is ultimately disposed of. This data must be reported to competent authorities and, where requested, made available to consumers.

Focus: New Obligations on Labelling, Marking, and Information

A central component of the new regulatory framework is the overhaul of information requirements for packaging. The goal is to provide clarity for consumers, efficiency for waste operators, and transparency throughout the supply chain. The previous system, based on national interpretations and the now-repealed Commission Decision 97/129/CE, is being replaced by a more stringent approach.

• Harmonized Labelling for Waste Sorting: PPWR mandates the creation of a harmonized label to clearly indicate the material composition of packaging and provide instructions for its correct disposal. The European Commission is tasked with developing the specifications for this label, which will be uniform across the EU. This will help consumers to correctly sort packaging waste, thereby increasing the quantity and quality of materials sent for recycling and reducing contamination in waste streams.
• Digital Information and the Product Passport: To avoid the risk of overwhelming consumers with too many physical labels, PPWR encourages the use of digital tools. Information can be provided through a data carrier, such as a QR code, affixed to the packaging. This data carrier can link to a website or, more significantly, to a Digital Product Passport. This concept allows for a vast amount of information to be stored and accessed digitally. This includes details on material composition, reusability features, recycled content, and the presence of any substances of concern.
• Marking of Substances of Concern: To enhance safety and promote high-quality recycling, PPWR introduces an obligation to provide information on the presence of “substances of concern” in packaging materials. This information should be accessible via digital means, to ensure that waste managers can identify and handle these substances appropriately, thereby facilitating cleaner material cycles and protecting human health and the environment.

Outlook for Economic Operators

PPWR marks a key transition for all economic operators involved in the packaging value chain, from material manufacturers and producers to importers, distributors, and retailers. Compliance will require a proactive and strategic approach. Companies must review their packaging portfolios to assess their conformity with the new requirements for recyclability, reuse, and recycled content.

Furthermore, the new information and labelling obligations necessitate an update of data management systems to track and disclose the required information, particularly through digital channels.

Companies that will embrace these changes early will not only ensure compliance, but also gain a competitive advantage in a market that increasingly values sustainability.

Legal advisors will play a key role in helping clients understand the obligations, ensure compliance, and assess the risks associated with the transition to a more circular economy.