Key Milestones of the EU Packaging and Packaging Waste Regulation (PPWR)

Since its publication in the Official Journal on 22 January 2025, Regulation (EU) 2025/40 (“PPWR”) has set a clear, phased timeline to transform packaging across the EU into sustainable, circular‐economy–friendly materials. From strict chemical limits and the first reusable packaging standards to binding recycled‐content requirements and “recycled at scale” targets, the PPWR charts a path from 12 August 2026 through 2035. Below, we highlight the Regulation’s most critical deadlines—organized by year—and the concrete obligations they impose on industry, Member States, and the European Commission.

 

By 2026

• PFAS limits for food‐contact packaging (Article 5): From 12 August 2026, food‑contact packaging may not be placed on the EU market if it contains any individual PFAS above 25 ppb, the sum of PFAS above 250 ppb, or total fluorine (including polymeric PFAS) above 50 ppm.
• Heavy‑metals content limit (Article 5): The combined concentration of cadmium, lead, mercury, and hexavalent chromium in any packaging or component must remain below 100 mg/kg of material.
• Commission report on substances of concern: By 31 December 2026, the Commission—assisted by ECHA—must report on the presence of substances of concern (including PFAS and heavy metals) in packaging and their impact on reuse and recycling.

 

By 2027

• Standards for packaging minimization (Article 10): By 12 February 2027, the Commission is empowered to request European standardization bodies to define maximum packaging weights, allowed empty‐space ratios, wall thicknesses for rigid packaging, and other minimization parameters.
• Reusable packaging cycle thresholds (Article 11): By 12 February 2027, the Commission must adopt a delegated act specifying minimum numbers of reuse cycles for packaging to qualify as “reusable.” Packaging placed on the market from 11 February 2025 is deemed reusable if it meets these conditions.

 

 

By 2028

• Design for Recycling (DfR) guidelines (Article 6): By 1 January 2028, the Commission will adopt delegated acts detailing DfR criteria—recyclability grades (A/B/C) based on Annex II Table 3—and methodologies to assist industry in designing packaging that meets the 2030 recyclability threshold.

 

By 2029

• Deposit‑Return Schemes (Article 50): By 1 January 2029, Member States must set up deposit‑return systems for single‑use plastic bottles and metal beverage containers (≤ 3 L capacity). Exemptions apply to wine, spirits, milk products, and products consumed on HORECA premises, or if a Member State already collects over 90 % by weight.

 

By 2030 —Critical Milestones

• Mandatory Design for Recycling (Article 6): All packaging placed on the market must comply with the DfR criteria and achieve a recyclability performance grade A, B or C (≥ 70 % recyclability per unit by weight). Anything below C is not considered recyclable.
• Minimum recycled‐content targets – PCR (Article 7):
  • Contact‑sensitive PET (food/cosmetics): ≥ 30 % recycled content
  • Contact‑sensitive non‑PET plastics (e.g., PP, HDPE): ≥ 10 %
  • Other plastic packaging (e.g., industrial goods): ≥ 35 %
• Packaging minimization enforcement (Article 10): Excess packaging must be eliminated per the technical parameters defined by 12 February 2027.
• Per‑capita waste reduction (Article 43): Member States must achieve a 5 % reduction in packaging waste per capita compared to 2018.
• Transport‑packaging reuse (Article 29): At least 40 % of transport‑assisting packaging (e.g., drums, crates, pallet wraps) must be reusable.
• Extended Producer Responsibility modulation (Article 46): EPR fees will be eco‑modulated based on recyclability performance grades and recycled content percentages.
• Delegated acts for “Recycled at Scale” (Article 53): The Commission will, by 1 January 2030, adopt acts defining the methodology for assessing “recycled at scale”—to be fully implemented by 1 January 2035.

 

 

By 2035

• Recycled at Scale (Article 53): All packaging categories must achieve separate collection, sorting, and recycling in “state‑of‑the‑art” infrastructure proven in operational environments across at least 75 % of the EU population.
• Per‑capita waste reduction (Article 43): Member States must achieve a 10 % reduction in packaging waste per capita compared to 2018.

Conclusion

By following this phased roadmap—from strict chemical restrictions in 2026 to binding recyclability, recycled-content, reuse, and waste‑reduction targets by 2030 and “recycled at scale” requirements by 2035—the PPWR aims to harmonize packaging across the Single Market, dramatically cut environmental impacts, and lock in circular‑economy practices for decades to come.

You can find more information on the official publication of the PPWR by the EU.