EU PPWR Explained: Key Packaging Requirements, Compliance Responsibilities and Implementation Timeline
EU PPWR Explained: Key Packaging Requirements, Compliance Responsibilities and Implementation Timeline
The European Union's Packaging and Packaging Waste Regulation (PPWR), formally known as Regulation (EU) 2025/40, is a major legislative framework governing packaging and packaging waste across the EU.
The Regulation was published on 22 January 2025, entered into force on 11 February 2025, and has applied since 12 August 2026. Compared with the previous Packaging and Packaging Waste Directive (94/62/EC), the PPWR establishes a more harmonised regulatory framework for packaging across EU Member States. Its requirements extend to packaging design, material composition, manufacturing, placing on the market, reuse and recycling.
For packaging manufacturers, brand owners, importers and packaging buyers, the PPWR introduces more specific environmental requirements and makes it increasingly important to review packaging design, supply chain documentation and product conformity.
This article examines the scope of the Regulation, business responsibilities, key regulatory requirements and implementation timeline. It also focuses on the potential impact of the PPWR on plastic packaging and apparel packaging.
1. What Is the PPWR and Why Has the EU Introduced It?
The PPWR is the EU regulation governing packaging and packaging waste. Its official title is:
Regulation (EU) 2025/40 on packaging and packaging waste.
The Regulation aims to reduce packaging waste, promote the circular use of packaging materials, minimise the environmental and human health impacts of packaging throughout its life cycle, and reduce regulatory differences between EU Member States.
How Does the PPWR Differ from Previous Packaging Legislation?
Previously, packaging and packaging waste were primarily regulated through the Packaging and Packaging Waste Directive (94/62/EC) and national legislation implemented by individual EU Member States. As a result, requirements concerning packaging, recycling systems and producer responsibility could differ between countries.
The PPWR takes the form of an EU Regulation, which is directly applicable across EU Member States and establishes a more harmonised framework for packaging regulation.
Its main changes include:
- Packaging Design: More specific requirements concerning packaging weight, volume, functionality and recyclability.
- Material Safety: Restrictions on certain substances in packaging, including PFAS in food-contact packaging.
- Recycled Content: Minimum post-consumer recycled plastic content targets for different categories of plastic packaging.
- Packaging Minimisation: Restrictions on unnecessary packaging weight, volume and empty space.
- Circular Economy: Measures to promote packaging recycling, reuse and improved waste management.
- Market Compliance: Requirements for relevant economic operators to fulfil their applicable technical documentation, conformity assessment and producer responsibility obligations.
It is important to understand that the PPWR does not simply replace every requirement of the previous Packaging and Packaging Waste Directive with a new set of rules on the same date. The Regulation establishes different transitional arrangements, and certain previous provisions may continue to apply during specific periods.
Official References:
Regulation (EU) 2025/40 – Official Legal Text | European Commission – PPWR
2. Which Businesses Are Affected by the PPWR, and What Are Their Responsibilities?
The PPWR covers packaging and packaging waste placed on the EU market. Packaging is not automatically excluded from its scope because it is made from plastic, paper, metal or another material.
However, different businesses have different legal roles within the supply chain and are therefore subject to different obligations.
| Business Category | Main Responsibilities |
|---|---|
| Manufacturer | Ensures that the packaging for which it is responsible meets applicable requirements, completes the relevant conformity assessment and prepares technical documentation and the EU Declaration of Conformity. |
| Supplier | Provides manufacturers with the information and documentation necessary to demonstrate compliance of packaging and packaging materials with applicable requirements. |
| Importer | Verifies that the manufacturer has completed the applicable conformity assessment and prepared the required technical documentation and labelling before placing packaging on the EU market. |
| Distributor | Fulfils applicable verification, storage, transport and supply chain cooperation obligations. |
| Producer | Fulfils applicable national registration, reporting and Extended Producer Responsibility (EPR) obligations in the relevant Member States. |
Important Distinction: Manufacturer Is Not the Same as Producer
These two terms are frequently confused under the PPWR.
Manufacturer
A manufacturer is not necessarily the factory that physically operates the production machinery.
Under Article 3 of the PPWR and the European Commission's implementation guidance, a business that has packaging or a packaged product designed or manufactured under its own name or trademark may be considered the manufacturer within the meaning of the Regulation.
For sales packaging, the responsible legal entity generally needs to be identified by considering the final processing, filling, branding and design decisions involved.
Producer
The term Producer is primarily associated with Extended Producer Responsibility (EPR). Producers are responsible for fulfilling applicable packaging waste management, registration and reporting obligations in the relevant Member States.
The Manufacturer and Producer may be the same legal entity, but they may also be different entities.
Therefore, a Chinese packaging factory supplying customised packaging to a European brand does not automatically assume all responsibilities associated with placing products on the EU market or fulfilling EPR obligations. Likewise, a brand owner cannot assume that it has no manufacturer-related responsibilities simply because a third party physically produces the packaging.
For Goolien's customers, it is important to identify the responsible parties for packaging design, branding, final processing, importation and placement on the market at an early stage.
Official References:
PPWR Article 3 – Definitions | Article 15 | Article 16 | Article 18 | Article 21 | Article 44 | Article 45 | European Commission Implementation Guidance
3. The Three Core Objectives of the PPWR: From Packaging Design to Recycling
The overall regulatory direction of the PPWR can be understood through three main objectives.
1. Harmonising the EU Packaging Market
The Regulation establishes common requirements for packaging design, materials and market access, helping reduce regulatory differences between Member States and the barriers businesses may face when entering different EU markets.
2. Promoting a Circular Economy for Packaging
The PPWR emphasises reducing packaging waste and improving the efficiency of material recovery and reuse.
It introduces requirements concerning recycled content, packaging minimisation, reuse and improved recycling performance to encourage more efficient use of resources.
3. Moving Compliance Considerations into the Packaging Design Stage
Packaging manufacturers and brand owners need to consider material composition, packaging structure, recyclability and technical documentation during the product design and procurement stages.
Compliance can no longer be considered only after packaging becomes waste. Packaging design, manufacturing processes and material selection may all influence whether the final product meets applicable market requirements.
Official Reference: PPWR Articles 5–12
4. Seven Key PPWR Requirements: What Should Businesses Pay Attention To?
1. Article 5: Restrictions on Substances in Packaging
Article 5 of the PPWR establishes restrictions on certain substances in packaging and packaging components.
Heavy Metal Concentration Limits
The combined concentration of lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr VI) must not exceed:
100 mg/kg
This restriction applies to packaging and packaging components. It should not be interpreted as a requirement that applies only to food-contact packaging.
The Regulation also provides for specific exceptions and conditions. Businesses should therefore assess the applicable requirements in relation to their packaging materials and any relevant exemptions.
PFAS Restrictions
From 12 August 2026, food-contact packaging must not be placed on the EU market if it meets or exceeds the PFAS concentration limits specified in the Regulation.
| Testing Parameter | Regulatory Limit |
|---|---|
| Individual PFAS (targeted analysis, excluding polymeric PFAS) | 25 ppb |
| Sum of targeted PFAS (including relevant precursor substances where applicable) | 250 ppb |
| Total PFAS, including polymeric PFAS | 50 ppm |
The third limit also involves a documentation obligation. Where the total fluorine concentration exceeds 50 mg/kg, the relevant economic operator must, under the conditions specified in the Regulation, provide supporting documentation upon request so that the manufacturer or importer can complete the technical documentation.
It is important to emphasise that these PFAS limits apply to food-contact packaging. They are not universal testing limits for all non-food apparel packaging bags.
What Should Businesses Do?
- Verify the chemical composition of packaging materials and components.
- Determine whether the intended application falls within the definition of food-contact packaging.
- Arrange applicable testing and collect relevant supporting information.
- Retain material declarations, laboratory reports and supply chain records.
Official References:
PPWR Article 5 | European Commission Guidance – PFAS Restrictions and Implementation
2. Article 6: Recyclability Requirements for Packaging
Article 6 of the PPWR requires packaging placed on the EU market to be recyclable.
Two aspects must be distinguished.
First: Design for Recycling
Packaging must be designed so that its materials can be recovered through recycling processes and converted into secondary raw materials of sufficient quality to replace primary raw materials.
Second: Recycled at Scale
After becoming waste, packaging must also be capable of entering appropriate collection, sorting and actual large-scale recycling systems.
The PPWR establishes three recyclability performance grades: A, B and C.
| Implementation Stage | Key Requirement |
|---|---|
| From 2030 | Packaging must, in principle, achieve Grade A, B or C under the applicable design-for-recycling criteria. |
| From 2035 | Recyclability assessments will additionally take large-scale recycling into account. |
| From 2038 | Packaging must, in principle, achieve Grade A or B. |
However, it would be inaccurate to assume that all design-for-recycling requirements automatically become applicable on 1 January 2030.
The application date under Article 6(2)(a) is 1 January 2030 or 24 months after the relevant delegated act enters into force, whichever is later.
The requirements concerning recycling at scale also have their own implementation mechanism.
The European Commission is required to adopt the relevant delegated act on design for recycling by 1 January 2028. The detailed assessment methodology and application dates must also be considered in light of subsequent official legislation.
What Does This Mean for Apparel Packaging?
The European Commission's guidance clarifies that shoe bags and garment dust bags used as packaging may fall within the definition of packaging under the PPWR when they serve to contain, protect, handle, deliver or present products.
In addition, Article 6(11)(g) provides an exemption from the relevant recyclability requirements for certain sales packaging made from materials such as lightweight wood, cork, textile, rubber, ceramic, porcelain and wax.
This exemption applies to the specified sales packaging materials. It does not mean that plastic apparel packaging bags made from PE, PP or CPE are automatically exempt.
For plastic packaging, the material type, printing, adhesives, closure components and compatibility with recycling processes may all affect the final assessment.
Official References:
PPWR Article 6 | European Commission Guidance – Recyclability and Application Dates
3. Article 7: Minimum Recycled Content in Plastic Packaging
This is one of the most important provisions for plastic packaging manufacturers and buyers.
Article 7 of the PPWR establishes phased minimum post-consumer recycled plastic (PCR) content targets for different categories of plastic packaging.
| Plastic Packaging Category | 2030 Target | 2040 Target |
|---|---|---|
| Contact-sensitive packaging made predominantly from PET (excluding single-use plastic beverage bottles) | 30% | 50% |
| Contact-sensitive packaging made from other plastic materials (excluding single-use plastic beverage bottles) | 10% | 25% |
| Single-use plastic beverage bottles | 30% | 65% |
| Other plastic packaging | 35% | 65% |
Three Important Legal Details Should Be Understood
- Recycled content must come from qualifying post-consumer plastic waste. Not all recycled materials or production scrap can automatically be counted as PCR.
- The recycled content is calculated as an annual average for each manufacturing plant and each packaging type and format. This does not mean that every individual packaging unit must contain exactly the same recycled percentage.
- The 2030 targets apply from 1 January 2030 or three years after the relevant implementing act enters into force, whichever is later.
The 2040 targets are scheduled to apply from 1 January 2040, as specified in the Regulation.
Article 7 also provides specific exemptions, including certain packaging where recycled content could endanger the health of food-contact products, as well as plastic components representing less than 5% of the total weight of the packaging unit, subject to the applicable conditions. Manufacturers must retain technical information demonstrating that the relevant exemption criteria are met.
What Does This Mean for the Apparel Packaging Industry?
PE, PP and CPE bags generally used for apparel packaging are typically non-food-contact plastic packaging. Unless an applicable exemption applies, they should be assessed against the minimum recycled content targets for other plastic packaging under Article 7.
Packaging buyers will increasingly need to verify:
- Whether the recycled plastic comes from qualifying post-consumer waste.
- Whether the recycled content percentage is supported by verifiable calculations.
- Whether the raw material source and supply chain are traceable.
- Whether the material composition of the finished packaging matches the relevant declarations and technical documentation.
Certifications such as GRS and EN 15343 can support recycled material claims and supply chain traceability. However, they cannot independently replace the PPWR requirements for recycled content calculation, verification and technical documentation.
Official References:
PPWR Article 7 | European Commission Guidance – Recycled Content and Exemptions
4. Article 9: Requirements for Compostable Packaging
The PPWR does not require all plastic packaging to be replaced with compostable materials.
Article 9 establishes specific industrial or home compostability requirements for certain categories of packaging.
These include:
- Permeable tea bags, coffee bags and other beverage bags.
- Soft single-serve units intended to be used and disposed of together with their contents.
- Other specific single-serve beverage system packaging covered by the Regulation.
The packaging categories specified in the Regulation must meet the applicable compostability requirements.
In addition, Member States may require certain lightweight plastic carrier bags and other qualifying packaging to be compostable under the conditions set out in the Regulation, including where appropriate separate collection and treatment infrastructure is available.
Important Considerations
For other packaging that is not required to be compostable, the PPWR does not establish a general requirement to replace conventional plastic with compostable materials.
Instead, such packaging should be designed for material recycling in accordance with Article 6, without compromising the recycling of other waste streams.
Industrial compostability and home compostability must also be distinguished. Compliance with industrial composting requirements does not automatically demonstrate that packaging can decompose under home composting conditions.
For apparel packaging bags, obtaining OK compost or EN 13432-related certification does not automatically mean that the product belongs to a category for which the PPWR requires compostable materials.
Official References:
PPWR Article 9 | European Commission Guidance – Compostable Packaging and Member State Powers
5. Article 10: Packaging Minimisation Requirements
Article 10 of the PPWR aims to reduce unnecessary packaging weight and volume. However, it does not simply require all packaging to become thinner.
From 1 January 2030, manufacturers or importers must ensure that the weight and volume of packaging placed on the market are reduced to the minimum necessary to ensure its functionality, taking into account the packaging's shape and material.
Packaging must also meet the performance criteria set out in Annex IV.
These assessments cover factors such as:
- Product protection.
- Manufacturing and filling processes.
- Transportation, handling and storage safety.
- Packaging functionality and intended use.
- Hygiene and product safety.
- Recyclability, recycled content and reuse considerations.
The Regulation also restricts unnecessary packaging designs intended solely to increase the perceived volume of a product, such as unnecessary double walls, false bottoms and redundant layers, subject to the specific exemptions provided.
For Apparel Packaging Businesses, Minimisation Should Focus on:
- Adjusting bag dimensions according to the actual dimensions of folded garments.
- Assessing the relationship between film thickness and actual protection requirements.
- Reducing unnecessary packaging space and material consumption.
- Conducting sealing, tear resistance and transportation compatibility tests to confirm that optimised packaging continues to perform its intended function.
Furthermore, compliance with Article 10 must be supported by technical documentation. This includes the basis for the design assessment, explanations of why further reductions in packaging weight or volume are not feasible, and relevant testing and study results.
Therefore, packaging minimisation under the PPWR is not simply about reducing material thickness. Businesses must be able to demonstrate why the packaging structure and material quantity are necessary to fulfil the intended function.
Official References:
PPWR Article 10 | Annex IV – Packaging Minimisation | European Commission Guidance – Packaging Minimisation
6. Article 24: Overpackaging and Empty Space Restrictions
Article 24 of the PPWR establishes empty-space requirements for different packaging categories.
Two separate requirements must be distinguished.
First: Grouped Packaging, Transport Packaging and E-commerce Packaging
From 1 January 2030 or three years after the relevant implementing act establishing the calculation methodology enters into force, whichever is later, economic operators filling these packaging types must ensure that the maximum empty-space ratio does not exceed 50%.
During the calculation, void fillers such as paper shreds, air cushions, bubble wrap, sponges, foam and other filling materials are considered empty space.
The European Commission is required to establish the calculation methodology by 12 February 2028.
Second: Sales Packaging
Under Article 24(4), from 12 February 2028, economic operators filling sales packaging must reduce empty space to the minimum necessary to ensure the packaging's functionality, including product protection.
This provision does not establish a universal 50% empty-space limit. Instead, compliance is assessed according to the actual product, packaging function and applicable assessment methodology.
What Does This Mean for Apparel Packaging and E-commerce Businesses?
- Packaging dimensions should be appropriately matched to product dimensions.
- Unnecessary internal space should be avoided.
- E-commerce transport packaging should be designed according to actual product dimensions and transportation protection requirements.
- Necessary protection space should be assessed according to its intended function.
The 50% empty-space limit under Article 24 should not be directly applied to every apparel self-adhesive bag, grip seal bag or zipper bag.
Official References:
PPWR Article 24 | European Commission Guidance – Distinction Between Article 10 and Article 24
7. Article 25: Restrictions on Certain Packaging Formats
Article 25 of the PPWR, together with Annex V, restricts certain single-use packaging formats for specific applications.
These restrictions apply from 1 January 2030.
The main categories include:
- Certain single-use plastic grouped packaging used to encourage consumers to purchase multiple products.
- Certain single-use plastic packaging for unprocessed fresh fruit and vegetables weighing less than 1.5 kg, subject to specified exceptions.
- Certain single-use plastic packaging used in hotels, catering and other food service settings.
- Certain single-use packaging formats used in accommodation settings.
- Specific small single-use plastic packaging formats.
It is important to emphasise that Article 25 does not prohibit all single-use plastic packaging, nor does it prohibit all plastic apparel packaging bags.
In particular, some restrictions under Annex V apply to single-use plastic packaging and specific applications. The European Commission's 2026 guidance also provides further clarification on the scope of certain plastic-containing composite packaging formats. For the restrictions under points 1 to 4 of Annex V, certain composite packaging formats containing 5% or more plastic may fall within the scope of the restrictions. However, the specific packaging format and intended use must still be assessed.
Apparel brands and packaging buyers should therefore determine whether the restrictions apply based on the intended use, packaging format and specific descriptions in Annex V, rather than making decisions solely according to the packaging material.
Official References:
PPWR Article 25 | Annex V – Restrictions on Certain Packaging Formats | European Commission Guidance – Packaging Restrictions and Prohibited Formats
5. PPWR Implementation Timeline: Key Dates Businesses Should Know
The PPWR follows a phased implementation approach. Different provisions have different application dates.
The following table distinguishes the main regulatory milestones from deadlines for adopting subsequent delegated or implementing acts.
| Date | Regulatory Milestone |
|---|---|
| 22 January 2025 | The PPWR was officially published. |
| 11 February 2025 | The PPWR entered into force. |
| 12 August 2026 | The PPWR became applicable, including the applicable requirements under Article 5. |
| 31 December 2026 | Deadline under Article 7(8) for adopting the implementing act concerning recycled content calculation and verification methods. |
| 12 February 2027 | Deadline under Article 10(3) for requesting the development of harmonised standards on packaging minimisation. |
| 1 January 2028 | Deadline under Article 6(4) for adopting the delegated act concerning design for recycling. |
| 12 February 2028 | Deadline under Article 24(2) for adopting the implementing act establishing the empty-space calculation methodology. |
| 12 February 2028 | The sales packaging empty-space minimisation requirement under Article 24(4) becomes applicable. |
| 1 January 2030 | Important milestones for packaging minimisation, minimum recycled content and restrictions on certain packaging formats. |
| 1 January 2035 | Statutory milestone for incorporating large-scale recycling into recyclability assessments. |
| 1 January 2038 | Packaging must, in principle, achieve Grade A or B for recyclability. |
| 1 January 2040 | Higher minimum recycled content targets for plastic packaging apply. |
Important Note
The dates of 31 December 2026, 12 February 2027 and certain 2028 milestones are deadlines for the European Commission to adopt legislative acts or initiate standardisation work. They should not be interpreted as dates on which businesses must automatically complete all related compliance obligations.
In addition, the requirements under Articles 6, 7 and 24 include specific application mechanisms linked to subsequent delegated or implementing acts. Businesses should monitor the publication and entry into force of these legal instruments.
Official References:
Article 6 | Article 7 | Article 10 | Article 24 | Article 25 | Article 71 | European Commission – PPWR Implementation Guidance
6. How Should Businesses Prepare for PPWR Compliance?
Understanding the regulatory provisions is only the first step. The more important task is to incorporate the applicable requirements into packaging products, material selection and supply chain management.
Businesses can follow the steps below.
Step 1: Identify the Packaging Type and Applicable Requirements
First, identify the packaging material, intended use and structural design.
Examples include:
- Plastic apparel packaging bags.
- Food-contact plastic packaging.
- Paper-based packaging.
- Compostable packaging.
- Transport and e-commerce packaging.
Different packaging categories may be subject to different regulatory provisions. Businesses should first establish the legal classification of the packaging and then identify the specific requirements that apply.
Step 2: Verify Material Composition and Supporting Documentation
Establish a complete record of the packaging's material composition, including:
- Main materials and their respective proportions.
- Recycled material content.
- Printing inks.
- Adhesives.
- Zippers, sliders and other accessories.
- Other components that may affect material safety or recyclability.
Collect material declarations, laboratory reports, certification documents and supply chain traceability records according to the applicable requirements.
Step 3: Conduct Packaging Design and Performance Assessments
Evaluate whether the packaging meets the actual protection requirements of the intended product.
Key considerations include:
- Whether material consumption is reasonable.
- Whether packaging dimensions are appropriate for the product.
- Whether the packaging structure affects recyclability.
- Whether closure performance meets the intended requirements.
- Whether unnecessary packaging layers or empty space can be reduced.
Step 4: Prepare Technical Documentation and Conformity Records
Under Article 15, Article 38, Article 39 and Annex VII of the PPWR, manufacturers must complete the applicable conformity assessment and prepare the required technical documentation and EU Declaration of Conformity.
Depending on the specific packaging requirements, the technical documentation should include:
- Product and material specifications.
- Packaging design and structural descriptions.
- Applicable test reports.
- Recycled content calculations and supporting information.
- Recyclability and minimisation assessment records.
- Other applicable supply chain supporting documents.
It is important to understand that certification documents, laboratory test reports, supplier declarations and the EU Declaration of Conformity serve different purposes and cannot automatically replace one another.
Step 5: Maintain Supply Chain and Product Change Management
When packaging materials, suppliers, printing inks, adhesives or structural designs change, the relevant impacts should be reassessed.
Businesses should also retain supplier information, product specifications, technical documentation and conformity records to ensure consistency between procurement, manufacturing and the packaging ultimately placed on the market.
PPWR compliance is not a one-time exercise in collecting documents. It is an ongoing process of product and supply chain management.
Official Reference:
Article 15 | Article 16 | Article 18 | Article 38 | Article 39 | Annex VII
7. How Does Goolien Packaging Support Customers in Addressing PPWR Requirements?
For apparel brands and packaging buyers, selecting a packaging supplier involves more than comparing materials and prices. It is also important to consider the supplier's manufacturing capabilities, material management and customisation capabilities.
Dongguan Goolien Packing Technology Co., Ltd. specialises in custom packaging bag manufacturing, with 23 years of industry experience and a production facility covering more than 5,000 square metres. Its integrated production processes include film extrusion, precision printing, bag making and quality inspection.
For sustainable packaging, Goolien offers a range of material options and relevant certification credentials, including:
- Recycled Materials: GRS and EN 15343, supporting relevant recycled material claims and supply chain traceability.
- Compostable Materials: OK compost and EN 13432, supporting the development of products within applicable compostable packaging routes.
- Paper-Based Packaging: FSC-related credentials, supporting the development of paper-based packaging products.
The company's main material options include PE, PP, OPP, CPE, PLA+PBAT, glassine paper and cellulose film. Different bag styles, dimensions and printing designs can be customised to meet individual customer requirements.
For apparel packaging projects, Goolien can assist customers in evaluating material options, bag dimensions, closure structures and intended product applications. The company also supports sample evaluation and the preparation of relevant product documentation.
It is important to clarify that certifications such as GRS, EN 15343, OK compost, EN 13432 and FSC support different material, product or supply chain claims. They do not, individually or collectively, automatically demonstrate full compliance with the PPWR. Final compliance must be assessed according to the specific packaging product, applicable regulatory provisions, test results and technical documentation.
If you are developing apparel packaging for the European market, contact Goolien Packaging to discuss material selection, packaging structures and customised solutions for your brand.
The PPWR is changing packaging design practices and market access requirements across the European Union.
From restrictions on hazardous substances and packaging recyclability to recycled content, packaging minimisation and supply chain responsibilities, businesses need to integrate regulatory considerations throughout the entire packaging life cycle.
For packaging manufacturers and brand owners, identifying applicable requirements, verifying material information, optimising packaging design and maintaining complete technical documentation can help reduce future compliance risks.
The future of packaging competition will depend not only on materials and prices, but also on product functionality, resource efficiency, traceability and the ability to adapt to evolving regulatory requirements.
//www.goolien.com/
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