PPWR: What the New EU Packaging Regulation Means for Your Business
On 12 August 2026, Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste – the PPWR for short – becomes directly binding law. It applies in all 27 member states at once, with no national transposition required. For companies that manufacture, import, fill or distribute packaging, this changes quite a lot.
The PPWR replaces the previous Packaging Directive 94/62/EC. It does so not as an update, but as a fundamentally new legal framework. Instead of 27 different national transpositions, a single, directly applicable set of rules now applies across the EU. From 2030, virtually all packaging placed on the market must be designed for recycling. Plastic packaging will also need mandatory minimum recycled content (10–35% from 2030, up to 65% from 2040), and grouped, transport and e-commerce packaging will be capped at 50% empty space from 2030. A new substance restriction already applies from the start date itself: food-contact packaging must not exceed certain PFAS limits.
One important practical point: around 35 implementing and delegated acts from the European Commission are still pending. They will only spell out key details over the coming years, so many deadlines may still shift. Austria's accompanying legislation – the planned amendment to the Waste Management Act (AWG) and the 2014 Packaging Ordinance – has also not yet been passed. Until then, the existing participation obligation for primary obligated parties under Section 13g AWG 2002 continues to apply unchanged.
Five PPWR Takeaways From Our Advisory Practice
Directly Applicable EU Law – Legal Compliance
The PPWR applies as an EU regulation, directly and without national transposition. At the same time, the old Packaging Directive 94/62/EC is repealed. It belongs in the legal register immediately.
Role in the Supply Chain – Risk Management
Producers, importers, distributors, authorised representatives and suppliers each carry different obligations. Which role your company holds in its specific supply chain needs to be clarified case by case. Every other obligation follows from that.
EU Declaration of Conformity – Document Management
Producers will need to issue an EU declaration of conformity together with technical documentation. They must then keep it for 5 years (single-use) or 10 years (reusable packaging).
Banned Formats From 2030 – Risk Management
Certain single-use plastic packaging formats may no longer be placed on the market from 1 January 2030. Examples include plastic wrapping for fresh fruit and vegetables under 1.5 kg, single-use tableware for on-site consumption in hospitality venues, miniature cosmetics packaging in hotels, and very lightweight plastic carrier bags. Businesses still relying on these formats should therefore start looking at alternatives now.
Licence Fees & Levies – Cost Management
On top of the PPWR obligations themselves come ongoing licence fees, for example via ARA in Austria, ranging roughly from 0.02 to 1.14 euro per kg depending on material. There is also the litter levy for certain single-use plastic products, whose 2026 rates are currently open pending a court ruling. Accompanying obligations such as the already applicable EmpCo Directive on environmental claims are worth keeping in view too.
At a glance: Applies from 12 August 2026 – directly applicable EU law that replaces Directive 94/62/EC. Further key deadlines follow in 2027, 2028, 2029, 2030, 2035, 2038 and 2040.
Companies already running a quality or environmental management system have the right structure in place. Supplier evaluation, document control and a legal compliance register can, in fact, be applied directly to PPWR requirements, instead of treating the regulation as an isolated add-on task.
Alongside the PPWR, the EmpCo Directive on environmental claims and the Microplastics Regulation (REACH) are also relevant for packaging. The new ISO 14001:2026 covers similar ground too. The new PFAS substance restriction for food packaging also connects thematically to our post on the PFAS ban in firefighting foam. If you're already tracking 2026 regulatory deadlines, our post on the new EU AI Act covers further details.
Want to know which role your company holds in the supply chain and which PPWR obligations specifically apply to you? Sennefer Consulting supports you through implementation – from role clarification to integration into your existing management system.
This article was created with AI assistance.