EU Packaging and Packaging Waste Regulation, Sebastian Meyn, Lena Blinquiree, James Marlow, Markus Appel, Atdhe Krasniqi

EU Packaging and Packaging Waste Regulation, Sebastian Meyn, Lena Blaske, James Marlow, Markus Appel, Atdhe Krasniqi


The PPWR (Regulation (EU) 2025/40) entered into force on 11 February 2025. Its provisions will generally apply from 12 August 2026, although certain obligations will take effect at a later date. 

The PPWR replaces the former EU Packaging Directive (94/62/EC). 

Unlike a Directive, the Regulation applies directly and does not necessary to be transposed into national law by the Member States. However, Member States can implement supplementary national regulations.

The PPWR is designed to harmonise national rules on packaging, avoid market fragmentation and promote more sustainable practices. It lays down environmental sustainability requirements for the entire life cycle of packaging, which must be met for packaging to be placed on the market. Its objectives include reducing the overall consumption of packaging, increasing and improving product recyclability and thereby achieving more sustainable packaging solutions. 

The PPWR imposes (among other things):

  • packaging conformity requirements and the framework for a conformity assessment system;

  • restrictions on substances of concern in packaging;

  • recyclability and reusability requirements and tarobtains; 

  • eco-frifinishly design and labelling requirements and  

  • Extfinished Producer Responsibility (EPR). 

The European Commission published a (non-binding, but interpretive) guidance document in March 2026 (“PPWR Guidance”) to assist interpret selected provisions of the PPWR. 

The Commission has also published a set of Frequently Asked Questions (FAQs) to answer some practical questions raised since the PPWR was adopted.



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