Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation)
PPWR: what the EU Packaging Regulation has required since 12 August 2026
The EU Packaging Regulation has applied since 12 Aug 2026 — B2B and transport packaging included. Deadlines to 2030, recycled content, PFAS.
Status: applies since 12 Aug 2026; further obligations phased in through 2040 (recycled-content quotas and format bans from 2030, PFAS limits for food contact already active)
Relevant for: everyone placing packaging on the market — including B2B and transport packaging
What is the PPWR?
The PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) is the EU Packaging Regulation. It has applied directly in all member states since 12 August 2026 and replaces the old Packaging Directive 94/62/EC. It governs how packaging must be designed, labelled, recycled and reused. Unlike the directive, it is a regulation: it applies directly without German transposition. The German Packaging Implementation Act (VerpackDG) now only governs national responsibilities, registration and system participation.
The regulation’s ambition, in substance from Article 1: all packaging must be designed for recycling, unnecessary packaging is reduced, plastic packaging contains recycled content, and reuse becomes mandatory for certain applications. The obligations are phased in until 2040.
Who is affected?
Everyone who places packaging on the EU market, i.e. manufacturers, importers and distributors of packaged goods, regardless of whether the customer is a consumer or a company:
- Sales packaging: the packaging around the product.
- Grouped packaging: bundles, trays, displays.
- Transport packaging: cartons, pallets, stretch and shrink film, strapping, edge protectors.
- Service packaging and e-commerce packaging, which additionally has an empty-space rule.
A machine builder shipping a system on a single-use pallet wrapped in film places three pieces of packaging on the market. A supplier delivering parts in cartons to the OEM does the same.
Not affected: only companies that place no packaging on the market, such as pure service providers without goods shipments. Micro-enterprises have relief on some obligations, such as the conformity assessment, but no general exemption. And companies using only reusable packaging in closed loops have fewer, but not zero, obligations.
What applies from when?
| Date | What applies |
|---|---|
| 11 Feb 2025 | Entry into force |
| 12 Aug 2026 | Date of application: basic obligations, conformity assessment, technical documentation, PFAS limits for food-contact packaging |
| 12 Aug 2026 | German VerpackDG in force; replaces the VerpackG (Bundestag 11 Jun 2026, Bundesrat 10 Jul 2026, Federal Law Gazette 2026 I No. 207) |
| 12 Aug 2028 | Harmonised packaging labelling (material composition, sorting instructions) |
| 1 Jan 2030 | Recyclability performance grades; minimum recycled content in plastic packaging (first stage); format bans (e.g. single-use plastic for fresh fruit and vegetables under 1.5 kg, miniature hotel cosmetics); reuse targets for transport packaging; maximum 50 % empty space in e-commerce packaging |
| 2035 to 2040 | Second stage of recycled-content and reuse targets, stricter recyclability requirements |
Which concrete obligations arise?
- Prove recyclability: from 2030 every piece of packaging must be assigned a recyclability grade; packaging in the lowest grade may no longer be placed on the market. Assessment criteria come via delegated act.
- Minimise packaging: reduce weight and volume to what is necessary; e-commerce packaging may have at most 50 % empty space from 2030.
- Use recycled content: plastic packaging needs minimum post-consumer recycled content from 2030, between 10 % and 35 % depending on application, higher from 2040.
- Comply with substance restrictions: PFAS limits in food-contact packaging since 12 August 2026; heavy-metal limits continue.
- Label: harmonised labelling with material information and sorting instructions from 12 August 2028; information on recycled content and reusability.
- Document conformity: technical documentation and EU declaration of conformity per packaging, available on request to market surveillance.
- Register and report volumes: continued registration with the Central Agency Packaging Register (LUCID) and system participation under the VerpackDG; additional EU-wide reporting on volumes and materials.
- Organise reuse: reuse quotas apply from 2030 to transport packaging within the EU and between sites of one company.
Common misconceptions
- “We only pack in cardboard, that’s paper, so it’s harmless.” Cardboard is packaging and falls fully under the regulation: conformity assessment, labelling, minimisation. Coated cardboard may additionally fall under the PFAS limits.
- “B2B is exempt.” No. The regulation does not distinguish by recipient. Transport packaging in industrial business is explicitly covered and gets its own reuse quotas.
- Forgetting the suppliers. Anyone importing packaged goods is the importer of the packaging and carries the conformity obligation. The technical data (material, recycled content, recyclability) must come from the supplier.
- Treating 2030 as far away. Packaging changeovers take two to three years with sampling, testing and supplier changes. Start in 2027 or buy under time pressure in 2030.
How SCRM Guard helps
The PPWR compliance module on the platform records your packaging per commodity group and supplier with material, weight and recycled content, requests missing data from suppliers in a structured way and shows you which packaging will no longer be permitted in 2030. Obligations and deadlines sit in the system as actions with owners; reminders arrive in Microsoft Teams.
In the full service we take over the inventory of your packaging, the supplier survey and the ongoing maintenance of conformity documentation. We also tell you which packaging is already compliant today and where you do not need to change anything.
Frequently asked questions
Does the PPWR also apply to transport packaging in B2B business?
What changes in the German Packaging Act?
When do the recycled-content quotas apply?
What do PFAS have to do with packaging?
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste, EUR-Lex (22 Jan 2025)
- DIHK: economic policy — briefing on the EU Packaging Regulation (PPWR) (01 Aug 2025)
- German Federal Ministry for the Environment: circular economy and packaging (VerpackDG) (17 Jul 2026)
This page is an editorial briefing for procurement and compliance teams in mid-sized companies, not legal advice. We check deadlines and thresholds against primary sources; the review date is shown at the top of the page.