SG 019/25
The European Union (EU) has issued new rules for packaging and packaging waste as part of its transition to a circular economy. The new law will enter into force on February 11, 2025.
On January 22, 2025, the EU published Regulation (EU) 2025/40 on packaging and packaging waste (the Packaging and Packaging Waste Regulation (PPWR)). Once in full effect, this comprehensive piece of legislation will replace Directive 94/62/EC on packaging and packaging waste.
The PPWR establishes rules covering the entire life cycle of packaging. It contributes to the efficient functioning of the internal market by harmonizing national measures, while preventing and minimizing the negative impacts of packaging and packaging waste on the environment and human health.
Additionally, the PPWR includes waste reduction measures and targets, along with provisions to reduce excessive packaging – including e-commerce packaging – improve recyclability, increase recycled content, phase out hazardous and harmful substances such as per- and polyfluoroalkyl substances (PFAS), and promote re-use.
According to the definitions in the PPWR, PFAS means any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CH2-) carbon atom (without any H/Cl/Br/I attached to it), except substances that only contain the following structural elements:
- CF3-X or X-CF2-X’, where X = -OR or -NRR’ and X’ = methyl (-CH3), methylene (-CH2), an aromatic group, a carbonyl group (-C(O))-), OR’’, -SR’’ or -NR’’R’’’
- Where R/R’/R’’/R’’’ is a hydrogen (-H), methyl (-CH3-), methylene (-CH2-), an aromatic group or a carbonyl group (-C(O)-).
Highlights of several provisions in the PPWR are summarized in Table 1.
Section to PPWR | Highlights |
Article 1 ‘Subject matter’ | - Establishes requirements for the entire life cycle of packaging concerning environmental sustainability and labeling, extended producer responsibility and packaging waste prevention
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Article 2 ‘Scope’ | - Applies to all packaging and packaging waste
- Applies to provisions under Directive 2008/98/EC (Waste framework directive (WFD), consolidated version to February 2024) concerning the management of hazardous waste and Union legislative requirements for packaging
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Article 3 ‘Definitions’ | - Provides a list of terms and their definitions, including but not limited to:
- Primary production packaging: packaging item for unprocessed products from primary production (Regulation (EC) No 178/2002)
- Sales packaging (primary packaging)
- Grouped packaging (secondary packaging)
- Transport packaging (tertiary packaging)
- E-commerce packaging: transport packaging used to deliver products based on sale online or through other means of distance sales to the end user
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Article 5 ‘Requirements for substances in packaging’ | - ≤100 mg/kg sum of lead, cadmium, mercury and chromium (VI), without prejudice to chemical restrictions falling under Annex XVII of Regulation (EC) No. 1907/2006 (Annex XVII of REACH) or specific measures on food contact materials (FCM) and articles in Regulation (EC) No 1935/2004
- Unless prohibited by another Union act, restricts the use of PFAS in food contact packaging materials from August 12, 2026 (see Table 2 below)
- Requires technical documentation (Annex XVII) to demonstrate compliance with the above two points
- Authorizes the European Commission (EC) to monitor the presence of substances of concern (SoC) in packaging, report the findings by December 31, 2026, and examine appropriate follow-up measures, including new restrictions on these chemicals
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Article 6 ‘Recyclable packaging’
| - Emphasizes that all packaging must be recyclable (with several derogations to be reviewed by January 1, 2035)
- Defines criteria for packaging to be considered ‘recyclable’, including but not limited to:
- The EC must adopt delegated acts containing standards in relation to ‘design for recycling’ (DFR) criteria and recyclability performance grades by January 1, 2028.
- This will become effective on January 1, 2030, or 24 months from the date of entry into force (EIF) of the adopted delegated acts (only packaging with a DFR of at least 70% (Grade A, B or C) is considered recyclable (Annex II Table 3))
- The EC must adopt implementing acts establishing, inter alia, the methodology for the recycled-at-scale assessment per packaging category (Annex II Table 2) by January 1, 2030 (effective January 1, 2035, or five years from the date of EIF of the implementing acts)
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Article 7 ‘Minimum recycled content in plastic packaging’ | - Sets target dates for defined quantities of recycled content recovered from post-consumer plastic waste for four categories of plastic packaging:
- Polyethylene terephthalate (PET) contact-sensitive packaging¹, except single-use plastic (SUP) beverage bottles
- Non-PET contact-sensitive packaging¹, except SUP beverage bottles
- SUP beverage bottles
- Plastic packaging other than those indicated above
- ¹includes food contact and cosmetic packaging
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Article 9 ‘Compostable packaging’ | - By way of exemption from the recyclable packaging requirements under (Article 6(1)), certain packaging² must meet the standard for composting or, where required by Member states, the standard for home-composting. These standards are to be prepared or updated
² 1) Permeable tea, coffee or other beverage bags, or soft after-use system single-serve units that contain tea, coffee or another beverage, and which is intended to be disposed of together with the product 2) Sticky labels for fruits and vegetables |
Article 10 ‘Packaging minimization’ | - Authorizes the EC to request European standardization organizations to prepare or update standards for packaging minimization by February 12, 2027
- Requires the weight and volume of packaging to be reduced to the minimum required to ensure its functionality by January 1, 2030
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Article 11 Reusable packaging’ | - Packaging placed on the market from February 11, 2025, must be considered to be reusable if it meets a set of defined conditions
- Directs the EC to adopt a delegated act by February 12, 2027, to establish the minimum number for the rotations of reusable packaging
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Article 12 ‘Labeling of packaging’ | - Mandates packaging to be marked with a (yet to be established) harmonized label containing information on its material composition to facilitate consumer sorting from August 12, 2028, or 24 months from the date of EIF of the adopted implementing acts
- Requires packaging containing SoC to be marked using standardized, open digital-marking technologies:
- By August 12, 2026, the EC must adopt rules to establish a methodology for identifying material composition
- By January 1, 2030, the EC must adopt rules to establish the methodology for identifying SoC
- Directs the EC to adopt guidelines to clarify aspects of labels that are likely to mislead or confuse consumers or other end users
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Articles 15, 17 to 19 | - Obligations for manufacturers, authorized representatives (AP), importers and distributors
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Article 24 ‘Obligations related to excessive packaging’ | - Economic operators who fill grouped packaging, transport packaging or e-commerce packaging must ensure that the maximum empty space ratio is 50% by January 1, 2030, or three years from the EIF of adopted rules:
- The EC must adopt rules to establish a methodology by February 12, 2028
- Economic operators who fill sales packaging must ensure that empty space is reduced to the minimum necessary for ensuring packaging functionality and product protection by February 12, 2028:
- Filling materials such as air cushion, bubble wraps, foam fillers, paper cuttings, polystyrene (Styrofoam) chips, sponge fillers and wood wool are considered as empty space
- Defines characteristics for sales packaging for products that are subject to settlement during transportation or where headspace is required to protect the food product or other products
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Article 34 ‘Plastic carrier bags’ | - Sets targets for Member states to achieve a sustained reduction in the consumption of lightweight plastic carrier bags on their territory
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Article 39 ‘EU declaration of conformity’ (DoC) | - Details the requirement for a DoC (Annex VIII)
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Article 70 ‘Repeal and transition provisions’ | |
Article 71 ‘Application’ | - With the exception of Article 67(5), which will apply from February 12, 2029, the PPWR will apply from August 12, 2026
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Annexes | - Contains 13 Annexes of supplementary material in support of the PPWR:
- Annex I ‘Indicative list of items in the scope of packaging’
- Annex II ‘Categories and parameters for assessment of recyclability of packaging’
- Annex III ‘Compostable packaging’
- Annex IV ‘Methodology for packaging minimization assessment’
- Annex V ‘Restrictions on the use of packaging formats’
- Annex VI ‘Requirements specific to re-use systems and refill stations’
- Annex VII ‘Conformity assessment procedure’
- Annex VIII ‘EU declaration of conformity’
- Annex IX ‘Information for registration and reporting to the register under Article 44’
- Annex X ‘Minimum requirements for deposit and return systems’
- Annex XI ‘Implementation plan to be submitted under point d to Article 52(2)’
- Annex XII ‘Data to be included by Member States in their databases on packaging and packaging waste (in accordance with Tables 1 to 4)
- Annex XIII ‘Correlation table’ (between Directive 94/62/EC and the PPWR)
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Table 1
Substance | Scope
| Requirement
| Effective date
|
PFAS | Food contact packaging materials | - < 25 ppb individual PFAS tested with target analysis¹
- < 250 ppb sum of individual PFAS, where applicable with prior degradation of precursors¹
- < 50 ppm PFASs, including polymeric PFAS²
| August 12, 2026 |
¹ Excludes polymeric PFAS from quantification ² If total fluorine exceeds 50 mg/kg, proof is required upon request for the quantity of fluorine content measured as either PFAS or non-PFAS to draw up technical documentation (Annex VII) |
Table 2
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