PPWR: KEY DEADLINES TO PREPARE FOR FROM 2026

PPWR, or how 30 years of packaging directives are giving way to a single regulation

First proposed in 2022 and entered into force in 2025, the PPWR, for Packaging and Packaging Waste Regulation, is the result of a long European policy trajectory: Directive 94/62/EC of 1994, the European Green Deal in 2019, REACH regulation on chemical substances, the 2019 directive on single-use plastics, and more. However, the PPWR is not simply a regulatory adjustment, particularly because of its legal status: while a directive is transposed by each Member State, a regulation applies uniformly across the 27 EU countries, without national transposition. This means a single framework across the European market, but also directly enforceable obligations.

The reference documentation remains available on the European Commission portal and, in France, on the website of the Ministry of the Economy, which details the publication of the text and how it fits with national law.

PPWR: all packaging, the entire value chain

The first message from the speakers was that the scope of the PPWR is deliberately very broad. The regulation covers all packaging and all packaging waste, whether household or professional, including sales packaging, grouped packaging and transport packaging. All materials are concerned, from plastics and paper-cardboard to metals and glass. More broadly, the entire value chain is involved: manufacturers, producers, distributors and importers, each now assuming formal responsibility in the conformity assessment process. Only a few limited exemptions remain, notably for certain medical packaging.

To structure this dense regulatory framework, Pack Eko organised its presentation around the main blocks of the text, referring to their respective articles: prevention and reduction, recyclability, recycled content, reuse, hazardous substances, harmonised labelling and the technical conformity file. Each follows its own timeline, running from 2026 to 2040.

PFAS and heavy metals: the first PPWR milestone in August 2026

The most widely discussed requirement concerns hazardous substances, addressed in Article 5. From 12 August 2026, the sum of concentrations of heavy metals, lead, cadmium, mercury and chromium, must not exceed 100 mg/kg in any packaging. Restrictions on PFAS will also apply from the same date. These perfluorinated compounds are used in particular to make food-contact packaging water-resistant. The thresholds detailed by the speakers are 25 ppb for targeted analysis, 250 ppb for the sum of PFAS and 50 ppm for PFAS overall. The guidelines published by the Commission have clarified the conformity assessment approach, a point Pack Eko highlighted as decisive for food industry manufacturers.

Reducing, lightening and removing the unnecessary

The second pillar focuses on packaging prevention and reduction. Article 43 of the PPWR sets targets for reducing packaging waste per capita, regardless of material: 5% in 2030, 10% in 2035 and 15% in 2040. Article 25 imposes requirements to minimise weight and volume, with a calculation method expected in 2027 and application from 2030. Article 24 addresses the reduction of empty space: empty space in sales packaging will have to be reduced to a minimum from 12 February 2028, while a 50% empty-space cap will apply to grouped and transport packaging from 1 January 2030. In addition, Article 45 restricts six categories of single-use formats listed in Annex V, including grouping packaging, very lightweight plastic bags and certain formats used in the hotel and restaurant sector. According to Pack Eko, the aim is to tackle overpackaging, optimise grammages, reduce empty space in logistics and question certain promotional or multi-component formats.

Recyclability graded until 2038

Article 6 makes recyclability a condition for market access. From 2028, design-for-recycling criteria and the methodology for assessing performance classes will apply. From 2030, only packaging rated A, B or C will be authorised, with the threshold tightening in 2038 to allow only classes A and B. Pack Eko emphasised the role of harmonised standards, publication of which is due to begin in 2026 with a first wave covering plastics and a second covering other materials. Beyond design, the regulation introduces a requirement for recyclability at scale: packaging must be effectively collected, sorted and recycled in industrial facilities covering at least 75% of the European population, with an assessment methodology due on 1 January 2030 and application from 2035. For manufacturers, this means simplifying certain structures, limiting elements that disrupt recycling and arbitrating between technical performance and recyclability.

Recycled content and reuse: quantified targets

Article 7 makes it mandatory to incorporate recycled plastic into any packaging in which the plastic part represents at least 5% of the total weight of the packaging unit. The calculation methodology is expected by the end of 2026, with the first targets and traceability requirements taking effect on 1 January 2030. Rates vary by category: 30% in 2030 then 50% in 2040 for sensitive PET packaging, and up to 65% in 2040 for single-use beverage bottles.

Reuse follows a comparable logic, with sector-specific targets from 2030, ranging from 10% for grouped packaging to 100% for transport packaging between sites within the Union. For companies, the challenge concerns both securing supplies of recycled material and redesigning packaging capable of withstanding several use cycles.

PPWR: new labelling and a conformity file to prepare

Article 12 harmonises sorting instructions at European level. The methodology and new material-based marking are expected by 12 August 2026, with application set for 12 August 2028. The regulation also opens the way for digital media, such as QR codes, and provides for the identification of reusable packaging from 12 February 2029. To demonstrate conformity, each manufacturer will have to prepare a technical file bringing together the packaging description, material specifications, references to standards and test reports, then establish a declaration of conformity by packaging type. This information must be kept for five years for single-use packaging and 10 years for reusable packaging.

PPWR: a four-step roadmap proposed by Pack Eko

Beyond the regulatory analysis, the value of the webinar lay in its methodological dimension. The experts from Pack Eko presented a four-step roadmap: diagnose the packaging portfolio to identify the most exposed references, prioritise actions by focusing efforts on high-volume items and non-conformities by 2030, act by launching quick-win projects such as integrating recycled material or reducing weight, then secure long-term conformity through regulatory monitoring and appropriate internal governance. 2026 was described as a pivotal year, combining legal transition, with French transposition expected via the DDADUE law in autumn 2026, technical structuring and documentation. The research and development decisions taken today will determine conformity through to 2040.