The PPWR: a new framework for
credible and measurable eco-design
Perrine Sébastien & Emilie Guilvert
The European Packaging and Packaging Waste Regulation (PPWR) stems from a simple observation: despite increasing collection and recycling rates, the amount of packaging waste continues to grow in Europe, while many packaging formats remain difficult to recycle, contain excessive amounts of virgin materials or do not integrate effectively into a circular economy. The regulation therefore aims to reduce packaging waste at source, improve recyclability, promote reuse and increase the use of recycled materials in order to reduce the use of natural resources and the associated environmental impacts.
The PPWR entered into force in 2025 and becomes applicable from 12 August 2026. However, its main technical requirements (recyclability, recycled content and reuse) will only be introduced progressively between 2028 and 2030.
This transition period is crucial: companies need to start structuring their data today, identifying compliance risks and preparing for changes to their packaging. In this article, we review the key PPWR deadlines and the actions to take now to prepare your packaging portfolio for the requirements of 2030 and beyond.
Who is affected?
The PPWR covers all packaging, regardless of the material used, and all packaging waste, irrespective of the context in which the packaging is used or the origin of the packaging waste: industry, retail or distribution, offices, services or households.
However, certain categories are subject to specific exemptions from the recyclability requirements:
Certain primary pharmaceutical packaging
Contact-sensitive medical devices
In vitro diagnostic devices
Preservation of the quality of medicinal products
Contact-sensitive infant formula packaging
The transport of dangerous goods
The sale and use of packaging made from light wood, cork, textile, rubber, ceramic, porcelain or wax
What are the key PPWR deadlines?
-
Compliance
- Technical documentation
- EU Declaration of Conformity
- Packaging Traceability
- Restrictions on PFAS and Heavy Metals
- European Commission and ECHA Report on Substances of Concern
- Initial Labelling Requirements
- Rules on Reusable Packaging to Be Developed by February 2027
-
Progressive Entry into Force of Several Technical Requirements
- Design for Recycling Criteria
- Methods for Calculating Recyclability
- Compostability Standards and Requirements
- Harmonised Labelling for Sorting Instructions
- Review of Bio-based Plastics and Their Sustainability
-
Generalised Harmonised Labelling
- Sorting Instructions
- Identification of Reusable Packaging
- Identification of Compostable or Bio-based Packaging, Where Relevant
- Digital medium, such as a QR code
-
Initial Circular Performance Requirements
These deadlines will depend on the publication date of the delegated acts.
- Packaging Designed for Recycling
- Recyclability Classified as Class A, B or C
- Minimum recycled content
- Packaging Minimisation Wherever Possible
- Reuse targets
-
Recycling at scale
- Mandatory “Recycled at Scale” criterion
- Packaging designed to be recyclable
- Effective collection and sorting of packaging
- Recycling carried out at scale within the European Union
How to comply from 12 August 2026?
Unlike the recyclability and recycled content requirements, which will mainly apply from 2030, the key challenge in 2026 is being able to demonstrate the compliance of your packaging. This relies on two pillars: technical documentation and the EU Declaration of Conformity.
First requirements: PFAS content and substances of concern
From 12 August 2026, food-contact packaging may no longer be placed on the market if it contains a total measured concentration of per- and polyfluoroalkyl substances (PFAS) of ≥ 250 ppb or ≥ 50 ppm where the total fluorine content is > 50 mg/kg.
By the end of 2026, the European Commission is preparing a list of substances of concern that are hazardous to human health and the environment, as well as substances that may hinder recycling and reuse. Their minimisation will then be recommended, and this report could serve as the basis for future restriction measures.
Technical documentation
The manufacturer must be able to substantiate the characteristics of the packaging and demonstrate its compliance with the applicable PPWR requirements. The technical documentation must be sufficiently detailed to enable the authorities to assess the packaging’s compliance.
Declaration of conformity
The PPWR requires packaging compliance to be demonstrated through an EU Declaration of Conformity issued by the manufacturer.
This declaration must include, in particular:
Preparing for circularity requirements
Recyclability
From 1 January 2030, all packaging subject to Article 6 will have to meet the recyclability requirements, with a classification that will determine whether the packaging can be placed on the market.
The detailed criteria for recyclable content will be specified in the Commission’s delegated acts, but the classification currently envisaged for 2030 is:
- Class A: ≥ 95%
- Class B : ≥ 80 %
- Class C : ≥ 70 %
- < 70%: packaging considered technically non-recyclable.
|
Recyclability class |
Recyclable content |
Status |
|
Class A |
≥ 95 % |
Excellent recyclability |
|
Class B |
≥ 80 % |
High recyclability |
|
Class C |
≥ 70 % |
Acceptable recyclability |
|
Non-compliant |
< 70 % |
Packaging considered technically non-recyclable |
Recycled content
From 2030, several categories of plastic packaging will have to incorporate a minimum proportion of recycled material, superseding the targets set by Directive (EU) 2019/904, which established a now outdated target for plastic bottles: 25% by 2025 and 30% by 2030.
|
Packaging category |
Minimum recycled content |
|
Contact-sensitive PET packaging |
30 % |
|
Other contact-sensitive packaging |
10 % |
|
Single-use plastic bottles |
30 % |
|
Other plastic packaging |
35 % |
Companies should already be assessing:
Whether their product
is covered
The availability of recycled materials
Food contact
constraints
Product
traceability
Economic
impacts
Their suppliers’
capabilities
Exceptions apply to medical, food-contact, low-mass or compostable packaging.
How can LCA support PPWR implementation?
The PPWR requires technical information (as listed above) to be provided to demonstrate the compliance of the packaging concerned.
LCA can help you demonstrate the compliance of your packaging, but above all, it can help you prepare now for the circularity requirements by objectively comparing several scenarios:
LCA
Multicriteria
comparison
LCA will therefore tell you which option is genuinely the best-performing from an environmental perspective, but it is also an essential tool for substantiating your environmental claims. As efforts to combat greenwashing intensify and environmental claims such as “recyclable”, “low carbon footprint”, “green” and “more sustainable” become increasingly regulated, companies must be able to support their claims with robust and verifiable data.