What Is The EU Packaging and Packaging Waste Regulation (PPWR)?

The Packaging and Packaging Waste Regulation (PPWR) is the EU’s new set of rules aimed at reducing the growing pile of packaging waste, cutting back on unnecessary packaging, and tackling plastic pollution across the EU market. Unlike the old Packaging Directive (94/62/EC), which allowed each Member State to implement the rules in its own way, the PPWR is a Regulation. In practice, that means no creative interpretations: the rules apply directly and uniformly across all EU Member States, helping to create a genuine level playing field for packaged goods.

The regulation lays down clear, non-negotiable rules for packaging, from how it’s designed, to what it’s made of, to where it ends up.

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Packaging design & recyclability: no more “recyclable-ish”

Recyclability is moving from a marketing claim to a proper scorecard. From 1 January 2030, all packaging placed on the EU market must be recyclable. Not “in theory”, not “with the right facilities somewhere”, but demonstrably so.

Instead of a simple yes or no, packaging will get a grade based on “Design for Recycling” (D4R) criteria (to be finalised by 1 January 2028):‍

Anything below 70% (Grade D) won’t make the cut from 1 January 2030. And the bar rises again in 2038, when Grade C is also phased out, meaning packaging must score at least 80% to stay on the market.

And yes, the details matter: compliance is proven through a conformity assessment that looks at each component separately (so caps, labels and bottles all get their moment in the spotlight).

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Recycled content: plastic needs to pull its weight

To make sure recycled plastic actually gets used, the PPWR sets minimum recycled content targets for plastic packaging. By 2030:

‍- 30% for contact-sensitive PET packaging (e.g., food and beverage containers), except for single-use plastic beverage bottles

- 10% for contact-sensitive non-PET plastics

- 30% for single-use plastic beverage bottles

- 35% for other plastic packaging

By 2040 the targets climb significantly, reaching up to 65% recycled content for single-use beverage bottles and other plastic packaging.

Some packaging types such as compostable plastics and medical devices get a pass on these specific targets.

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Reuse & refill: recycling isn’t the only answer

The regulation also pushes reuse, especially where it already makes practical sense.

- Transport packaging (B2B): By 2030, at least 40% of pallets, crates, drums and boxes used within the EU must be reusable, with an ambition of 70% by 2040.

- Beverages (B2C): By 2030, at least 10% of alcoholic and non-alcoholic drinks must be offered in reusable packaging.

- Refill: From 12 February 2027, hotels, restaurants and cafés must let customers bring their own containers for drinks and ready-made food.

- Reuse systems: From 12 February 2028, those same businesses must also offer packaging as part of a reuse system.

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Waste prevention: less packaging, full stop

The simplest way to cut waste is to create less of it and the PPWR makes that official. If your business uses grouped, transport, or e-commerce packaging, PPWR now has a very clear message: stop shipping air. The regulation caps the empty space ratio at 50%, and it has a surprisingly strict view of what counts as “empty”. All those familiar helpers like paper cuttings, bubble wrap, air cushions, foam fillers, wood wool, even good old polystyrene chips are officially just air with extra steps. Stuffing a box full of fillers does not save you; the box itself has to shrink.

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Bans and restrictions: some packaging is simply out

From 12 August 2026, food-contact packaging containing PFAS (per- and polyfluoroalkyl substances) above set thresholds is banned. For example, targeted analysis must stay below 25 ppb. This is a major hurdle for grease-proof papers and barrier coatings that have relied on PFAS to do the hard work.

From 1 January 2030, several familiar packaging formats disappear altogether:

- Grouped packaging: Single-use plastic used to bundle cans or bottles (such as shrink wrap or collation films) is banned.

- Fresh produce: Single-use plastic packaging for less than 1.5 kg of unprocessed fruit and vegetables is banned (with limited exceptions where packaging is needed to prevent water loss or quality issues).

- HORECA: Single-use plastic plates, cups, trays, and sugar or condiment sachets used on hotel, restaurant and café premises are banned.

- Miniature cosmetics: Single-use plastic shampoo bottles and lotions in hotels and other accommodation are banned.

The message is clear: if a packaging format is hard to justify or easy to avoid, the PPWR isn’t interested in keeping it around.

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Harmonised labelling: same rules, same bins

To stop consumers guessing, packaging labels will look the same across the EU.

- From 12 August 2028: packaging must show a harmonised label identifying its material.

- Bins must match: waste containers will carry the same labels, so it’s clear what goes where.

- Reusable packaging: must be clearly marked as reusable, with extra information (like return points) available via a QR code or similar.

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“Recyclable” by 2030 vs. “recycled at scale” by 2035

One final and important distinction:

- Recyclable (2030): the packaging is designed so it can be recycled.

- Recycled at scale (2035): the packaging is actually being collected, sorted and recycled in real life.

To count as “recycled at scale”, the EU must have the infrastructure in place to recycle the material at a rate of at least 55% (or 30% for wood). From 1 January 2035, packaging that doesn’t meet this test won’t stay on the market.

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Who Is Affected?

The scope of the PPWR is broad - very broad. If you do business in the EU and touch packaging at any point, chances are this regulation touches you too, no matter where you’re based.

The rules apply to all packaging (B2C and B2B), all packaging materials, and all packaging waste. In other words: if it wraps, holds, protects or ships a product, it’s in scope.

The regulation uses the term “economic operators”, but what it really means is pretty much everyone involved in getting a packaged product to market, including:

- Manufacturers: Companies that make packaging under their own name or brand.

- Importers: Businesses bringing packaged goods in from outside the EU.

- Distributors & fulfilment service providers: The organisations that move products along the supply chain and into customers’ hands.

- Final distributors: Retailers and HORECA businesses (hotels, restaurants and catering) selling packaged products to the end user.

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What types of packaging are covered?

All of them, at every stage:

- Sales packaging: The packaging you see on the shelf (think yoghurt pots).

- Grouped packaging: Packaging that bundles products together (like cardboard wraps around multipacks).

- Transport packaging: Pallets, boxes and wrapping used to get products from A to B.

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Timeline

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What Companies Have to Do to Comply (And Why Data is Key)

PPWR compliance isn’t a quick box-ticking exercise, it’s a data workout. To keep selling in the EU, companies must be able to prove they comply, through a formal conformity assessment and a solid set of technical documents to back it all up.

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The data reality check

For every single packaging SKU, you’ll need clear, reliable data showing:

- Minimisation: The packaging uses no more weight or volume than it absolutely needs to do its job.

- Composition: Exactly what it’s made of, right down to individual components (yes, the cap and the bottle are counted separately).

- Recyclability: The design meets the official “Design for Recycling” (D4R) criteria.

- Recycled content: The precise share of post-consumer recycled plastic used.

- Chemical safety: Substances of concern (such as PFAS) are kept to a minimum; or better yet, not there at all.

In short, if the data isn’t there, compliance isn’t either. Under the PPWR, knowing your packaging inside out isn’t just helpful, it’s essential.

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Why starting with an LCA is a smart move

PPWR might not explicitly tell you to run a life cycle assessment (LCA), but it quietly sets you up to do exactly that. Many of the data points PPWR demands, from material composition and weights to volumes, transport, and reuse behaviour, are the same ingredients an LCA needs. Do an LCA properly, and you will suddenly realise you are holding most of the answers PPWR is asking for. Compliance becomes less of a scavenger hunt and more of a by-product.

PPWR is not just about following rules, it is about making packaging better. If you want to prove that a lighter box, a new material, or a shiny new manufacturing process is actually more sustainable, and not just different, LCA is your reality check. PPWR tells you what to fix; starting with an LCA shows you whether you fixed the right thing.

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How Pilario Can Help

The PPWR transforms packaging compliance into a massive data management exercise. You need to assess thousands of SKUs, calculate weight ratios, track chemical composition, and model recyclability scores, all while preparing for mandatory digital reporting.

Pilario is designed to navigate this complexity. As a platform rooted in LCA expertise and data management, Pilario helps you turn this regulatory burden into a competitive advantage.

1. Data Collection & Organisation: Pilario helps you gather and structure the granular data required for PPWR technical documentation across your entire product portfolio. From component weights to material origins, we ensure your data is audit-ready.

2. Integrated LCA & Eco-Design: Because Pilario is an LCA tool, we allow you to leverage your compliance data to run full environmental assessments. You can compare different packaging prototypes to see which one not only meets the Grade A recyclability standard but also has the lowest carbon footprint.

3. Future-Proofing: With the "Recycled at Scale" and Digital Product Passport requirements on the horizon, you need a system that offers traceability. Pilario acts as the central hub for your packaging's environmental intelligence, ensuring you are ready for 2030 and beyond.

If you’re ready to move beyond compliance and turn packaging data into smarter design decisions and a competitive edge, Pilario is ready to help.