PPWR – the EU Packaging Regulation: What applies from 12 August 2026
Regulation (EU) 2025/40 on packaging and packaging waste – PPWR for short – has been directly applicable in all EU member states since 12 August 2026. This overview makes a clear distinction: what applies now, what is being phased in until 2030 – and what role the German implementation act plays.
What is the PPWR?
The PPWR is an EU regulation – unlike the previous Packaging Directive 94/62/EC, it applies directly without needing to be transposed into national law. It entered into force on the twentieth day following its publication and has applied since the 12 August 2026 Art. 71 PPWR. It harmonises requirements for packaging across the entire lifecycle: from substance restrictions, recyclability, recycled content, minimisation and labelling to reuse and extended producer responsibility.
These obligations have been in force since 12 August 2026
- Fabric restrictions: Limit values for substances of concern in packaging, including PFAS limits for food-contact packaging (e.g. 50 ppm for PFAS including polymeric PFAS) Article 5(4) and (5) PPWR. This is demonstrated in the technical documentation. Art. 5(6) PPWR.
- Compliance obligations: Before placing the products on the market, manufacturers carry out the conformity assessment procedure and draw up the technical documentation and provide the EU Declaration of Conformity from Art. 15(2), Art. 38, 39 PPWR.
- Role obligations along the supply chain: Specific catalogues of obligations for manufacturers, importers, distributors and fulfilment service providers Articles 15, 18, 19 and 20 of the PPWR – who which Role has, the actual activities are decisive.
- Recyclability as a principle: All packaging placed on the market must be recyclable Article 6(1) PPWR; the specific design criteria and performance levels apply in a phased manner (see below).
This will be staggered: 2027 to 2030
- Design for recycling: The performance-based design requirement applies from 1 January 2030 (or 24 months after the delegated acts, whichever is later); the requirement for „large-scale“ recycling follows from 2035 Art. 6(2) PPWR.
- Minimum recycled plastic content in plastic packaging: from 1 January 2030 (or three years after the implementing act) – e.g. 30 % for PET contact packaging, 35 % for other plastic packaging; higher levels from 2040 Art. 7(1), (2) PPWR.
- Void ratio: a maximum of 50 % for retail, transport and e-commerce packaging from 1 January 2030 (or three years after the implementing act) Art. 24(1) PPWR.
- Bans on certain packaging formats: The formats and uses listed in Annex V shall no longer be placed on the market from 1 January 2030 Art. 25 para. 1 PPWR.
- Reuse targets: from 1 January 2030, at least 40 % reusable transport packaging items of the specified types within a reuse scheme Art. 29(1) PPWR.
- Labelling The harmonised labelling (material composition, sorting instructions) will be introduced in phases following the adoption of implementing acts; regarding detailed questions on the start of the application period for individual labelling obligations, there are currently unresolved interpretation issues (!) – we will add to this point as soon as a reliable classification is available Article 12 PPWR.
Germany: the Packaging Act
Even a directly applicable regulation requires national implementation – administrative responsibilities, maintenance of registers, sanctions. In Germany, this is handled by Packaging Act Implementation Act this task. It was published in the Federal Law Gazette on 17 July 2026 and essentially entered into force on 12 August 2026 Federal Law Gazette 2026 I No. 207. For the declaration of conformity, there is a practical language rule there: at the manufacturer's discretion, it can be issued in German or English. Section 62 of the Packaging Act.
The first steps
The applicable obligations result in a clear sequence: clarify roles per product line, record the packaging portfolio, check material restrictions, assess and document conformity, issue a declaration – and schedule the 2030 deadlines into packaging development. A prioritised step-by-step overview with references can be found in our PPWR checklist; the quick start is offered by the Summary.
Frequently Asked Questions
From when does the PPWR apply?
The PPWR applies directly in all EU member states from 12 August 2026 (Art. 71 PPWR). Individual requirements such as recycled content, empty space limits, format bans and reuse targets will apply in stages from 2030.
Does the PPWR have to be transposed into German law?
No – as a regulation, it applies directly. The German Packaging Act (VerpackDG) additionally governs implementation, responsibilities, and sanctions (BGBl. 2026 I No. 207).
Are fines already looming?
The obligations have been in force since 12 August 2026. However, the German fine provisions for infringements of the PPWR obligations are only to be applied from 12 February 2027 (Section 66(2), Section 68(17) of the Packaging Act (VerpackDG)).
The PPWR applies. Do you know what this means for your packaging?
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This article provides an explanation and overview; it does not constitute legal advice and is no substitute for an assessment of the individual case. Sources: Regulation (EU) 2025/40 (PPWR, OJ L of 22 January 2025), Packaging Law Implementation Act (VerpackDG, Federal Law Gazette 2026 I No. 207). Legal status: 12 August 2026.