One of the European Union’s key objectives is to develop and implement successive strategies aimed at reducing negative environmental impacts and advancing the transition to a circular economy. Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC, is a part of this effort.
Packaging plays a crucial role in protecting products and facilitating their transport. However, it also constitutes a significant part of the global waste problem, not only generating large amounts of waste but also consuming valuable raw materials required for its production.
According to European Commission, as much as 40% of plastics and 50% of paper used in the EU are intended for packaging production. The growth in consumption worldwide is causing a continuous increase in packaging waste volumes, not only within the EU but globally. European Commission projections indicate that, without appropriate action, the amount of plastic packaging waste would increase by nearly 50% by 2030.
PPWR therefore imposes a range of additional obligations on businesses. According to the European Commission's objectives, compliance with the Regulation should give consumers confidence that both packaging manufacturers and sellers are committed to environmental sustainability, implement recycling practices, and ensure that packaging is designed for reuse wherever applicable.
Who will be subject to PPWR requirements?
Producers – companies manufacturing and packaging products in packaging.
Importers – entities placing goods from outside the European Union on the EU market.
Exporters – entities exporting goods to other countries.
Distributors and retailers – brick-and-mortar stores as well as e-commerce platforms.
Private label owners – entities marketing products under their own brand name.
Hospitality sector – restaurants and hotels.
Important! If your company falls into one or more of these categories – you must demonstrate that its operations comply with the requirements of the PPWR.
What obligations does the PPWR impose?
Limits on chemical substances in packaging
Conformity assessment and technical documentation
Manufacturers must implement an internal production control system. In addition, they are required to prepare technical documentation for each packaging type, demonstrating compliance with the requirements of the Regulation.
EU Declaration of Conformity
Before placing packaging on the market, an EU Declaration of Conformity must be drawn up. This document must be retained for 5–10 years after the last unit of a given packaging type has been placed on the market.
Recyclability
The Regulation introduces three recyclability performance classes: A, B, and C. The assigned class depends on the packaging material composition, packaging design, and the availability of recycling processes. Packaging classified as Class D must be phased out of the market from 2030 onwards.
Labelling
Packaging must display the manufacturer's name, address, and a QR code or another digital data carrier. This obligation will apply from 12 August 2028.
EPR registration and record-keeping
National regulations (draft Act UC100) require producers to maintain packaging records within the EPR system, pay Extended Producer Responsibility fees, and report the weight and types of materials used in packaging.
How can we support businesses in implementing the PPWR?
The PPWR is not only about new obligations – it also requires companies to redesign packaging, processes, and documentation. We help businesses prepare for the new requirements in a comprehensive and practical way by offering:
From packaging assessment to full PPWR compliance – we help businesses translate legal requirements into practical and effective business actions.
We encourage you to contact us and see how our expertise can help you navigate PPWR requirements faster, more effectively, and without complications!
