The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, applies from 12 August 2026 and replaces Directive 94/62/EC directly across all 27 Member States. If you import or distribute packaged goods in the EU, PPWR makes you responsible for packaging you did not design.

This guide summarises what the regulation requires, when each obligation starts, and what to ask your suppliers for.

1. PPWR at a Glance

PPWR covers the full life of packaging — design, composition, labelling, market placement, collection and end-of-life — and applies to sales, grouped, transport and service packaging.

2. The Liability Gap

This is the part most trading companies get wrong. Under PPWR, an EU-established company that places packaging or packaged goods from outside the Union onto the EU market is the importer, and must verify — before placing goods on the market — that the manufacturer completed the conformity assessment, technical documentation, declaration of conformity, and labelling. You cannot shift that responsibility to a third-country supplier: if a supplier ships non-compliant packaging, the EU importer answers for it.

There is a second trap. Under Article 21, if you place packaging under your own name or trademark, or modify it in a way that could affect compliance, you are treated as the manufacturer — taking on the full Article 15 obligations rather than the lighter importer set.

In practice, the problem is usually proof, not performance: verified substance data, recycled-content evidence, and material breakdowns from every link in the chain.

3. Why a Regulation, and What It's Trying to Achieve

Directive 94/62/EC left implementation to national authorities, producing 27 diverging systems for extended producer responsibility, labelling and packaging marking. A regulation applies directly and identically — one rulebook, less room for national add-ons. The Commission's own figures put 40% of EU plastics and 50% of paper use into packaging, and packaging at 36% of municipal solid waste, with volumes still rising while reuse and recycling stayed low.

PPWR sets four objectives:

● Reduce packaging waste per capita vs a 2018 baseline: 5% by 2030, 10% by 2035, 15% by 2040 (Art. 43).

● Make all packaging recyclable: designed for recycling from 1 Jan 2030 and recyclable at scale from 1 Jan 2035. Packaging below grade C loses market access from 2030; grade B minimum applies from 2038 (Art. 6).

● Close the material loop with binding minimum recycled plastic content, calculated per manufacturing plant per year (Art. 7) — see table below.

● Harmonise the internal market: compliant packaging circulates freely, and Member States cannot add conflicting national requirements.

Only post-consumer recyclate counts. Supporting targets: packaging recycling rates rise to 70% by 2030; deposit return systems for single-use plastic/metal beverage containers must reach 90% separate collection by 1 Jan 2029 (Art. 50).

4. The Compliance Timeline

Recyclability grades: A ≥95%, B ≥80%, C ≥70% recyclable by weight (Annex II, Table 3); below 70% is treated as non-recyclable. The calculation criteria sit in delegated acts not yet published, so no company can grade its portfolio with certainty today.

5. Who Is Responsible for What

Obligations follow your role, not your location. Many companies hold more than one role without realising it.

The Article 17 (conformity) and Article 45 (EPR) representatives are different appointments — one mandate does not cover both. Under the Article 21 micro-enterprise exception, where the importer or distributor is a micro-enterprise and the supplier is EU-based, that supplier is treated as the manufacturer.

6. Key Terms You Will Keep Meeting

● Placing on the market — first making available on the EU market; the trigger for most obligations.

● Making available — any commercial supply, paid or free.

● Sales / grouped / transport packaging — primary / secondary / tertiary packaging in older vocabulary.

● Design for recycling (DfR) — packaging designed so materials can be recycled without disrupting other waste streams; criteria due by 1 Jan 2028.

● Recycled content — share of post-consumer plastic waste in the plastic part, averaged per plant per year.

● Substances of concern (SoC) — substances harming reuse/recycling or health/environment; PFAS in food-contact packaging is the headline restriction.

● Empty space ratio — unused volume, capped at 50% for grouped/transport/e-commerce packaging from 2030 (Art. 24).

● EU declaration of conformity (DoC) — manufacturer's signed statement of compliance (Annex VIII).

● Extended producer responsibility (EPR) — producer's financial responsibility for collection, sorting and treatment of packaging waste, with fees modulated by recyclability grade.

7. Industrial Chemical Packaging

Most PPWR commentary targets consumer goods and e-commerce. Industrial chemicals sit differently. Drums, IBCs, jerricans, pails, FIBCs, liners, pallets and stretch film — and their labelling — are all packaging under PPWR.

7.1 Sales or transport packaging?

Transport packaging facilitates handling of a number of sales units to prevent transit damage; sales packaging is the unit delivered to the end user. For bulk B2B chemicals, a 200-litre drum or 1,000-litre IBC is normally the sales unit itself — logistics language calls it "transport packaging," but the regulation's definition points to sales packaging. The classification flips where the container groups goods that already have their own sales packaging, or moves product between a company's own sites. Record the reasoning in your technical file.

Reuse targets (Art. 29) do not turn on this distinction — they cover both transport packaging and sales packaging used for transport.

7.2 Non-hazardous chemical packaging

● Recyclability: drums, IBCs and liners must reach grade C from 2030 and grade B from 2038; multi-layer/non-separable liners are the main risk (grading criteria not yet published).

● Recycled content: falls in the general plastic band — 35% post-consumer recyclate by 2030, 65% by 2040 (post-industrial doesn't count); plastic parts under 5% of total pack weight are excluded (Art. 7(5)). Recyclate-in-regulated-substance qualification takes time — start now.

● Minimisation: from 2030, weight/volume must be minimised for functionality against Annex IV criteria.

● Empty space: 50% cap on grouped/transport packaging from 2030; obligation sits with the filling party.

7.3 Dangerous goods packaging

● Directive 2008/68/EC (inland transport of dangerous goods) prevails where the two frameworks conflict; UN certification is not overridden.

● Recyclability requirements (Art. 6) and reuse targets (Art. 29) do not apply to packaging used for dangerous-goods transport — exempted alongside medicinal products, medical devices and infant/medical food packaging.

● The exemption is time-limited: the Commission must review it by 1 Jan 2035 (Art. 6(12)).

● Not exempt: Art. 5 substance restrictions, Art. 7 recycled content, technical documentation and DoC, labelling, EPR registration and fees, and importer verification duties. Dangerous-goods status removes two design obligations — it removes no documentation obligations.

7.4 What to request from a non-EU supplier

Set a response deadline — suppliers who cannot answer within a reasonable window are a compliance risk to flag now, not in August.

8. How PPWR Sits Alongside Other EU Rules

● Directive 2008/68/EC (dangerous goods transport) — PPWR gives way where the two conflict.

● Single-Use Plastics Directive (EU) 2019/904 — amended by PPWR; certain formats restricted or banned (Art. 25, Annex V).

● REACH and CLP — substance restrictions continue to apply; PPWR adds packaging-specific duties on top.

● Food contact rules — Regulation (EC) 1935/2004 and (EU) 2022/1616 apply in parallel with PPWR's PFAS thresholds.

● Ecodesign for Sustainable Products Regulation (EU) 2024/1781 — ESPR covers products, PPWR covers their packaging; a shared digital product passport should carry both data sets.

9. Consequences of Non-Compliance

Three things can happen, and they compound: market access is blocked (shipments held or rejected); corrective action — withdrawal or recall, with authorities informed — is required where non-compliance is suspected; and penalties, set by each Member State to be effective, proportionate and dissuasive, apply. There is also a commercial cost: eco-modulated EPR fees mean poorly graded packaging costs more every year, inspected or not.

10. Action Checklist

A. Establish your role

☐ List every packaging type you place on or make available in the EU

☐ Identify your role per type: manufacturer, importer, distributor, or more than one

☐ Check the Article 21 trigger — do you brand or modify any of it?

B. Build the document chain

☐ Obtain/issue an EU DoC and confirm technical documentation exists for each type

☐ Set retention (5/10 years) and a process to answer authorities within 10 days

☐ Confirm name, trade name and address appear on packaging or accompanying docs

C. Close the supply-chain data gap

☐ Send a supplier information request (Section 7.4) to every packaging supplier

☐ Track responses; flag suppliers who cannot provide evidence

☐ Confirm recycled content offered is post-consumer, not post-industrial

☐ Identify single-source packaging with no compliant alternative — highest risk

D. Registration and EPR

☐ Register in the national producer register of every relevant Member State (Art. 44)

☐ Appoint an EPR authorised representative where not established (Art. 45)

☐ Budget for eco-modulated, not flat, fees

E. Review the packaging itself

☐ Check empty-space ratios ahead of 2030; screen food-contact packaging for PFAS ahead of Aug 2026

☐ Map packaging likely to fail design-for-recycling criteria once published

☐ Document which packaging qualifies for the Art. 6(11)/Art. 29 dangerous-goods exemptions

F. Distributors specifically

☐ Verify labelling before making packaging available; confirm upstream obligations met; document a refusal process for non-conforming stock

11. How FORU Chemtech Supports Customer Compliance

12. FAQ

When does PPWR come into force?

11 February 2025; applies from 12 August 2026. Compostable packaging follows in Feb 2028; design-for-recycling, recycled content, minimisation and the empty-space cap start 1 Jan 2030.

Can I pass PPWR responsibility to my non-EU supplier?

No. As EU importer you carry legal responsibility for compliance; you can require documentation, but liability stays with you.

I only rebrand and resell — am I a manufacturer?

Yes, if you place packaging under your own name or trademark. Article 21 gives you the full Article 15 obligations.

Do I need an authorised representative?

Depends which one: the Article 17 conformity representative is optional (one mandate covers the EU); the Article 45 EPR representative is mandatory wherever you're not established. They are separate appointments.

Does PPWR apply to drums and IBCs?

Yes — transport packaging is packaging under PPWR. Minimisation, recyclability and substance rules apply, subject to the dangerous-goods exemptions.

What are the PFAS limits?

From 12 Aug 2026, food-contact packaging is barred where PFAS exceed: 25 ppb per individual non-polymeric PFAS, 250 ppb summed, or 50 ppm total organic fluorine (Art. 5). Guidance proposes screening total fluorine first — below 50 ppm, no further testing is needed.

Is dangerous-goods packaging exempt from PPWR?

Partly — exempt from Art. 6 recyclability and Art. 29 reuse targets, and Directive 2008/68/EC prevails on conflict, subject to review by 1 Jan 2035. Not exempt from substance restrictions, recycled content, documentation, labelling or EPR.

Official Sources

● Regulation (EU) 2025/40, full text — EUR-Lex

● European Commission, Packaging and packaging waste — policy page, guidance document and FAQ

● Delegated Decision (EU) 2026/429 — pallet wrappings and straps

● Directive 2008/68/EC on the inland transport of dangerous goods

● Directive (EU) 2019/904 on single-use plastics, as amended