The Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) came into force on February 11, 2025. However, it is not applicable until August 12, 2026.
The PPWR does not completely replace the directive immediately. There are numerous transitional periods. The requirements of the Packaging Directive 94/65/EC, including all national transpositions, remain fully valid until the date of application of the respective provisions.
The following is a selection of transitional provisions and deadlines. Many harmonized standards and implementing acts can be expected at the specified dates, which specify the requirements of the PPWR.
In individual cases, this means, for example, that the implementing act for harmonized marking is to be published by August 12, 2026. The requirements described therein will only apply from August 12, 2028 or 24 months after the expected implementing act comes into force. For companies, this means that the Packaging Directive and the national implementations of the labels (e.g. Triman) are expected to be complied with by August 12, 2028.
If you have any questions about the PPWR, please contact us or attend our Material & Environmental Compliance Officer training course (in German language). Among other things, the requirements for producers of packaged products are highlighted and it is described why there should be an EU declaration of conformity but no CE marking for the packaging.
Europen (European organization for packaging and the environment) has published an interactive guide to help you understand your own obligations and any applicable exemptions.
February 12, 2026
- Implementing act expected:
- Reporting to registers
- Harmonized standard expected:
- Compostability
August 12, 2026
Start of general application (start of transition repeal of Directive 94/62/EC)
- Implementing act expected:
- Harmonized labelling
- Indication of the material composition
- Concentration of heavy metals
- PFAS Ban on food contact
- EU declaration of conformity + technical documentation
- Producer labeling (Art. 15), importer labeling (Art. 18)
December 31, 2026
- ECHA study on substances of concern in packaging expected
- Implementing act expected:
- Review of the recycled content
- Sustainability criteria
February 12, 2027
- Member states have defined sanctions
- Harmonized standard expected:
- Calculation of minimization of packaging
- Delegated act expected:
- Minimum number of reusability
- EPR packaging may be labeled with QR code
- Guideline for food contact expected
June 06, 2027
- Implementing act expected:
- Calculation of reuse targets
January 01, 2028
- Harmonized standard expected:
- Recyclability
- Delegated act expected:
- Detailed conditions and reporting obligations
February 12, 2028
- Implementing act expected:
- Empty space calculation
- Hospitality reuse system
August 12, 2028
- Application of harmonized labelling
(or from 24 months after entry into force of the implementing acts on labeling expected from August 12, 2026) - Labeling of waste containers
January 01, 2029
- Compliance with implementing act
- Recyclate content
February 12, 2029
- Compliance with implementing act
- Labeling for reusability (QR code)
- Avoidance of packaging waste: at least 5%
January 01, 2030
- Minimum recycled content to be complied with in plastic packaging
- Minimization of packaging to be complied with
- All packaging must be recyclable "Design for recycling"
- Exception up to 5 years: innovative packaging
- Recycling target (obligation to provide evidence)
- Transport/sales packaging: min. 40%
- Storage/distribution unit: at least 10%
- Implementing act expected:
- Assessment of "recycled on a large scale"
- Indication of substances of concern
- Empty space ratio max. 50% (e-commerce)
- Ban on single-use packaging in accordance with Annex V
- Aim for refill stations Food
February 12, 2030
- Implementing act expected:
- Minimum requirements for public contracts for packaging
Would you like to read more about material compliance and packaging? Then you can find more content here:
→ France and Spain: Infringement proceedings from March 10, 2025
We are also happy to provide you with further details.
Author's note
This article has been machine translated into English.
DEFINITIONS AND ABBREVIATIONS
The Triman logo is a French symbol for recycling that can be found on recyclable products and packaging. It indicates that these must be disposed of separately from residual waste in order to ensure proper recycling.
