Short answer: PPWR is the EU's Packaging and Packaging Waste Regulation. Its official reference is Regulation (EU) 2025/40. It has applied since 12 August 2026 and covers all packaging entering the EU market. A company outside the EU is affected through the role it holds for that packaging.
If you sell packaging or packaged goods to the EU, your buyer now asks you for PPWR information and documents. This article is a general introduction: what the Regulation is, what it covers, which requirements apply today and which are tied to later dates. The information was read from the sources on 13 October 2026. Each fact carries its article number.
What is PPWR and what does it stand for?
PPWR stands for Packaging and Packaging Waste Regulation. It is Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024, published in the Official Journal on 22 January 2025.
The Regulation sets environmental sustainability and labelling requirements for the entire life-cycle of packaging, so that it can be placed on the market. It also covers extended producer responsibility and the prevention, collection and recycling of packaging waste (Art. 1(1)).
Is PPWR a regulation or a directive?
It is a regulation. Under its closing provision it is binding in its entirety and directly applicable in all Member States. The text it replaces, Directive 94/62/EC, was a directive. That directive was repealed with effect from 12 August 2026, apart from a few provisions (Art. 70(1)).
Local names vary. In Turkish, many people search for it under the word for a national by-law, while Türkiye's Ministry of Trade uses the word for an EU regulation. In your documents, write "Regulation (EU) 2025/40".
Since when has PPWR applied?
The Regulation entered into force on the twentieth day after its publication (Art. 71). The Commission's guidance notice gives that date as 11 February 2025. It has applied since 12 August 2026 (Art. 71). Some requirements start later, on dates set in the Regulation or tied to secondary legislation. See the table below.
Which packaging does PPWR cover?
The Regulation applies to all packaging, regardless of the material used, whether it is used in industry, retail, offices or households (Art. 2(1)). Three types are defined separately:
| Type | Definition | Source |
|---|---|---|
| Sales packaging | Packaging that forms, with the product, a sales unit for the end user at the point of sale. | Art. 3(1)(5) |
| Grouped packaging | Packaging that groups a certain number of sales units and can be removed without affecting the product's characteristics. | Art. 3(1)(6) |
| Transport packaging | Packaging that eases handling and transport and prevents damage to the product. Road, rail, ship and air containers are excluded. | Art. 3(1)(7) |
Annex I gives an indicative list of items that count as packaging (Art. 3(2)). According to Türkiye's Ministry of Trade, wooden pallets, stretch film, strapping and cardboard boxes also count as packaging to the extent that they protect or transport the product. Packaging that never reaches the final consumer is not out of scope for that reason.
How does PPWR affect a company outside the EU?
According to Türkiye's Ministry of Trade, the Regulation does not define an "exporter". Obligations follow from your role in the supply chain.
- Manufacturer: whoever makes the packaging or the packaged product. If someone else has it designed or made under their own name or trademark, they are the manufacturer (Art. 3(1)(13)). The manufacturer carries out the conformity assessment, draws up the technical documentation and issues the EU declaration of conformity (Art. 15(2)).
- Supplier: whoever supplies packaging or packaging material to a manufacturer (Art. 3(1)(16)). It gives the manufacturer all the information and documents needed to demonstrate conformity (Art. 16).
- Importer: established in the EU and placing packaging from a third country on the market (Art. 3(1)(17)). It ensures the manufacturer has carried out the assessment (Art. 18(2)). If it places packaging on the market under its own name or trademark, it is treated as the manufacturer (Art. 21).
According to Türkiye's Ministry of Trade, a company that makes packaging under its own brand and sells it to the EU can be treated as the manufacturer, and one selling material to an EU manufacturer as a supplier. A warehouse, branch or subsidiary in the EU does not settle your role on its own.
Which requirements have applied since 12 August 2026?
- Heavy metal limit. The sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg (Art. 5(4)).
- PFAS limit. Food-contact packaging only, with three thresholds (Art. 5(5)). For the detail, see PPWR PFAS limits and testing.
- Conformity assessment, technical documentation and EU declaration of conformity. The manufacturer completes them before placing on the market (Art. 15(2), Art. 38, Art. 39).
- Identification. Packaging carries a type, batch or serial number and the manufacturer's name and postal address (Art. 15(5)-(6)). The importer adds its own name and address (Art. 18(3)).
What buyers call a "PPWR certificate" is the declaration in the third point. Who issues it and what goes into it is explained step by step in our article on the PPWR declaration of conformity.
Which requirements have not started yet, and when do they start?
| Date | What happens | Source |
|---|---|---|
| 31 December 2026 | The Commission sets the method for calculating and verifying recycled content in plastic by this date. | Art. 7(8) |
| 1 January 2028 | The Commission adopts the design for recycling criteria and performance grades by this date. | Art. 6(4) |
| 12 August 2028 or later | Harmonised label on material composition. The date moves to 24 months after the implementing act if that is later. Transport packaging other than e-commerce packaging is outside this label. | Art. 12(1) |
| 1 January 2030 or later | Packaging outside grades A, B and C cannot be placed on the market. Minimum recycled content in plastic starts. Both dates can move later depending on secondary legislation. | Art. 6(3), Art. 7(1) |
| 1 January 2038 | Only grade A and B packaging can be placed on the market. | Art. 6(3) |
According to Türkiye's Ministry of Trade, digital labelling and the digital product passport did not start on 12 August 2026 either, and some EU buyers may ask for labels or information that are not mandatory yet. Such requests are not obligations under the Regulation.
What is the penalty for not complying with PPWR?
The Regulation sets no amounts. Member States lay down their rules on penalties by 12 February 2027. Penalties must be effective, proportionate and dissuasive (Art. 68(1)). Penalties for failing to comply with the articles on excessive packaging, restricted packaging formats, re-use and refill (Art. 24 to 29) include administrative fines (Art. 68(2)).
The date for penalty rules does not postpone the obligations. Packaging may only be placed on the market if it complies with the Regulation (Art. 4(1)). An importer may not place packaging it believes non-compliant on the market until it conforms (Art. 18(2)). A manufacturer must bring non-compliant packaging into conformity, withdraw it or recall it (Art. 15(8)). Authorities endeavour to check at least part of the declarations each year (Art. 39(5)).
Where should you start?
- List the packaging for every product going to the EU: sales, grouped and transport packaging separately.
- Settle your role for each.
- Check today's four requirements for each.
- Put the later dates in your calendar.
The Registamp PPWR module keeps your packaging records, your role and the documents for the requirements in force today in one place. See the PPWR module page.
This article is general information, not legal advice. For your own case, refer to the text of the Regulation and, where needed, to a specialist.
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste: eur-lex.europa.eu/eli/reg/2025/40/oj
- European Commission guidance notice, C(2026) 3702 final, 5 June 2026: EUR-Lex
- Ministry of Trade of Türkiye, PPWR announcement and information note, 3 August 2026 (in Turkish): ticaret.gov.tr