Regulation (EU) 2025/40 on packaging and packaging waste (‘PPWR’) was published on 22 January 2025 in the EU official journal. It will apply from 12 August 2026.

The regulation, repealing the existing Directive 94/62/EC on packaging and packaging waste (‘PPWD’) introduces more stringent, circularity-oriented obligations.

Unlike the previous regulation, the PPWR will be directly enforceable in all EU Member States, thereby fostering the harmonization of packaging-related legislation across the EU. However, it remains to be seen whether Member States will utilize some of flexibility offered by the legislation to adjust the requirements to their national ambitions.

Obligations will apply to all packaging placed on the EU market, whether it is manufactured in the EU or in third countries.

The regulation’s requirements further cover the packaging’s full life cycle, from the design stage (e.g. composition requirements, recyclability, recycled content), through the use stage (e.g. reusability, empty space minimization) up until the waste stage. Hence, the regulation will affect the whole packaging supply chain. 

While the legislative work on the file has come to an end, the Commission is tasked in the months and years to come with the elaboration of a wide array of acts of execution (i.e. implementing and delegated acts) which will ultimately frame the scope of the regulation’s requirements (e.g. recyclability and reusability criteria, labeling requirements, reuse targets).

The elaboration of each of these acts will constitute a major opportunity for further dialogue between the Commission and stakeholders. Key engagement and advocacy strategies can deliver real results where implementation and compliance may pose challenges to future business operations.