PPWR: What Will Change in Packaging and What Obligations Await Businesses?

The Packaging and Packaging Waste Regulation (PPWR) introduces harmonized requirements across the entire European Union regarding packaging and packaging waste. These rules cover design, material composition, labeling, recycling, reuse, and compliance documentation.

The regulation entered into force on February 11, 2025, and the majority of its provisions will apply starting August 12, 2026. Further requirements will be implemented in phases, which is why businesses should begin organizing their packaging data now and determine which obligations apply to their operations.

PPWR: Definition and Objectives

PPWR refers to EU Regulation 2025/40 on packaging and packaging waste. Replacing the former Directive 94/62/EC, it applies directly in all EU member states.

The new regulations aim to reduce packaging waste, decrease packaging weight and volume, and promote design for recycling. Key objectives also include expanding reuse systems, supporting a circular economy, and increasing the proportion of recycled content.

Because not all obligations will apply simultaneously and detailed rules will be clarified through subsequent implementing acts, businesses must stay informed about the rollout schedule.

Who and What Does PPWR Cover?

PPWR applies to all packaging placed on the EU market, regardless of the material or industry. It encompasses sales (primary), grouped (secondary), transport (tertiary), and e-commerce packaging.

The scope of obligations depends on a company’s specific role. Packaging Manufacturers are primarily responsible for the design, material compliance, and technical documentation. Importers must verify that products brought in from outside the EU meet all requirements and possess the necessary paperwork. Distributors must check basic product compliance information. Brand Owners / Packaging Companies filling their own cosmetics are responsible for the entire assembled package, its labeling, and minimizing unnecessary elements (primarily reducing weight and volume).

For cosmetic packaging, compliance evaluations extend beyond the bottle or jar to include the pump, cap, label, seal, outer carton, and any other components that make up the finished package.

PPWR vs. Existing Regulations

Previous laws focused mainly on overall recovery and recycling targets. PPWR places much greater emphasis on how packaging is designed.

Businesses must demonstrate that their packaging:

• Contains no unnecessary structural elements
• Uses the minimum material necessary
• Is designed for recycling
• Is properly labeled
• Meets restrictions on hazardous and restricted substances

PPWR does not replace all national obligations; registration, reporting, and financial settlements under Extended Producer Responsibility (EPR) frameworks remain mandatory.

A Roadmap of Business Obligations

The first step is identifying your company’s legal role for every piece of packaging used. A manufacturer of empty containers, an importer, and a brand launching a finished product each face different duties.

A baseline audit should include:

• A complete inventory of all packaging components used
• Material composition and weight for each component
• Supplier data and distribution markets
• Technical documentation and declarations of conformity
• Recycled content percentages and recyclability evaluations

Companies packaging their own products must evaluate the complete assembly. Individual components might be compliant on their own, but when combined, they may hinder material separation or recycling.

Packaging Design Compliant with PPWR

PPWR requires packaging weight and volume to be reduced to the minimum necessary to ensure product safety, transport durability, hygiene, and mandatory information display. However, this does not mean downsizing at any cost—an overly light or poorly fitted structure can lead to damage, leaks, and product loss.

When evaluating packaging, verify:

• Whether the size corresponds to the actual product volume
• If material weight can be reduced without compromising protection
• Whether different components can be easily separated
• If labels, adhesives, dyes, or coatings hinder recycling
• If the pump or closure matches the primary packaging material

Assessments should cover the complete package, not just the largest part. Partnering with an experienced cosmetic packaging manufacturer simplifies gathering material, weight, and construction data for each component.

Heavy Metals in Packaging

PPWR maintains strict limits on lead, cadmium, mercury, and hexavalent chromium. The cumulative concentration of these substances in packaging or its components must not exceed 100 mg/kg.

A simple declaration that heavy metals were not intentionally added is insufficient. Businesses must maintain supporting documentation, such as:

• Material declarations from suppliers
• Raw material specifications
• Laboratory test reports
• Contamination risk assessments
• Technical details regarding recycled content used

If testing reveals heavy metals below the threshold, the packaging may remain in use. However, documentation must clearly show the values for individual substances as well as their combined total. Exceeding 100 mg/kg requires verifying whether a specific exemption applies; otherwise, the packaging must be redesigned.

Labeling, Reporting, and Documentation

PPWR introduces standardized material identification marks to assist consumers with proper waste sorting. Detailed graphic symbols will be finalized through forthcoming implementing acts.

Companies should design labels flexibly to allow for future mandatory markings. Caution is also advised regarding environmental claims about recyclability or secondary raw material content—every claim must be substantiated by documentation.

Businesses must maintain core data for each package:

• Material type and weight of each component
• Recycled content percentage
• Manufacturer and supplier details
• Component assembly method
• Test results and conformity assessments
• Target sales markets

Technical documentation should include engineering drawings, material specifications, test reports, calculations, and risk assessments. Supplier documents must be explicitly linked to specific products, material variants, or production batches.

Supply Chain Collaboration and Non-Compliance Risks

Meeting PPWR standards requires a smooth flow of information between packaging manufacturers, importers, co-packers, and brand owners.

Suppliers must provide precise material designations, individual component weights, recycled content percentages, heavy metal compliance data, and notifications of any changes to raw materials, colorants, or sub-suppliers. While recovery organizations assist with reporting and settlements, they do not assume legal responsibility for packaging design or technical documentation accuracy.

Member states will define specific penalties for non-compliance. Beyond financial fines, non-compliance can lead to mandatory documentation updates, label revisions, batch recalls, sales restrictions, and costly packaging redesigns. Preparing early through thorough audits and clear internal responsibilities is key to mitigating these risks.