The European Union adopted in December 2024 Regulation on packaging and packaging waste (EU) 2025/40 (PPWR), which replaces the previous Packaging Directive (94/62/EC). This Regulation is directly applicable and establishes a harmonised legal framework for all packaging placed on the EU market. Its main objective is reduce the amount of packaging waste a promote reuse, recyclability and supply chain transparencyThe regulation responds to the growing amount of packaging waste and the low reuse and recycling rates, which represent a significant obstacle to achieving a low-carbon circular economy.

Who is affected and when?

PPWR applies to all economic operators, which place any packaging on the EU market, regardless of the material used. This includes manufacturers, importers, distributors, online retailers, direct-to-consumer (D2C) brands and online marketplaces. The regulation entered into force on 11 February 2025 and will apply after an 18-month transition period starting on 11 February 2025. August 12, 2026Some specific obligations will be phased in gradually, with key measures on reuse, recycled content and digital labelling coming into effect between 2027 and 2030, and some continuing beyond 2030.

Key changes and responsibilities:

The PPWR introduces a set of new or significantly expanded legal obligations:

• Online marketplaces are explicitly designated as responsible actors if they provide packaging or logistics on behalf of third-party sellers.
• Packaging design and volumetric efficiency: From August 12, 2026, packaging, including e-commerce packages, must meet strict rules on material and space efficiency. Empty space in packages must not exceed 40 %unless technically necessary. This applies to group, transport and e-commerce packaging.
• Digital labeling: From 2027, packaging must be marked with digital identifiers (e.g. QR codes) linking to structured environmental information, including details on material composition, recyclability and reuse. Packaging containing substances of concern must be marked using digital technology.
• EU Central Packaging Register: By 2029, national packaging databases will be replaced by a single register of manufacturers and distributors at EU level.
• Mandatory recycled content: From 2030, various types of plastic packaging will be subject to minimum recycled content limits ranging from 30 % to 65 % depending on the category. Higher targets are set for 2040, for example 65 % for single-use plastic beverage bottles.
• Reusable packaging option for e-commerce: From 2030, online retailers must offer a reusable delivery option at checkout. This alternative must be clearly presented and no less attractive than disposable options.
• Companies outside the EU: They must appoint an authorized representative within the European Union, a new obligation increasing the responsibility of sellers from third countries.
• Restrictions on the use of certain formats: From 1 January 2030, the placing on the market of packaging in specific formats and for uses listed in Annex V shall be prohibited. These include, for example, single-use plastic group packaging, single-use plastic packaging for unprocessed fresh fruit and vegetables (less than 1.5 kg), single-use plastic packaging for food and beverages consumed directly on the premises of the HORECA sector and very lightweight plastic bags, except for hygiene reasons or to prevent food waste.

Exceptions and risks:

There is no general exemption for micro or small enterprises, but limited exemptions apply. Packaging for medical and hazardous products, B2B packaging and export packaging may be exempted from some targets or obligations under certain conditions. Micro enterprises may be exempted from the restrictions for packaging listed in Annex V if it is technically not possible not to use such packaging or if they do not have access to the necessary infrastructure for a reuse system.

Failure to comply with PPWR may result in legal and commercial consequences, including fines and administrative sanctions under national legislation, restrictions on market access or delisting of products by competent authorities or online platforms, as well as reputational damage. Companies should review their packaging, materials and suppliers now, assess reusable transport options, collect documentation on recycled content and prepare IT systems for digital labelling. Acting early will help ensure compliance and prepare for a market that is increasingly focused on sustainability. JRi