.png)
The PPWR Regulation (EU) 2025/40 on Packaging and Packaging Waste entered into force on 11 February 2025 and becomes enforceable from 12 August 2026, replacing the Packaging and Packaging Waste Directive (94/62/EC) that had been in place since 1994.
Unlike the directive it replaces, PPWR is a regulation: it applies directly across all EU Member States without national transposition. If your company manufactures, imports, distributes, or sells packaged products on the EU market, it applies to you regardless of where you are registered.
What PPWR Requires
PPWR restructures packaging obligations around four pillars:
1. Recyclability. By 2030, all packaging placed on the EU market must meet recyclability Grade A, B, or C defined by what percentage of the packaging unit (by weight) can actually be recycled. Grade C (the minimum) is phased out by 2038, leaving only the two highest grades. Design for Recycling (DfR) criteria will be published by the European Commission in delegated acts by January 2028.
2. Recycled content in plastic packaging. From 1 January 2030, plastic packaging must contain minimum post-consumer recyclate (PCR). Post-industrial recyclate does not count toward these targets.
3. Reuse. From 2030, binding reuse targets apply to transport packaging (40%), intra-EU transport between company sites (100%), and beverage packaging (10%). The HORECA sector must enable consumers to bring their own containers for takeaway.
4. Extended Producer Responsibility (EPR). Producers must register in national producer registers and pay fees that are eco-modulated the lower your recyclability grade and the less recycled content you use, the higher your fees. This is a direct financial incentive for better packaging design.
What Applies from 12 August 2026
Three obligations take effect at the main application date, before the 2030 milestones:
- PFAS ban in food-contact packaging. Concentration limits apply (25 ppb per individual PFAS). Testing and supplier declarations of conformity are required now.
- Void space limit of 40% maximum for all packaging, including e-commerce parcels.
- EPR registration and reporting in each EU market where you sell.
The European Commission published formal implementation guidance and a FAQ on 30 March 2026 to support businesses with compliance interpretation.
What This Means in Practice
PPWR is not just a packaging regulation its implications run across your sustainability reporting, carbon footprint, and product lifecycle documentation.
Switching to recycled-content or reusable packaging changes the emissions profile of your upstream supply chain, which directly affects Scope 3 Category 1 in your GHG inventory. It also changes the end-of-life assumptions in any Life Cycle Assessment or Environmental Product Declaration you maintain. And the recyclability grade of your packaging will increasingly appear in EPR fee calculations, supplier questionnaires, and CSRD double materiality assessments.
For manufacturers, importers, and distributors operating in Romania, the obligations are identical to those in any other EU Member State. EPR registration with the national authority and compliance with design requirements apply regardless of company size PPWR does not provide a general exemption for SMEs.
Where to Start
The businesses most exposed to disruption after August 2026 are those that have not yet mapped their packaging portfolio. A practical first step is a packaging audit covering: materials and recyclability assessment, PFAS testing for food-contact items, void space ratios, and EPR registration status in each relevant market.
Beyond the immediate deadline, the 2030 milestones require supplier qualification for PCR, packaging redesign for reuse-affected formats, and system readiness for digital labelling.
ECONOS works with manufacturers, distributors, and brand owners on the sustainability dimensions of PPWR including Scope 3 carbon footprint measurement, LCA/EPD development, and CSRD reporting. If PPWR compliance intersects with your ESG obligations, get in touch.