What do the rules mean for companies?
The EU has adopted the new Packaging & Packaging Waste Regulation (PPWR) – Regulation (EU) 2025/40, which aims to ensure less waste, better resource efficiency, and more harmonised rules across Member States. At Reccura, we provide a clear overview of who is covered, which requirements apply, and what your company should already be doing now.
🎯 Why is the EU introducing this regulation?
The EU wants to address the increasing volumes of packaging waste and ensure a more circular approach to materials. The regulation aims to:
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📉 reduce waste volumes
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🔄 increase reuse and recycling
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♻️ ensure the use of recycled materials
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🌱 reduce environmental and health impacts
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🧭 create harmonised rules across the EU
Over 40% of plastic consumption in the EU is used for packaging – making this area central to the green transition.
Who is covered?
The rules apply to all companies placing packaging or packaged products on the EU market, including:
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🏭 Manufacturers of packaging or packaged products
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🚢 Importers bringing goods into the EU market
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🛒 Distributors and retailers, including e-commerce
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🌍 Non-EU companies selling online into the EU
It is therefore essential to identify your role as an economic operator first, as the technical documentation you must prepare depends on which role you hold (e.g., manufacturer, importer, distributor, etc.).
🚫 Which types of packaging and practices will be banned or regulated?
The regulation includes bans, limits, and design requirements. Examples include:
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Single-use packaging for items such as fresh fruit and vegetables will be banned from 2030
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Excessive empty space (max. 50% empty space in transport and e-commerce packaging)
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Packaging that cannot be recycled under the new EU standards will be banned from 2030
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PFAS in food-contact packaging will be regulated
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Stricter limits for heavy metals (lead, cadmium, mercury, Cr VI)
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Mandatory minimum recycled plastic content in new packaging
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Compostable packaging: Tea and coffee filters/bags and fruit stickers must be industrially compostable by 2028
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Compostable packaging: All other types (e.g., PLA, PHA) MUST be designed for material recycling, not composting
From 2030, packaging may only be placed on the market if it is recyclable according to the new EU criteria.
Whether your packaging is subject to all requirements depends on the type, intended use, etc. There are exceptions.
📑 Articles 5–12: key requirements companies MUST meet
The regulation includes detailed rules on design, content, and documentation. Below are the key points from Articles 5–12:
Article 5 – Substances in packaging
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Strict limits for heavy metals
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Ban on certain hazardous substances
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Documentation of “substances of concern”
Articles 6 & 11 – Design and recyclability requirements
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Packaging must be designed for recycling
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Mandatory minimum recycled content, especially for plastic
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Requirements for reuse systems where relevant (certain categories apply)
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Limits on excessive empty space
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Packaging minimization requirements during product design
Article 12 – Labelling
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Harmonized EU labelling for material types
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Sorting instructions
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Digital labelling (QR code, DPP) may become mandatory
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Standardized EU-wide pictograms
What must companies do beyond meeting EU’s technical criteria?
You must be able to present:
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Declaration of conformity
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Technical documentation
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Traceability
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Registration in the EPR system (Extended Producer Responsibility)
📌 Final recommendations
We recommend companies start now by:
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Mapping their packaging portfolio
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Assessing compliance with design and material requirements
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Defining their role as an economic operator (importer, manufacturer, etc.)
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Collecting documentation from suppliers
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Planning a transition to recyclable packaging designs
Most requirements will enter into force in August 2026, but packaging and process changes take time—so early action is essential.
We have prepared a guide outlining what must be documented in 2026 and what must be documented in the years leading up to 2040. Download this technical documentation here (available in Danish only).
